Local Finance Notice 2021-21 American Rescue Plan Act of 2021: Effective Planning; Equity & Evidence Requirements
This Notice reviews recent State Comptroller guidance and summarizes recent U.S. Treasury guidance on assessing optimal uses of Coronavirus Local Fiscal Recovery Funds and equitable implementation of LFRF-funded recovery programs.
Effectively Deploying LFRF Funds
- Local governments should engage with community stakeholders to assess community needs, determine priorities, and analyze potential costs to ensure LFRF funds are used efficiently.
- Municipal and county planning should account for other funding streams to effectively coordinate response to the pandemic’s negative economic impacts.
- Local governments are strongly encouraged to utilize the State’s existing infrastructure to administer ARP funds used for housing, rental, utility, or other assistance programs. The Division of Housing will determine an appropriate amount to be charged for offsetting the Division’s administrative costs.
- Municipalities and counties considering LFRF-funded landlord assistance programs should also be aware of the Small Landlord Emergency Grant (SLEG) Program administered by the Housing and Mortgage Finance Agency.
- Local governments should review the Small Business Emergency Assistance Grant and Loan Programs, NJ Entrepreneur Support Program, and CDFI Emergency Assistance Grant/Loan Loss Reserve Fund Program before offering small business assistance.
- Municipalities and counties should weigh how LFRF funds can achieve maximum longer-term impact while minimizing future unfunded legacy costs. Projects expected to exceed $12.5 million must be submitted to the Office of the State Comptroller for review at least 30 calendar days prior to advertisement.
Advancing Racial and Economic Equity for Underserved Communities
- President Biden’s Executive Order 13985 calls for promoting racial and economic equity as a core part of management and policy making processes, and for successful equity work to yield tangible changes positively impacting American lives.
- The Executive Order 13985 defines equity as the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment.
- Local units may deploy LFRF funds toward eligible uses under Expenditure Category 3 (Services to Disproportionately Impacted Communities), which focuses on addressing disproportionate COVID-19 economic and public health impacts on the hardest-hit communities, populations, and households.
- The U.S. Treasury strongly encourages all counties and municipalities to follow the Recovery Plan Template to improve equity and solicit diverse input from underserved communities.
Evidence-Based Intervention & Program Evaluations
- The Recovery Plan report must include whether ARP LFRF funds are being used for evidence-based interventions and/or rigorous program evaluations.
- The term “intervention” refers to a program designed to deliver social benefits and develop human capital of specific communities. The project must have a strong or moderate evidence base, and must consist of one or more well-designed and well-implemented experimental studies.
- Local units are encouraged to use evidence clearinghouses to assess the level of evidence for a particular intervention and identify evidence-based models that could be applied in their jurisdiction.
- U.S. Treasury encourages using learning agendas to develop evidence to support policymaking, which are strategic evidence-building plans highlighting priority questions and focusing attention on building evidence needed to solve big problems.
- A learning agenda is a document that describes how an agency intends to develop evidence to support policymaking. It includes a list of policy-relevant questions, a list of data, a list of methods, and a list of challenges.
- Local units are exempt from reporting on evidence-based interventions when a program evaluation is being conducted. They must describe the evaluation design, key research questions, statistical power, and timeframe for completing the evaluation.
Local Finance Notice 2021-21
Please follow the link below to read more about these items and guidance on how your local unit can implement them: https://www.nj.gov/dca/divisions/dlgs/lfns/21/2021-21.pdf
Contact Wielkotz & Company, LLC Today
For further information on Local Finance Notice 2021-21 and its implementation feel free to reach out to Steven Wielkotz at (973)-835-7900 ext. 201 or sdw@w-cpa.com.