ARPA SLFRF Annual Reporters: Use October to Prep for the April 30, 2026 Report

September 29, 2025

If you’re a non-entitlement unit (NEU) or another Tier 4–5 recipient under ARPA’s Coronavirus State and Local Fiscal Recovery Funds (SLFRF), your next annual Project & Expenditure Report isn’t due until April 30, 2026. That breathing room is a gift—use it to get your house in order before the next reporting cycle and eventual closeout. 

Why now? While quarterly reporters are gearing up for the October report, annual reporters have likely not logged into the Treasury portal or even thought about reporting in the past six months.   In today’s day and age, electronic identifiers and multi-factor authentication might safeguard your information, but if you’re used to writing your password down on a piece of paper these safety features might cause users to struggle to access those systems and accounts that they do not use regularly.  During the last annual reporting cycle some of the most significant issues we saw with reporting were not programmatic or even counting dollars and cents, but staff turnover and access issues. 

A quick “readiness” checklist you can finish this quarter to prepare for the spring deadline: 

Access & roles

• Log into the Treasury portal via Login.gov/ID.me and verify every staffer who needs access still has it; update user roles after turnover.

• Confirm your Points of Contact (POCs) and recovery email/phone are current.

Entity status 

• Make sure SAM.gov registration is active and your UEI data matches the Treasury portal record (legal name, TIN, banking).

• Re-validate debarment/exclusion checks are included in your procurement files before paying any outstanding invoices to contractors.

Documentation hygiene 

• Spot-check your SLFRF file structure against your internal SOP/controls (2 CFR 200 alignment): procurement, contracts/subawards, performance evidence, drawdown support, equipment/asset logs, and records retention.

• Reconcile project ledgers to your GL and prior P&E submissions; flag variances now—not the week before filing.

Performance & transparency 

• Refresh logic models/KPIs so outcomes and outputs map cleanly to projects and expenditures.

• Draft your 2026 P&E skeleton (projects, narratives, totals) so you’re only updating deltas next spring.

Subrecipients & partners 

• Reevaluate risk assessments for subrecipients; confirm monitoring coverage plans are achievable with current staffing.

• Validate pass-through entities have current SAM/UEI status and active agreements.

Closeout foresight 

• Work backward from 12/31/2026: develop a timeline to close out projects without knowing if you will have the traditional 120-day liquidation period.

• If you’ve already fully expended funds, be ready in case Treasury notifies you that you’re eligible for early closeout, and consider what documentation Treasury might require.

What “ready” looks like by year-end 

• No orphaned users, locked accounts, or outdated POCs in the Treasury portal.

• SAM.gov active; UEI/Banking consistent across systems.

• Clean, indexed documentation that would satisfy a monitor or auditor without a scramble.

• A pre-drafted P&E report and updated dashboards so April 2026 is a click-through, not a fire drill.

Bottom line: Even with no filing due until April 30, 2026 for annual reporters, the smartest NEUs and Tier 4–5 recipients are using this window to eliminate access risks, tighten files, and rehearse closeout. Your future self (and your auditors) will thank you. 

Managing grants efficiently, without compromising compliance and integrity, can be a challenging task. If your organization is navigating the complexities of grant management, we can help you enhance oversight, streamline processes, ensure outcomes and reduce the risks of waste, fraud, and abuse. Reach out today to learn how our expertise in grants management can ensure your programs meet their goals, stay compliant, and make the best use of taxpayer dollars. 

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