As the American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Funds (SLFRF) program moves into closeout phase, it’s clear that closeout success is determined long before the final report is submitted.
NGMA and Hagerty Consulting partnered on a webinar presentation to help ensure a successful SLFRF closeout. Below are key takeaways from the presentation for recipients and subrecipients navigating the SLFRF closing stages. While this information focuses on SLFRF, the principles shared are broadly applicable for federal grant closeout.
- Spending the Money is Not the Finish Line
Awareness of the expenditure deadline (and the specific instances of variation from that deadline) is essential but is only the starting point of compliance, not the end. Treasury’s closeout process confirms that funds are spent and reported, but audits, data reviews and follow-up inquiries continue long after a closeout certification is submitted. SLFRF closeout triggers a five-year record retention period, during which Treasury, the Government Accountability Office (GAO), or the Treasury Inspector General may request records. Organizations that “finish strong” are those that can clearly track where every dollar went, reconcile reported data back to their general ledger, and explain why each cost was eligible. In short, reporting done does not mean compliance done.
- Audit Readiness Comes Down to Systems, Not Intentions
Let’s highlight a “48-hour test,” which is: If an auditor requested complete SLFRF documentation with two days’ notice after the person who organized it was no longer with the organization, could your organization deliver it? Many audit findings are not caused by bad actors or misuse of funds, but by fragmented documentation, informal practices or controls that existed on paper but not in daily operations. Audit-ready organizations have standardized documentation systems, clear ownership of compliance responsibilities and controls that operate in real time rather than at closeout. Additionally, if justification, approvals and reconciliations live only in email threads or people’s heads, the file is not audit‑ready, regardless of how confidently staff remember the decisions.
- The Real Outcome of Closeout is Institutional Capacity
SLFRF closeout is not just about SLFRF. The controls, governance, reconciliation practices, and documentation systems required to close this award cleanly are the same ones that auditors will expect on every future federal grant. Organizations that treat closeout as a one‑time cleanup exercise miss the opportunity to convert years of effort into durable grants management capacity and often repeat the same findings later under a new program.
Bottom line? Finishing strong requires planning ahead. Organizations that actively manage time risk, build documentation for external review, and treat closeout as capacity‑building, will exit SLFRF not just compliant, but stronger than when they entered.
Missed the webinar? This and all other recorded webinars are available in Grants Management Academy, NGMA’s education portal. (Member login required)
Nicole Ward and Benjamin Shay are senior managing associates with Hagerty Consulting, a firm that partners with clients to safeguard their people, operations and communities before, during, and after disasters.