Civilytics’ Comments on the State and Local Fiscal Recovery Funds Interim Final Rule

Updated 7/15/21 to reflect the final comments Civilytics submitted to Treasury

We submitted the following comments about the U.S. Treasury’s Coronavirus State and Local Fiscal Recovery Funds administrative rule. Comments on administrative rules are an important part of the lawmaking process, giving the public the opportunity to be heard on important administrative details that agencies must resolve to carry out the language of an enacted law, in this case, the America Rescue Plan Act.

Our comments are focused on the five topics below. We invite you to crib from our language and submit your own comment, let us know what you would comment differently and why, or submit your own comment on another aspect of the ARPA Interim Final Rule! Comments are due by July 16.


Distributing the aid equitably among smaller local governments (NEUs)

Ensuring incarcerated individuals are treated fairly through this program

Applying the same restrictions on tax cuts to cities, counties, and NEUs as to states and territories

Maintaining the focus on lower-income essential workers and those who were primarily devoted to responding to the pandemic