American Rescue Plan FAQs
Businesses who receive funding through the TUFF cost share program are considered subrecipients of American Rescue Plan funding. As subrecipients, grantees must comply with the requirements of the Uniform Guidance for Federal Awards (2 C.F.R. 200). These requirements include (but are not limited to):
1. Procurement Requirements
2. Asset Management and Disposition Requirements
3. Audit Requirements
4. Subrecipient Risk Assessment
Uniform Guidance may be found here: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200.
The Uniform Guidance procurement requirements at 2 CFR 200.317 – 327 apply to all purchases made under this program. These requirements set forth specific standards for full and open competition, with the goal of promoting competition and fairness in the procurement process. Awardees must fully comply with these requirements, including maintaining written procurement and conflict of interest policies in place, adhering to the most restrictive of federal, state, and local procurement requirements, and conducting all procurement transactions in a manner that provides for full and open competition, among other requirements.
Entities that do not comply with the federal procurement requirements may be subject to penalties, including disallowed costs and suspension or termination of their grants.
Micro-purchases under $10,000 do not require formal bids. Between $10,000 and $250,000 will require three quotes and documentation about why that vendor was selected. For purchases greater than $250,000, a formal procurement process is required, using either sealed bids or proposals. Please see § 2 CFR 200.320 for more information about methods of procurement.
§ 2 CFR 200.501 Audit requirements state that a non-federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year.
Recipients of TUFF cost share funding will be required to have a Unique Identifying Number (UEI) from SAM.gov. However, they are not required to go through the business registration process with SAM.gov. Step by step instructions for getting a UEI are located at this link: https://www.youtube.com/watch?v=0uv1YNAsINk.
100% of project costs must comply with program and federal guidance, including ARP and Uniform Guidance (2 CFR 200) requirements, except for guidance related to encumbrances on asset titles. It is allowable for assets purchased with the awardee’s cost share funds (not the TUFF funds) to be encumbered.