Summary of Required Policies Pertaining to Expenditure of ARPA/CSLFRF

The Town of Cornelius has been allocated $9,642,828 from the Coronavirus State and Local Fiscal Recovery Funds of H.R. 1319 American Rescue Plan Act of 2021 (ARPA/CSLFRF). 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. Further, ARPA/CSLFRF 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).

It is a requirement of the ARPA/CSLFRF that these compliance policies be adopted /reaffirmed as it relates to the expenditure of these specific funds.

• Eligible Use Policy: This policy defines the permissible and prohibited uses of the ARPA/CSLFRF funds. It also outlines the procedures for determining how the Town will spend its ARP/CSLFRF funds. Permissible expenditure categories include: 1) support COVID-19 public health expenditures; 2) address negative economic impacts caused by the public health emergency; 3) to provide governmental services through the revenue calculation; 4) provide premium pay for essential workers; and 5) invest in water, sewer, and broadband infrastructure.
• Cost Principles Policy: Defines those items of cost that are allowable, and which are unallowable. The tests of allowability under the cost principles are: (a) the costs must be reasonable; (b) they must be allocable to eligible projects; (c) they must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances; and (d) they must conform to any limitations or exclusions set forth in these principles or in the ARP/CSLFRF grant award as to types or amounts of cost items.
• Records Retention Policy: Outlines Treasury’s five-year record retention requirement for documents related to expenditures ARPA/CSLFRF funds. This record retention requirement is longer than the traditional three-year record retention requirement. The Town shall retain relevant records for a period of five years beyond the final expenditure of ARP/CSLFRF funds.
• Nondiscrimination Policy: Reaffirms that the unit will ensure that no person shall, on the ground of race, color, national origin (including limited English Proficiency), familial status, sex, age, or disability, be excluded from participation in, be denied the benefits of, or be otherwise, subject to discrimination under any program or activity administered by the local government, including programs/activities funded in whole or part with ARPA/CSLFRF.
• Conflict of Interest Policy: Establishes conflict of interest standards that apply when the unit enters into a contract or makes a subaward.