ARPA SLFRF closeout checklist: December 31, 2026 to April 30, 2027

The dates

• December 31, 2024 (passed)Funds had to be obligated.
• September 30, 2026 (passed)Spending deadline for Surface Transportation and Title I projects.
• October 31, 2026Third-quarter 2026 Project and Expenditure report due for quarterly reporters.
• December 31, 2026All other funds must be spent. This is also the end of the period of performance. Unspent funds go back to Treasury.
• April 30, 2027Final Project and Expenditure Report due, for quarterly and annual reporters alike. Administrative closeout costs can be paid until this date.

Before December 31, 2026

1. List every open project with its obligated amount, amount spent to date and the remaining balance.
2. Flag balances that may not be paid in time: invoices not yet received, retainage, change orders, delayed deliveries.
3. Chase subrecipients and contractors for final invoices now. Spending means money actually paid out, not just billed.
4. Check whether a falling-through obligation can be reclassified. Treasury allows funds obligated by December 31, 2024 to be moved to another eligible project when the original activity falls through, within its rules. See Treasury's FAQ 17.19 and its reclassification guide, and document the decision.
5. Write down why each move is allowed, with the eligible use category and the obligation it rests on. Your auditor will ask.
6. Get the decision approved by whoever your policy requires, such as the governing board, finance director or counsel.
7. Pay everything you can by December 31.

January to April 2027

1. Reconcile ARPA ledgers to bank records and to the amounts in your earlier reports.
2. Settle stray items. Treasury's newer FAQs, 17.25 to 17.28, cover subrecipient invoices and uncashed or voided checks around the closeout.
3. Prepare the final Project and Expenditure Report in Treasury's portal using the current user guide. Note that the 2026 cycle does not let you report projects above the amount obligated in the report that covered the obligation deadline.
4. Submit by April 30, 2027.
5. Return unspent funds only when Treasury asks. Treasury's closeout resource says not to send money back until it formally requests it.
6. Watch for the Award Closeout Notice. The award is not closed until Treasury issues it.

After closeout

• Keep records for the period your award terms and the Uniform Guidance require.
• Expect ARPA spending to appear in your Single Audit for the years funds were spent.

This checklist summarizes Treasury guidance. It is not legal or accounting advice. Your finance director, auditor or counsel should review any reclassification before it is made.