City of Pomona
American Rescue Plan (ARP) Update
May 16, 2022
Attachment NO. 7
ARP Update
• Update on the ARP Expenditure Spending Plan
• Update on ARP Appropriations for FY 2021-22 and FY 2022-23 • Request for Appropriation for FY 2021-22 of $15k for District 2 Allocation • Review and approve the Proposed ARP Agreements
• ARP Grant Agreement Between the City of Pomona and Businesses and Non-Profits • ARP Grant Agreement Between the City of Pomona and Individuals • ARP Subrecipient Agreement
• Award a three-year Contract to Hinderliter de Llamas Associates (HdL) ECONSolutions for Business Assistance Grant Program - Includes Appropriating $91k • June 6th City Council Meeting Staff Report
• US Treasury “highly recommends” a transparent process be setup • Staff will bring forward A “Process, Policies and Procedures” document to the Mayor and City Council for approval ARP Update
ARP Update
•Appropriate items that could be spent by June 30th (FY 2021-22) To date $17.2M has been appropriated
Mainly to CIP Projects
$15k Requested for District 2 City Council Allocation •Appropriate $13.9M for items that will be spent on or after July 1st (FY 2022-23)
•Incorporated into the FY 2022-23 Proposed Budget
Including Remaining CIP Appropriations
Balance of Each Councilmembers allocated amounts
ARP Update
• Appropriations to come forward in FY 2022-23 when programs are formalized include:
• $5M Universal Household Grant
• $1.9M Small Business Grants
• $1M Economic Support related to the Pandemic
• $1.6M Health and Wellness Activities
• $1M Technology Update, Leadership Development, and Operational Efficiencies
• $2M Participatory Budget (Only Eligible for ARP related uses) ARP Update
• Need to create Processes, Policies and Procedures to allocate funds to recipients for many of the items including those identified in the Mayor and City Council Allocations
o US Treasury “Highly Recommends” that a transparent process be set up o The process could be similar to CDBG Grant Process as it relates to the application process
o Need to establish standard Agreements for:
Businesses/Non-Profits
Individuals
Subrecipients
ARP Update
Summary
• BBK has worked with City staff as it relates to a process of providing ARP funding to Subrecipients and Beneficiaries. Specifically, in; • Developing policies and procedures to allocate ARP funds per the US Treasury Guidelines (These will be forthcoming at the June 6, 2022 City Council Meeting)
• Developed agreements, forms, and the necessary back up required by the City (Attachments No. 2, 3, and 4)
• Developed agreements for Subrecipients/Businesses/Non-Profits and Individuals and a Beneficiary Checklist (Exhibit A to Attachment 2 & 3) • Staff is working on a universal application for the Mayor and Councilmembers to utilize
ARP Update
•Federal law defines a Subrecipient to include any entity that receives a subaward from the City to carry out a program or service that is authorized under ARPA. In some cases, it can be difficult to differentiate between a Subrecipient and a Beneficiary.
•Generally, the Beneficiary is the end user of whatever program or service is created with the ARPA funds. •A Subrecipient uses the funds to implement the program or service. •The Federal Government has adopted Uniform Guidance on how recipients of federal funding can distribute those funds. The Uniform Guidance applies to funds the City distributes under ARPA, and imposes requirements on Subrecipients that do not apply to Beneficiaries. •These include certain contracting requirements and record keeping, reporting and audit requirements. •In order to ensure that its Subrecipients are eligible to receive funds under ARPA, and that they are complying with applicable federal law, the City must adopt written policies to that assess and monitor Subrecipient compliance, and impose certain requirements in its agreements with Subrecipients.
ARP Update
Subrecipient Requirements:
Subrecipients are required to follow Uniform Guidance,
including but not limited to the financial management, cost principles, property standards, procurement standards, and record retention. In addition, they are subject to
subrecipient monitoring.
ARP Update
“Beneficiary” Recipients of American Rescue Plan Act funds Treasury has defined Beneficiaries as the end user of the funds, and generally requires that only the following categories can qualify:
• Individuals and households
• 501(c)(3) and 501(c)(19) non-profit organizations
• Small businesses
• Impacted industries as defined by Treasury
In addition to these categories, ARPA imposes restrictions on how funds can be spent. In order to ensure that the recipients of the City’s ARPA funds are qualified Beneficiaries, and that the funds they are receiving fall into an authorized ARPA funding category, the City must collect the following information before releasing funds:
ARP Update
Business Assistance Grant Program – Hinderliter de Llamas Associates (HdL) • HdL is well positioned to assist the City of Pomona with developing and administering a Business Assistance Program to provide assistance to local businesses using ARP funds. • During the past 1 ½ years, HdL has worked with several cities to deal with the COVID-19 Pandemic and the negative economic impact it has delivered to cities and especially their business communities. • HdL’sscope of work is as follows:
• Develop and assist the City in administering a Business Needs Survey to understand the impacts on local businesses from the COVID-19 pandemic. • Utilizing the results of the Business Needs Survey assist the City in designing a Business Assistance Program for Pomona. • HdL recently designed and implemented a successful turnkey Commercial Rent Relief Program for the City of San Leandro and is working towards doing similar programs in Hawthorne, Hercules, Lafayette, Goleta and San Fernando. HdL will use this model to formulate and administer a Business Assistance Program on behalf of the city.
• Understanding that the implementation of the ARPA program is a very dynamic process, HdL can provide additional ARPA related services on an as needed basis based upon the hourly rates below and scope of work as agreed upon by the City and HdL. • Approval of this item will award a three-year agreement to HdL ECONSolutions to develop and administer a specific business assistance program but also be available to provide additional ARPA related assistance as needed in an aggregate amount not to exceed $91,000 for three (3) years, with one (1) one-year renewal option.
• City staff has reached out to both the Pomona Chamber of Commerce and the Pomona Hispanic Chamber of Commerce regarding their interest to assist HDL with developing and both are interested in assisting with a Business Needs survey.
ARP Update
QUESTIONS