Are ARPA funds subject to single audit?
Yes — State and Local Fiscal Recovery Funds are a federal award, and money you received through a state, county or city still counts as federal awards expended. Treasury also describes an alternative compliance examination engagement that some recipients may use instead of a full single audit (Treasury SLFRF Compliance Supplement).
Last verified: 2026-09-20 · Every figure links its source.
Are ARPA funds subject to single audit?
Treasury's own compliance material explains that many SLFRF recipients became subject to a single audit or a program-specific audit for the first time because the award pushed them over the threshold (Treasury). That only makes sense if the funds count, and they do: they are a federal award, and the test in 2 CFR 200.501(a) is federal awards expended in the fiscal year.
Source: Treasury, State and Local Fiscal Recovery Funds · Treasury, 2024 SLFRF Compliance Supplement · 2 CFR 200.501 · Last verified: 2026-09-20
Does money received through a city or county still count?
Yes. A subrecipient's award is still a federal award; the pass-through entity must identify it as a subaward and pass down the federal award identification and requirements (2 CFR 200.332). On the schedule you report it under the federal program, and you also name the pass-through entity and the identifying number it assigned (2 CFR 200.510(b)).
The common failure is not the audit, it is the paperwork: nonprofits receiving city money sometimes do not know it is federal until the auditor asks. If a contract mentions ARPA, SLFRF or an Assistance Listing number, treat it as federal money and ask the city for the subaward identification in writing.
Source: 2 CFR 200.332 · 2 CFR 200.510 · Last verified: 2026-09-20
What is the alternative compliance examination engagement?
Treasury describes an alternative approach, permitted by OMB, for SLFRF recipients that would not otherwise have needed an audit under subpart F if it were not for their SLFRF expenditures. Treasury publishes a report user guide for it (Alternative Compliance Examination Engagement report user guide). Eligibility and the reporting format are set by Treasury, not by the auditee, so read the current Treasury guidance for your fiscal year before assuming you can use it.
Source: Treasury, Alternative Compliance Examination Engagement report user guide · Treasury, 2024 SLFRF Compliance Supplement · Last verified: 2026-09-20
How do ARPA funds appear on the SEFA?
| Item | Where it goes |
|---|---|
| Federal agency and Assistance Listing number | Program identification on the schedule |
| Pass-through entity name and its identifying number | Required for any award received as a subrecipient |
| Amount expended in the period | Total federal awards expended for the program |
| Amounts passed to your own subrecipients | Total provided to subrecipients from the program |
| Accounting policy note | Significant accounting policies and the de minimis rate election |
Source: 2 CFR 200.510 · 2 CFR 200.502 · Last verified: 2026-09-20
Questions and answers
Are ARPA funds subject to single audit?
Yes. State and Local Fiscal Recovery Funds are a federal award and count toward federal awards expended, including money received through a state, county or city as a subrecipient.
Is SLFRF money received from a city a federal award?
Yes. A subaward keeps its federal character, and the pass-through entity must identify it and pass down the requirements under 2 CFR 200.332.
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This is public-record information, not accounting or legal advice.