American Rescue Plan Funding Guidance

The Tennessee Comptroller of the Treasury released a memorandum on July 9, 2021, regarding additional guidance on the American Rescue Plan Act.  In this memorandum, the Comptroller referenced the U.S. Treasury expectation to publish their final guidance in September.  The Comptroller also encouraged local governments wait to finalize plans to use of these funds until the final guidance is received.

CTAS has received various questions regarding eligible expenditures, sub-recipient monitoring, accessing the U.S. Treasury Portal, and reporting requirements.  As a result, CTAS has regularly contacted the Tennessee County Services Association, the Comptroller’s Office, and Finance and Administration over the last several weeks, working to provide counties with accurate responses.  Unfortunately, final guidance remains unpublished, resulting in the inability to answer many questions.

CTAS offers the following suggestions for counties to consider pending publication of the final guidance:

• Establish a committee that will be responsible for reviewing funding requests and developing a spending plan.
• Develop processes that include:
  • How funds can be requested;
  • Screening and evaluation of funding requests; and
  • How to categorize and prioritize the funding requests to ensure they fall within the four authorized categories outlined in the U.S. Department of the Treasury’s Interim Final Rule. 

Counties have communicated that they are considering multiple options for use of the funds.  Before making definite determinations, CTAS encourages counties to plan these expenditures strategically.   

• Consider funding those projects/ideas that will have a comprehensive and long-lasting effect on your counties;  
• Consider including community stakeholders in soliciting ideas for spending; and
• Consider opportunities for collaboration with state stakeholders.

We understand that many of these ideas have already been considered and implemented in counties across the state.  CTAS is offering these suggestions to assist in developing your spending plans until the final guidance has been published.  Once published, the final guidance will provide answers to many of your questions, enabling you to properly prioritize the use of your funds.  This prioritization will minimize the potential exposure to liability for spending funds inconsistent with one of the four authorized American Rescue Act Plan funding categories.

CTAS County Government Consultants are available to assist you in any way possible.  We encourage you to continue to reach out to your consultant for assistance.  Additional guidance for local governments about the American Rescue Plan can be found at the Tennessee Comptroller of the Treasury’s website: https://comptroller.tn.gov/about-us/learn-about-our-office/administration/covid-19-guidance-for-local-governments.html.