Legal Alerts Apr 16, 2021

U.S. Treasury Releases New Guidance on the Coronavirus State and Local Fiscal Recovery Fund

Agencies Should Be Aware of Pre-Award Requirements

Yesterday, the U.S. Treasury released new guidance on the certification process for entities that will be receiving a direct payment from the U.S. Treasury under the Coronavirus State and Local Fiscal Fund authorized by the American Rescue Plan Act.
Municipalities with a population of at least 50,000 will be receiving a direct payment from the U.S. Treasury utilizing a modified Community Development Block Grant formula. Prior to the launch of the program, eligible entities should start preparing pertinent information that will be needed to receive the funding in a more timely matter.
Per the policy guidance, state and local governments should take the following steps immediately:

  1. Have a valid DUNS number. A DUNS number is a unique nine-character number used to identify an organization and is issued by Dun & Bradstreet. The federal government uses the DUNS number to track how federal money is allocated. A DUNS number is required prior to registering with the System for Award Management (SAM) database (see below). There is no cost to register for a DUNS number. Visit Dun & Bradstreet’s website or call (866) 705-5711 to register.
  2. Have an active SAM registration. SAM is the official government-wide database with which an agency must register to conduct business with the U.S. government. All federal financial assistance recipients must register on and renew their SAM registration annually to maintain an active status to be eligible for federal financial assistance. There is no charge to register or maintain your entity SAM registration. To register or renew, please visit, to begin the entity registration or renewal process. Please note that SAM registration can take up to three weeks; delay in registering in SAM could impact timely payment of funds. Learn more about SAM registration by clicking here.
  3. Gather payment information, including:
  • Entity Identification Number, or EIN, name and contact information
  • Name and title of an authorized representative of the entity
  • Financial institution information (e.g., routing and account number, financial institution name and contact information)

Non-entitlement units of local government that will receive funds through the state government will also need a DUNS number for reporting requirements under the program. It is also recommended that non-entitlement cities have SAM registration completed prior to the distribution of funds.

Disclaimer: BB&K Legal Alerts are not intended as legal advice. Additional facts, facts specific to your situation or future developments may affect subjects contained herein. Seek the advice of an attorney before acting or relying upon any information herein.

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COVID-19 Legal Updates

All BB&K communications on the rapidly changing laws and requirements related to COVID-19 for businesses and public agencies can be found here.

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