SLFRF Recipients Considerations for Navigating Reporting Requirements

On March 25, 2025, The U.S. Department of the Treasury (Treasury) issued an alert to recipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) awards, emphasizing its commitment to monitoring the appropriate obligation of all SLFRF funding by the December 31, 2024, deadline.   

Treasury communicated an intent to “vigorously monitor” reported funding obligations and quickly work to request return of any obligated funds based on either the reports submitted on January 31, 2025 (for quarterly reporters) or those due on April 30, 2025 (for annual reporters). 

Recipients of SLFRF should ensure accurate and timely completion of required reporting to reflect the full obligation and expenditure of SLFRF funds to date, while also preparing for the need to provide additional support or information to Treasury related to the method of obligations. 

To aid recipients in reporting SLFRF data, Treasury has published new and updated resources to assist with the completing the reporting requirements:

Accurate and timely reporting is crucial not only for maintaining compliance but also for seeking to maximize the impact of your organization's funding. To prepare for a seamless reporting period, consider the following:

  • Verify you can access the Treasury Portal
  • Track and maintain organized records for ARPA expenses
  • Monitoring SLFRF guidance released from Treasury
  • Identify and evaluate resources within your organization
  • Compile all new subrecipient information

Though an exact timeline was not provided in Treasury’s communication, SLFRF recipients can expect to soon see increased compliance checks and Information Document Requests from Treasury. These requests will require recipients to support and describe the outstanding obligations and use of funds through December 31, 2024, as Treasury looks to recoup funds that were impermissibly obligated or expended or went unobligated past the established deadline. 

In instances of non-compliance, Treasury will issue "Financial Instructions to Return Unobligated Funds" to recipients who did not fully obligate their funds by the deadline, specifying repayment amounts, deadlines, and procedures. If repayment is not made by the specified date, a debt will be established, and interest and penalties will accrue, in coordination with the Bureau of the Fiscal Service.

BDO assists clients in navigating the complexities of grants management by providing guidance and support throughout the entire process. Our team of experienced professionals helps organizations understand and comply with grant requirements, assisting with accurate and timely reporting to help optimize funding impact. We offer tailored solutions for grant application, management, and compliance, helping clients identify eligible opportunities and effectively manage awarded funds. By leveraging BDO's extensive knowledge and resources, clients can confidently address challenges related to grant administration, mitigate risks, and enhance their overall financial and operational performance. We invite you to reach out to BDO today to discover how our knowledgeable professionals an support your organization's grants management needs and drive success.

BDO understands the historic moment communities have navigated as they manage their recovery from COVID-19. As a state, local, and Tribal governments work to navigate the requirements and intricacies of the SLFRF, our team is well-versed and experienced in providing guidance to clients to support strategic and sustainable funding of their plans. We continue to support states, local governments, hospitals, and public housing authorities manage capital received through the Coronavirus Relief Fund, the American Rescue Plan Act, FEMA Public Assistance for COVID-19, and a variety of other Federal grants. BDO’s professionals have vast experience in grants management, forensic audit, fraud prevention, and disaster recovery and are positioned to support you navigate the strategy and compliance of managing Federal grants.