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SUMMARY OF TREASURY'S ARPA INTERIM FINAL RULE GUIDELINES

Articles & Insights Oct 05 2021

TABLE OF CONTENTS

1. Background
2. Public Health and Economic Impacts
3. Premium Pay
4. Government Services/Revenue Loss
5. Investments in Infrastructure
6. Other Provisions
7. Appendix 1: Allowable Use Matrix

This document was created to highlight the applicable high-level rules, considerations, and guidance from the U.S. Department of Treasury's Interim Final Rule. This brief walks through the material in the same order as it is presented in the Interim Rule.

Eligible uses of these funds were pulled from the Interim Final Rule and categorized in an 'Allowable Use Matrix'. Please note that portions of the Interim Final Rule do not provide specific examples or offer vague guidance and details. In the instances where no precise examples were provided, or vague direction was given, the guidance language section of the Allowable Use Matrix was left 'blank’.

On March 11, 2021, the American Rescue Plan Act ("ARPA") of 2021 was signed into law. Two signature programs of the ARPA are the Coronavirus State Fiscal Recovery Fund ("SFRF") and the Coronavirus Local Fiscal Recovery Fund ("LFRF"). The attached document is a high-level review of the Interim Final Rule issued by
the U.S. Department of Treasury for these two programs on May 10, 2021.