Optimizing Post-ARPA Transition: Ensuring Effective Compliance and Transparent Funding Practices

As ARPA funding has been fully obligated and funds are being spent, the next phase of managing these funds involves ensuring compliance and preparing for future federal funding opportunities. Depending on the status of your ARPA program, you will need to continue monitoring both funding and program progress, ensuring that funds are spent in accordance with the terms and conditions of sub-award agreements.

You must also submit quarterly or annual reports to the U.S. Department of the Treasury. After submitting these reports, continue overseeing all expenditures and progress on projects funded by ARPA to ensure full compliance.

Monitor spending and ensure compliance with ARPA funds

At the same time, the federal government will closely review your submitted reports to ensure compliance and monitor for fraud, waste, or abuse. You can support this process by conducting a detailed desk review. This includes checking the following:

• Financial statements and Single Audit reports
• Active Unique Entity Identifier numbers
• Progress reports on the funded projects
• Updated financial and non-financial policies and procedures
• Risk assessments for internal and external policies
• A conflict-of-interest policy for you and your subrecipients

This desk review is critical in preventing issues before they arise and ensuring that ARPA funds are used appropriately.

The ARPA project closeout process

For the official subrecipient closeout process, ensure the following steps are taken:

•      Verify funds have been fully spent in accordance with the approved project's statement of work and budget.
• Confirm that the awardee has adhered to Federal Uniform Guidance (2 CFR Part 200).
• Ensure you’ve conducted a risk assessment, confirming that the awardee’s risk level has been lowered with appropriate internal and external policies and procedures.
• Review recent annual audits, financial statements, or single audit reports to ensure no material weaknesses have been reported. If weaknesses have been identified, ensure that corrective actions have been implemented.

After completing the project closeout process, an official closeout letter is issued to each subrecipient determined to have met closeout requirements.

Post-ARPA compliance checklist

For a quick reference on the essential steps to ensure compliance and smooth project closeout, refer to our Post-ARPA Compliance Checklist, which provides a clear outline to help guide you through the necessary actions.

What’s next after ARPA funds? Preparing for future federal funding

While finalizing the ARPA closeout process, planning for the next phase is important. Here are steps to help you transition to new federal funding opportunities:

• Stay updated on changes in federal funding by regularly checking Grants.gov, Sam.gov, and USAspending.gov.
• Schedule a meeting with your grant administrator to review upcoming deadlines.
• Create a team to research new federal funding opportunities.
• Align your organization's needs with federal government strategies and programs to ensure alignment with current funding priorities.
• Develop a strategy to show accountability and transparency toward continuous process improvement.

Contact UHY Advisors for ARPA compliance support

As you navigate the transition from ARPA to the next phase, remember that you're not alone. UHY Advisors is here to provide the expertise and support you need to enhance your efficiency and effectiveness.

To schedule a consultation or ask questions about your ARPA compliance or funding strategy, contact our State and Local Government Practice managing director, Jack Reagan, or our senior manager, Claire Collins.