On March 25, 2025, the Department of the Treasury issued a notice announcing its intent to enforce the obligation deadline for The Coronavirus State and Local Fiscal Recovery Funds (SLFRF). With the December 31, 2024 obligation deadline now past, Treasury is turning its focus from reporting to enforcement.
Below is a summary of the announcement and what recipients should know.
What Treasury Announced
According to the notice, Treasury plans to:
- Recoup funds that were not obligated by the December 31, 2024 deadline
- Review obligation data for compliance, including requests for supporting documentation
- Send repayment instructions to recipients who did not fully obligate their awards, based on the most recent reports
While those repayment instructions have not yet been released, Treasury stated they are expected in the next few weeks. The instructions will outline how much is owed, the deadline for repayment, and how to remit payment via Pay.gov. The agency also noted that interest and penalties will apply if debts are not repaid on time.
What This Means for SLFRF Recipients
If you are an annual reporter, this notice adds weight to the upcoming April 30, 2025 reporting deadline. The upcoming report will be based on data through the obligation cutoff, making it an important point of review for SLFRF compliance.
Recipients may also receive formal documentation requests from Treasury as part of its expanded review process. Being able to respond quickly with accurate documentation is important.
If you manage SLFRF reporting or compliance, now’s a good time to confirm that your records align with what’s being submitted and that you’re ready to respond to any requests Treasury may make.
Resources To Support Reporting and Compliance
The Treasury is hosting a workshop series this month:
- April 9th: Navigating SLFRF Reporting in the 2025 Annual and Q1 P&E Report Workshop (Session #1)
- April 15th: Navigating SLFRF Reporting in the 2025 Annual and Q1 P&E Report Workshop (Session #2)
If you need more details on the full SLFRF requirements, here are some resources on reporting requirements, obligations, and practical next steps:
- Updated SLFRF Compliance Checklist
-
ARPA SLFRF Reporting Language: What to Know (National League of Cities Blog)