For a while there was a huge burst of interest in the America Recue Plan Act of 2021 (ARPA) which provided $350 billion to tribal governments, states, Washington D.C. U.S. territories and more than 30,000 local governments. The goal was to help dig these many entities out of the fiscal holes that were created by the pandemic.

To provide oversight to this huge pile of cash, the Treasury Department called for regular filings from the governments that were allocated money. Although the majority of recipients complied with those requirements,  a surprising number of entities seemed to ignore them entirely, according to a July 22 report from the U.S Government Accountability Office (GAO).

Here are some of the most significant findings from that report:

• “In each year from 2022 to 2024, thousands of SLFRF recipients did not meet the reporting deadline for P&E (project and expenditure) reports. For example, 4,272 recipients— accounting for $2 billion in SLFRF awards—missed the deadline in 2024.” [Note: SLFRF stands for State Local Fiscal Recovery Funds]

• “Treasury has issued notices of noncompliance and conducted targeted outreach, but reporting remained inconsistent. As of January 2025, 1,012 recipients, mostly smaller localities—had never submitted a P&E report”.

• “While Treasury’s procedures allow Treasury to initiate recoupment with noncompliant recipients, the procedures do not require recoupment at any point and time and recoupment efforts have been inconsistent. Treasury started sending initial notices of recoupment in January 2025 to 988 of the 1,012 recipients that had never submitted a P&E report. Of those, 339 (34 percent) subsequently submitted a report between January and March 2025.”

These filings were critical to the Treasury Department’s capacity to adequately oversee this money. As the report concludes, the lack of documentation has limited Treasury’s (timely) ability to determine whether the recipients were spending SLFRF funds on allowable uses.

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