TITLE
Title
ARPA CORONAVIRUS LOCAL FISCAL RECOVERY FUNDS MANAGEMENT POLICIES
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SPONSOR
Sponsor
Tiffany Oliva (Amy Addington)
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BACKGROUND
Background
The County is administering $104,339,752 in American Rescue Plan Act (ARPA) funding received from the United States Treasury Department. The Treasury Department requires Guilford County to adopt and follow policies incorporating eligible uses, program income, cost principles, policy management, records retention, nondiscrimination, conflict of interest, and subaward and monitoring primarily outlined in the Federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R. Part 200). By adopting these policies and procedures, the County will reinforce its agreement with the Treasury Department that it has the institutional, managerial, and financial capability to ensure proper planning, management, and completion of ARPA funded projects. With these policies in place, the Board can proceed with projects and award grants to subrecipients. It will also provide the roadmap for proper reporting and ongoing monitoring of its project and those of the subrecipients. Finally, these policies and procedures will help mitigate the risk of non-compliance and potential recoupment of the grant funding. In instances, if any, where retention time differ from the County's Adopted retention schedule as compared to the attached ARPA retention policies, the longer retention period will control.
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RESOLUTION
resolution
RESOLUTION APPROVING COUNTY POLICIES TO AID IN ADMINISTERING FEDERAL CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS FROM THE AMERICAN RESCUE PLAN ACT
WHEREAS, Guilford County has been allocated $104,339,752 from the Coronavirus State and Local Fiscal Recovery Funds of H.R. 1319 American Rescue Plan Act of 2021 (ARPA/CSLFRF);
WHEREAS, CSLFRF funds are subject to the U.S. Department of Treasury (“Treasury”) regulations, including the Final Rule, the Award Terms and Conditions, and the Title VII implementing regulations at 31 C.F.R. Part 22;
WHEREAS, the funds may be used for projects within these categories, to the extent authorized by state law:
1. Support public health expenditures, by funding COVID-19 mitigation efforts, medical expenses, behavioral healthcare, and certain public health and safety staff;
2. Address negative economic impacts caused by the public health emergency, including economic harms to workers, households, small businesses, impacted industries, and the public sector;
3. Replace lost public sector revenue, using this funding to provide government services to the extent of the reduction in revenue experienced due to the pandemic;
4. Provide premium pay for essential workers, offering additional support to those who have borne and will bear the greatest health risks because of their service in critical infrastructure sectors; and
5. Invest in water, sewer, and broadband infrastructure, making necessary investments to improve access to clean drinking water, support vital wastewater and stormwater infrastructure, and to expand access to broadband internet;
WHEREAS ARPA/SLFRF funds are subject to the compliance requirements as listed in the Award Terms and Conditions and the Assistance Listing (21.027) which are primarily focused on the federal Uniform Grant Guidance, 2 CFR Sect. 200 (UG);
WHEREAS, the County intends to fully implement all compliance requirements required by the Award Terms and Conditions and the Assistance Listing to ensure the institutional, managerial, and financial capability to manage its internal projects and the potential subrecipients’ projects;
NOW, THEREFORE, BE IT RESOLVED, that the following policies, which shall apply to the operations of any program, activity, or facility that is supported in whole, or in part, by expenditures CSLFRF pursuant to the ARPA/CSLFRF award, attached hereto and incorporated herein by reference, are hereby adopted and enacted by the Guilford County Board of Commissioners:
1. ARPA Nondiscrimination Policy
2. ARPA Records Retention Policy
3. Conflict of Interest Policy
4. Cost Principles Policy
5. Eligible Use Policy
6. Program Income Policy
7. Real Property Policy
8. Subaward Policy
BE IT FURTHER RESOLVED, that this resolution is retroactively effective to the date of receipt of the first tranche of ARPA/CSLFRF on May 19, 2021.
BE IT FURTHER RESOLVED, that where federal compliance requirements change, these policies shall be deemed to automatically incorporate those changes.
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BUDGET IMPACT
Budget Impact
NO ADDITIONAL COUNTY FUNDS REQUIRED
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REQUESTED ACTION
Requested Action
Adopt resolution approving County ARPA policies to aid in administering the Federal Coronavirus State and Fiscal Recovery Funds from the American Rescue Plan Act, and authorize staff to take all reasonable actions to comply with federal compliance requirements. When federal compliance requirements change, these policies shall be deemed to automatically incorporate those changes.
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