American Rescue Plan Act (ARPA)

Overview

During the pandemic and continuing to today, we have directed our deep bench of legal talent and resources to serve dozens of units of government with their American Rescue Plan Act (ARPA) federal stimulus allocations – including ESSER and State and Local Fiscal Recovery Funds.

Our internal “strike team” of ARPA-informed attorneys have handled – on a daily basis since early 2021 – questions as to, “Can I spend our money on X?” and “How can I purchase ARPA-funded services for Y?” Such guidance by the firm on ARPA expenditures has been provided to counties, cities, townships and local school districts, including two of the nation’s Top 10 largest municipal recipients of Local Fiscal Recovery Funds.

We provide efficient and timely regulatory compliance, eligible use-of-funds, and federal procurement rules counsel to state, county, municipal, and township clients in expending ARPA funds under U.S. Treasury guidance issued in the 2022 Final Rule (31 C.F.R. Part 35), the 2023 Interim Rule, and regularly updated Frequently Asked Questions (among other guidance documents).

Our legal services include interpreting the U.S. Treasury’s issued guidance on eligibility, drafting authorizing resolutions and subgrant agreements, and advice as to procurement and contracting compliance under the federal Uniform Guidance. We also provide legal and administrative support with reporting obligations under ARPA, helping public entity clients with quarterly or annual ARPA reporting to the U.S. Treasury.