The U.S. Department of Treasury recently released new reporting requirements for the upcoming Project and Expenditure (P&E) Report due April 30, 2023, for the ARPA State and Local Fiscal Recovery Fund.
The portal will open April 1, 2023, for counties to submit their P&E Reports. These updates apply to all counties unless a county allocated its entire ARPA allocation towards the $10 million revenue loss standard allowance.
The P&E Report updates include:
1. Unique Entity ID Requirements for Subrecipients and Contractors:
All subrecipients and contractors are required to have a Unique Entity ID (UEI) and have that number included as part of the reporting process. The UEI is the replacement for the previously used DUNS numbers, and they are issued by SAM.gov. While this requirement is not new, starting in April 2023’s P&E Report the report form will now return an error when no valid UEI is provided when creating new subrecipient or contractor entities. This was previously not explicitly required, but strongly urged by Treasury.
Treasury has stated that for the April 2023 P&E reporting form, if a pre-existing subrecipient or contractor record does not have a UEI, the system will simply flag it as a warning but not prevent them from submitting the entire P&E report.
However, any new subrecipient or contractor records will be required to have their UEIs provided, and they cannot create those entities without one.
Treasury has stated it does not know how long it will be able to keep this flexibility available after April 2023 so counties should get their UEIs together as soon as possible.
2. New Subaward/Direct Payments Entity Type:
All subawards/direct payments records will be required to have an “entity type” selected before a subaward can be created. This field will capture whether the entity receiving the award or payment is a subrecipient, contractor, or beneficiary. If a county attempts to create a new subaward for a subrecipient without a populated entity type field, this will result in an error.
For more information, please see:
