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ARPA-SLFRF: Re-Obligate Now or Risk Leaving Money on the Table
October 20, 2025
We’re almost 10 months past the ARPA-SLFRF obligation deadline (12/31/2024). For many recipients, the memorandum of agreement (MOA) route was the administrative “easy button” to meet that date. But the clock didn’t stop—pressure is now on to get those dollars under contract/subaward and expended.
At the same time, some projects that looked solid in 2024 are slipping, downsizing, or finishing under budget. This requires a sense of urgency to re-obligate quickly to projects that can be executed without compromising compliance.
With all funds having to be liquidated by 12/31/2026, treat the next calendar year as a wrap-up and closeout year, not a period for deciding what to fund.
What to do in the next 60–90 days
1) Run a portfolio triage (green/yellow/red)
2) Convert MOAs into executable instruments
3) Re-obligate underspend fast—and cleanly
4) Lock cash flow and cadence
5) Protect compliance while you move fast
ARPA-SLFRF is in its final act. To ensure that your jurisdiction does not leave any funding on the table, move quickly to re-obligate lagging dollars, convert MOAs into executable agreements, and spend cleanly with documentation ready for monitors and auditors. Treat the coming year as execute and close, not debate and design—and you’ll preserve funding, deliver impact, and finish strong.
1) Run a portfolio triage (green/yellow/red)
- Green: On-track, under contract/subaward, burn rate supports finish by 9/30/2026 or sooner.
- Yellow: Scope/permit delays, staffing gaps, procurement pending—needs intervention.
- Red: Not viable, or material underspend likely—source of re-obligation dollars.
2) Convert MOAs into executable instruments
- For each MOA, confirm the binding vehicle: contract, subaward, IGA/ILA.
- Ensure allowability, deliverables, period of performance, and payment terms are explicit.
3) Re-obligate underspend fast—and cleanly
- Prioritize “shovel-ready” projects with clear procurement paths and environmental/permits in hand.
- Use standard packages (scope, budget, procurement method/justification, performance measures).
- Document the decision memo (why the move, risk review, public benefit).
4) Lock cash flow and cadence
- Set a contract/subaward drawdown calendar (bi-weekly or monthly) tied to a draw evidence index (contract/PO, invoice, performance proof, GL↔SEFA crosswalk).
- Require monthly status for yellow/red projects until they’re green or reprogrammed.
5) Protect compliance while you move fast
- Procurement discipline: method selection, price/cost analysis, conflicts, and file completeness.
- Subrecipient monitoring: risk-based, document monitoring efforts, SAM/UEI checks.
- Records & retention: organize now so closeout is a click-through, not a scramble.
ARPA-SLFRF is in its final act. To ensure that your jurisdiction does not leave any funding on the table, move quickly to re-obligate lagging dollars, convert MOAs into executable agreements, and spend cleanly with documentation ready for monitors and auditors. Treat the coming year as execute and close, not debate and design—and you’ll preserve funding, deliver impact, and finish strong.
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.
Authored by:
Matthew Hanson, CGMS, GPC
Managing Director, Government Advisory Services
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