Obligating ARPA Funds

Consistent with the final rule issued by the US Treasury, all ARPA funds must be obligated by December 31, 2024. The information below will clarify the amended definition of "obligation" and several related issues.

WEBINAR: U.S. Department of the Treasury: State and Local Fiscal Recovery Funds: New Obligation FAQs

The updated obligation-related FAQs are found in the new Section 17: https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf

  • What is an obligation? Please refer to Section 17 of the SLFRF FAQs for the latest information on the obligation requirement and how to meet the obligation deadline of December 31, 2024.
  • Do subrecipients have an obligation deadline? No. Refer to FAQ 17.18.
  • Are revenue loss funds automatically obligated? No. Refer to FAQ 17.15.
  • Questions about personnel costs in 2025 and 2026: Refer to FAQs 17.6, 17.7, and 17.9.
  • Questions about flexibilities for contracts after the obligation deadline: Refer to FAQs 17.16, 17.17, and FAQ 17.19.
  • What if I have questions about legal and administrative costs after the obligation deadline? For more information on these expenses, refer to FAQs 17.10, 17.11, 17.12, and 17.13.
  • What if my community has already obligated all of our SLFRF funds?  Please see FAQ 17.3 and 17.14.  Remember that all SLFRF recipients are required to continue to submit reports to Treasury as outlined in the SLFRF Compliance and Reporting Guidance.