ARPA closeout
Keep your ARPA dollars from going back to Treasury
American Rescue Plan funds that are not spent by December 31, 2026 go back to Treasury. Celsari reviews your open projects, finds balances that will not be paid out in time, and prepares the documentation to move them to eligible projects within Treasury’s rules. Then we help you finish the final reporting.
The deadlines
- December 31, 2024Funds had to be obligated. This date has passed.
- October 31, 2026Third-quarter 2026 Project and Expenditure report is due.
- December 31, 2026Funds must be spent, meaning cash paid out. Unspent funds are returned to Treasury. The date was September 30, 2026 for surface transportation and Title I projects.
- April 30, 2027The final Project and Expenditure report is due. Closeout costs, such as reconciling the ledger and finishing reports, can be paid through this date (FAQs 17.5 and 17.24). Records are kept for five years.
Sources: Treasury, Quick Reference Guide; Treasury, Compliance and Reporting Guidance.
Treasury is following up. Between March and October 2025 it told 1,041 recipients to return $59.5 million in funds that were not obligated by the 2024 deadline. GAO also found 135 local governments that had never filed a report, covering $6.1 million in awards. Source: GAO-26-108587.
What Treasury allows
Treasury does not allow new obligations, but it does let a recipient move excess funds that were obligated and not spent to another project that is eligible under the program rules, as long as the recipient had an obligation for that project by December 31, 2024. A project that was never under contract by then cannot take the money. The same freed-up funds can also cover cost increases on a 2024 contract that allows change orders, reporting and compliance costs, and closeout costs. The recipient attests to the obligation date and keeps the documentation. Treasury publishes the portal steps.
The move has to be supported. The paperwork behind it is what a monitor or auditor reads if the move is ever questioned, and it is most of the work.
Sources: Treasury, Reclassification How-To Guide for the SLFRF Program; Treasury, SLFRF Final Rule FAQ, section 17 (FAQs 17.16 and 17.19). Whether a particular move is allowed depends on the facts; we read your files against Treasury’s guidance before we say.
What you get
- A balance-at-risk map: every open project, what was obligated, what has been paid, and what realistically clears by December 31.
- A reclassification plan: which earlier obligations can take an at-risk balance.
- The written justification for your file.
- Portal entries prepared for your finance staff to review and submit.
- A check of your third-quarter report if it is not filed.
- Afterward: help with the final report and a records file for the five-year retention period.
Where our work ends
We prepare and recommend. Your finance director reviews and signs off on everything, and your own staff make the entries in Treasury’s portal. We do not submit anything for you, and we do not ask for your portal password. For larger moves we suggest your auditor or counsel read the justification.
We cannot guarantee that a given balance can be saved. If your funds are already spent, or nothing can move, we will tell you in the first conversation and stop there.
How it works
Free balance review
A 15-minute video call. You pull up your open projects and we look at what is obligated and what has been paid.
Fixed-price plan
If there is a balance at risk, we quote a flat fee in writing. We ask you for a short list of documents to reconcile your portal, your ledger and your contracts.
Plan and entries
We deliver the risk map, the reclassification plan and the justification, and prepare the portal entries early enough to fix anything the portal rejects.
Questions we hear
Our auditor handles ARPA. Why would we need you?
Auditors check what you did. This work happens before the deadline, so there is something correct to check. We work alongside your auditor and are glad to send them our materials.
Can we do the reclassification ourselves?
You can. The portal entry is short. The part that takes time is the written justification, because that is what is read if the move is questioned. We can also review a justification you have written.
Most of our funds are revenue replacement. Does that matter?
It can. Revenue replacement funds are often easier to close out, and some municipalities will not need help. We will tell you honestly after a first look at your numbers.
How is this allowed?
It comes from Treasury’s own guidance. We link the sources on this page so you and your auditor can read them first.
Is this legal advice?
No. We prepare documents and analysis. Your finance director and your counsel decide what to submit.
Find out in 15 minutes whether any balance is at risk
Send us your open-project list or book a short video call. If nothing is at risk, we will say so.