American Rescue Plan Act (ARPA)

The American Rescue Plan Act of 2021 was a $1.7 trillion package providing direct and indirect assistance to people, business, tribal and local governments. All funds must be allocated by the end of December 2024. Any uncommittted funds will revert to the federal government.

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UPDATE: new guidance in Final Rule, Frequently Asked Questions.

FAQ 1.8 expressly states that governments may devote their allocations of federal money to charitable nonprofits in two important ways: nonprofits as recipients of relief (beneficiaries) and nonprofits as providers of relief to others: 

Nonprofit as the Recipient of Relief: a government "recipient can provide funds to an entity, including a nonprofit organization, for the purpose of directly benefitting the entity as a result of the entity experiencing a public health impact or negative economic impact of the pandemic. In this instance, these entities will be considered beneficiaries, not subrecipients, and will not be expected to comply with subrecipient reporting requirements. Beneficiary reporting requirements will apply." (Emphasis added.)

Nonprofit as Provider of Relief to Others: "the final rule clarified that recipients may transfer funds to any entity to carry out, as a subrecipient, an eligible activity on behalf of the SLFRF recipient (transferor), as long as they comply with the SLFRF Award Terms and Conditions and other applicable requirements. A transferee receiving a transfer from a recipient under sections 602(c)(3) and 603(c)(3) will be considered a subrecipient and will be expected to comply with all subrecipient reporting requirements." (Emphasis added.)

The U.S. Treasury issued the Final Rule regarding the use of ARPA funds.

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The National Council of Nonprofits has provided an Analysis of Key Provisions Affecting Nonprofits and the People They Serve.