Notice to ARPA-SLFRF Recipients– Important Compliance Information

April 14, 2025

To:   Municipal Clerks, Treasurers, Heads of Government
County Clerks and Treasurers

On behalf of the U.S. Department of Treasury (Treasury), the Wisconsin Department of Revenue (DOR) is providing the following information on Treasury's compliance and recoupment efforts of the American Rescue Plan Act – State and Local Fiscal Recovery Funds (ARPA-SLFRF). For more detailed information review Treasury's March 25, 2025 notice.

Compliance Reviews and Related Recoupment Efforts

On March 25, 2025, Treasury issued a notice, which alerted all recipients of ARPA-SLFRF awards of its efforts to vigorously monitor recipients' methods of obligating funds by the December 31, 2024, deadline and is committed to recouping funds used in violation of SLFRF rules and guidance.

Reporting

  • Quarterly reporters – were required to submit their latest report to Treasury by January 31, 2025, covering obligations through the December 31, 2024, obligation deadline
  • Annual reporters – must submit their next report to Treasury by April 30, 2025, covering obligations through the obligation deadline. Note: All Wisconsin non-entitlement units (NEUs) report annually.
  • Treasury intends to enhance its compliance checks on the obligation data submitted by recipients as part of its efforts to ensure taxpayer funds are used in accordance with program requirements
  • Treasury plans to recoup funds obligated or expended impermissibly and to recapture funds that were not obligated by the deadline
  • Recipients may receive Information Document Requests in support of these efforts and will be expected to promptly comply with such requests

Financial Instructions to Return Unobligated Funds

Recipients that did not fully obligate their award funds by the deadline, based on the latest data available to Treasury will receive the "Financial Instructions to Return Unobligated Funds."

These instructions will:

  • Inform the recipient how much it owes, based on its most recently submitted report
  • Provide a date the recipient must repay the funds by
  • Require recipients to use Pay.gov to process the repayments

If recipients do not repay amounts owed by specified date

  • Treasury will establish a debt and follow standard debt collection policy and procedures in coordination with the Bureau of the Fiscal Service
  • Interest and penalties will accrue once the debt is established

Questions?

  • Contact Treasury at SLFRF@treasury.gov
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