Capital Projects Fund – reporting and compliance requirements

Recipients of allocation grants from the Capital Projects Fund are required to “meet construction, reporting, and compliance requirements.”

Treasury says they will put out more detailed information about fulfilling these requirements in the coming weeks.

Public reporting requirements

Required under Transparency Laws, Treasury must legally disclose to the public1:

  • Grant Recipients names
  • Amount of grants awarded
  • Other information provided by Recipients in their Grant applications or Grants Plans

Treasury stated in their guidance they “will post this information on their website and report this information on the usaspending.gov
website, which allows the public to see how the federal government has distributed COVID-19
relief funding1.”

Other reporting requirements – Capital Projects Fund

Each Capital Projects Fund Recipient will be responsible for completing the reporting requirements as listed below1

  • Submit Project and Expenditure Reports – Reports submitted quarterly to Treasury that include data in relation to “Projects, expenditures, Project status, subawards, civil rights compliance, equity indicators, community engagement efforts, programmatic data such as geospatial data for Broadband Infrastructure Projects, and other measures as determined by Treasury.” These reports aim to give the public transparency on whether Capital Projects are practicing and promoting efficient on-time and on-budget delivery. “Treasury will seek information from Recipients on their workforce plans and practices related to Capital Projects Fund Projects, as well as information about subcontracted entities1.”
  • Submit Performance Reports – Annually and demonstrate the results of the Capital Projects Fund-financed grant programs. “Reports must include data related to Project and Program outputs and outcomes against the stated objectives of the Recipient’s Grant Plan.” Costs associated with collecting and measuring performance data and conducting activities needed to establish and maintain a performance management and evaluation regime, including program evaluations conducted in support of Performance Report requirements, are eligible under the Capital Projects Fund1.

The reporting requirements will vary by the use of allocation grants and project type1. Treasury says they will put out more detailed information about fulfilling these requirements in the coming weeks2.

Compliance requirements for construction

Capital Projects Fund grant Recipients must complete an environmental checklist (available on the Capital Projects Fund website) to ensure projects funded comply with all applicable environmental laws.

Project completion details

Treasury states that all Capital Projects “reach substantial completion prior to December 31, 2026.”

As defined by Treasury substantial completion “is defined as the date for which the Capital Projects can fulfill the primary options that it was designed to perform, delivering services to end-users. At substantial completion, service operations and management systems infrastructure must be operational1.”

Recipients are allowed to request an extension beyond December 31st, 2026 if the factors hindering the completion of the project are outside of the Recipient’s control. The extension requests will be accepted on a case-by-case basis by Treasury1.

Source:

1 – U.S. DEPARTMENT OF THE TREASURY. (2021, September). Guidance for the Coronavirus Capital Projects Fund. Retrieved October 25, 2021, from https://home.treasury.gov/system/files/136/Capital-Projects-Fund-Guidance-States-Territories-and-Freely-Associated-States.pdf

2 – U.S. Department of Treasury. (2021, October 22). Capital Projects Fund. Retrieved November 02, 2021, from https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/capital-projects-fund

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