Creation of American Rescue Plan Act Resolution

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THE BOARD OF COMMISSIONERS OF STARKE COUNTY, INDIANA (the “COMMISSIONERS”), after consultation with the Auditor of Starke County and the County Attorney and reference to written guidance from the Indiana State Board of Account (“ISBOA”) as set forth in State Examiner Directive 2021-1 dated March 18, 2021, has determined that an Ordinance establishing separate fund for assistance to be provided to the county through the American Rescue Plan Act of 2021 (“ARP”) is necessary and desirable ; and,

WHEREAS the Board of Commissioners of Starke County (the “Commissioners”) has determined that acceptance of ARP funds is in the best interests of the citizens of Starke County, Indiana; and,

WHEREAS the Commissioners, as the chief executive body of Starke County, possess authority to adopt an Ordinance establishing an ARP Fund and to authorize an ARP Fund Implementation Plan in compliance with State Examiner Directive 2021-1; and,

NOW, THEREFORE, BE IT RESOLVED AND ORDAINED by the Board of Commissioners of Starke County as follows:

  1. Establishment of ARP Fund. The ARP Coronavirus Local Recovery Grant Fund is hereby established and assigned Fund Number
  2. Administration of the ARP Fund. The Auditor of Starke County is authorized and directed to oversee the ARP Fund in all respects as is customary and appropriate, including acting as the custodian and auditing agent of the fund.
  3. Receipts into the ARP Fund. The ARP Fund shall be a separate and distinct fund from all other Starke County funds. Therefore receipts to be accepted into the fund shall be restricted solely to ARP funds received by Starke County, Indiana pursuant to Section 9901 of the ARP Coronavirus Fiscal Recovery Fund.
  4. Expenditures from the ARP Fund. In compliance with State ExalT1iner

Directive 2021-1 all expenditures from the ARP Fund shall be by appropriation of the Starke County Council, subject to approval of the Commissioners and consistent with the terms set forth in Section 9901 of the ARP Act (to be codified as Section 603(c) of the Social Security Act).

All expenditures shall comply with the Starke County ARP Funds Implementation Plan as authorized below. Expenditures must be for direct application for an appropriate and compliant use and may not be transfers to any other entity or unit. Expenditures the ARP Fund are limited to the following purposes:

    1. To respond to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19) or its negative economic impacts, including assistance to households, small businesses, and nonprofits, or aid to impacted industries such as tourism, travel, and hospitality;
    2. To respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of the county, city, town, or non-entitlement unit of local government that are performing such essential work, or by providing grants to eligible employers that have eligible workers who perform essential work;
    3. For the provision of government services to the extent of the reduction in revenue of such county, city, town, or non-entitlement unit of local government due to the COVID-19 public health emergency relative to revenues collected in the most recent full fiscal year of the State, territory, or Tribal government prior to the emergency; or
    4. To make necessary investments in water, sewer, or broadband infrastructure.

ARP Fund Implementation Plan. The Commissioners, in concert with the

Auditor and relevant elected officials and department heads, will direct preparation of an ARP Fund Implementation Plan to detail specific uses of the ARP Fund and ensure full transparency, internal controls over all transaction, separation of funds, documentation of audit trails, appropriate approvals and other aspects of good internal controls.

  1. Non-Reverting Fund. Money remaining in the Fund at the end of the calendar year shall not revert to another fund but shall remain in the ARP Fund as a separate nonreverting fund.
  2. Intent and Amendment. This Ordinance is intended to implement the guidance set forth in ISBOA State Directive 2021-1 and is subject to amendment from time to time to comply with any additional directive or guidance, statutory amendment, updated rules or by an order of any court of competent jurisdiction.
  3. Effective Upon Passage. This Ordinance is effective immediately upon passage. Adopted by the COMMISSIONERS, and approved on this day of April 2021, by the following vote:




Telephone: (317) 232-2513

Fax: (317) 232-4711

Web Site:


Date: March 18, 2021

Subject: Accounting for American Rescue Plan Act (ARP), Accounting Processes for Subtitle M-Coronavirus State and Local Fiscal Recovery Funds

Authority: 5-11

Application: This Directive applies Counties, Cities, and Towns

From: Paul D. Joyce, CPA, State Examiner

The purpose of this directive is to prescribe the accounting procedures for federal assistance received through the American Rescue Plan Act of 2021 (ARP).

Separate Fund Required. Assistance provided through the ARP must be received into a separate fund. There are many funding provisions in this Act. A separate fund must be established for each separately identified assistance provided with ARP in the naming title.

The fund name and number for each ARP grant fund must be assigned as follows:

Counties: ARP [Name of Grant]; Fund Number Range 8950-8975

Cities and Towns: ARP [Name of Grant]; Fund Number Range 176-199

ARP Coronavirus Local Fiscal Recovery Fund. Counties, Cities, and Towns will each receive an allocation of Coronavirus State and Local Fiscal Recovery Funds. Each local unit that receives an allocation from the Coronavirus Local Fiscal Recovery Fund under Section 603 of the Social Security Act, as added by Section 9901 of the ARP, shall establish by ordinance a separate local grant fund called the ARP Coronavirus Local Fiscal Recovery Fund within the fund number range described above. For a county, the ARP grant fund must be established by ordinance of the County Commissioners. For a city or town, the ARP grant fund must be established by ordinance of the legislative body. The ordinance must specify the uses of the fund in accordance with the purposes outlined in Section 603(c). The ordinance should reference a plan that will provide the details for the use of these funds. All moneys received from the Local Fiscal Recovery Fund must be receipted into the separate ARP grant fund.

Before money in the fund is disbursed, the fiscal body must appropriate the money in the fund for a use consistent with Section 603(c) as stated in the adopted ordinance and the plan. Only a local appropriation is needed. To ensure accountability and transparency of the use of these funds, all disbursements must be made from the ARP grant fund; money from the ARP fund may not be transferred to another fund of the county, city, or town.


March 18, 2021

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A detailed accounting of the fund is required by the ARP. All related expenditure records (accounts payable vouchers, minutes, correspondence, contracts, etc.) must be maintained in a separate file for future audits of ARP funds. It is important that you track every dollar disbursed and maintain supporting documentation for those disbursements. Each disbursement must be directly tied to a use listed in Section 603(c). The grant funding may be used to cover costs incurred by December 31, 2024. It is extremely important that these files be complete and accurate for this time period.

If your unit chooses to use the ARP funds to cover costs incurred for the provision of govemmental services as provided in Section 603(c)(1)(C), you must detailed calculations of the reduction in revenue due to COVID-19. For purposes of this calculation, the most recent full fiscal year prior to the emergency is 2019.

Note that the use of the funds for the provision of governmental services is limited to the extent of the reduction in revenue due to the COVID-19 public health emergency.

Other ARP Assistance or Grants. Other assistance or grants may be coming through the ARP. As stated above, each form of assistance or grant must be separately identified and accounted in a separate fund with a fund name and number as described. The Indiana State Board of Accounts will prescribe accounting procedures for these funds as more information becomes available.

Internal Controls. Sufficient internal controls over all transactions must be in place. Separate funds, maintaining records, detailed comments that provide audit trails, appropriate approvals, etc., are all part of good internal controls.

These prescribed accounting procedures will promote transparency and accountability of funds received through the Coronavirus Local Fiscal Recovery Fund. This Directive may be amended from time to time and may be rescinded at any time in writing by the suite Examiner or Deputy State Examiner.

Paul D. Joyce, CPA State Examiner