As you are undoubtedly aware, ARPA funds must be “obligated” by December 31, 2024. US Treasury regulations define “obligation” to mean that an order has been placed for property or services or the municipality has awarded contracts, subawards, or similar transactions that require payment. Accordingly, it is not sufficient for the Select Board to vote to use ARPA funds for a particular project, supply, or service prior to the end of this calendar year. There must be a binding commitment in place by the deadline in order for the funds to be properly “obligated.” Given that the municipality must still comply with state procurement rules and may have local procurement rules for compliance, it may be most expedient at this late date to commit ARPA funds towards an existing contract or construction project in progress.
One thing we can all agree on is that we do not want any municipality to return the funds to the US Treasury due to missing this deadline!
Please contact us as further questions arise.
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