The Kentucky Department for Local Government (DLG) sent most cities on Thursday a budget certification form associated with American Rescue Plan (ARP) funds. Each city will need to complete the budget certification form prior to obtaining ARP money next month.
The American Rescue Plan precludes cities from receiving funding that amounts to more than 75% of their annual budget as of January 27, 2020. For purposes of the budget certification, cities can use all general and special funds to get the total budget figure.
The budget certification requirement differs from the revenue loss calculation, which excludes utilities, federal intergovernmental transfers, issuance of debt, and other uncommon situations from general revenues. Cities can include all sources of revenue for their budget certification.
Non-entitlement communities – all Kentucky cities except Ashland, Bowling Green, Covington, Elizabethtown, Henderson, Hopkinsville, Lexington, Louisville, and Owensboro – must certify their budget amount to the Department for Local Government. DLG acts as a pass-through entity for non-entitlement communities; the nine entitlement cities apply directly with the U.S. Department of the Treasury.
The budget certification form requires cities to include their FY 2020 budget that was in effect prior to January 27, 2020. That includes the entire year and any amendments a city passed for that fiscal year prior to that date.
In addition to contact and financial information, the form requires your federal tax identification number (EIN), DUNS number, and SAM registration number. The SAM registration number is the same as the CAGE code you receive after you complete the SAM registration. Mayors must sign the certification form.
By law, DLG has until June 9, 2021, to allow non-entitlement communities to access the first tranche of ARP funding; however, DLG may seek an extension from Treasury. Cities may receive half of their total allocation this year and the other half roughly 12 months later. Cities generally have until December 31, 2024, to expend their funds.
Except for the certification form, cities should not yet contact DLG about their allocation, Treasury guidance, or other concerns with the American Rescue Plan. Please contact the Kentucky League of Cities with questions or concerns about the regulatory guidance, frequently asked questions, and allowable expenses.