Notice

ARPA Update

December 2nd, 2025

It has been nearly a year since the deadline to obligate ARPA funds has passed. Your borough should now be looking towards the expenditure deadline, which is December 31, 2026, for all eligible uses except Surface Transportation projects and Title I projects if the projects conducted with ARPA funds have not been spent.

Given this stage of the ARPA process, your borough may have met the necessary requirements for Treasury to initiate early closeout. Boroughs that have reported fully expending their ARPA allocation may be invited to close out their account ahead of the period of performance end date. As of summer 2025, Treasury has initiated this process on a rolling basis, notifying recipients with instructions as applicable.

Please review the State and Local Fiscal Recovery Funds (SLFRF) Award Closeout Preparation Checklist, which serves as a vital resource for recipients who have fully obligated and expended their ARPA funds. It offers comprehensive guidance to ensure recipients are fully prepared when it is time to close out their awards.

The Treasury Department has begun to notify municipal governments that did not obligate all funds by December 31, 2024, that they will be required to return those unobligated funds. The unobligated balance is determined based on the most recent P&E Report submitted to Treasury following the obligation deadline. Boroughs who have received instructions to return funds are not permitted to revise previously submitted P&E Reports.

If unobligated funds are not returned to Treasury by the deadline specified in the “Instructions to Return Unobligated SLFRF Funds” email that was sent on September 19th, Treasury will proceed with the recoupment process outlined in the American Rescue Plan Act.

The next step in the recoupment process will be the issuance of an Initial Notice of Recoupment. Recipients will have the opportunity to remedy their noncompliance or to submit a request for reconsideration within a specified timeframe. In all cases, Treasury will issue a Final Notice of Recoupment, which will include the final amount to be returned, if any.

For any questions regarding this process, please contact Ron Grutza at rgrutza@boroughs.org, Logan Stover at lstover@boroughs.org , or Wendy Nickerson at wnickerson@boroughs.org.