July 14, 2021

Promoting Public Trust While Managing ARPA Funding

From small businesses support to health care initiatives, state and local government has the opportunity to provide relief to struggling communities in the wake of the pandemic with the American Rescue Plan Act. Here's how to steward those funds wisely.

The American Rescue Plan Act (ARPA) was signed on March 11 -- a $1.9 trillion bill with $350 billion allocated to cities, counties, and states to help them address the local issues created by the COVID-19 pandemic. Unlike the CARES act in 2020, it has a longer time span with more flexible spending criteria.

But this is more than just a second infusion of cash into crippled communities; the CARES Act also revealed cracks in an outdated system. With this new opportunity, how do local government officials gain the public’s trust in a process that was accused of shutting out minority-owned organizations and underserved communities?

Municipalities must take the time this year to undergo proper planning and consider investing in a comprehensive grant management system to ensure the integrity of their ARPA program. The Office of Management & Budget (OMB) released memorandum M-21-20, Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of Taxpayer Resources earlier this year to provide guidance to do just that.

The memorandum requires awarding agencies to:

  • Improve program and service design to achieve more equity-oriented results for Federal assistance

  • Manage payment integrity risks

  • Ensure robust and transparent reporting

Let’s take a deeper look.

Improving Program & Service Design to Achieve More Equity-Oriented Results for Federal Assistance

The design of your program and internal processes can hinder your applicants and overall grant management process.

Start by ensuring your program is more accessible. First look at the application itself - is it someone every constituent can access, complete, and understand? Complex applications and instructions can bewilder your applicants, and requiring hard copies or using application formats that require software or a desktop computer can limit those with transportation or resources.

It’s best to use plain language and stay within an 8th grade reading level. Avoid professional jargon and any buzzwords.

Make applications more ADA-friendly with keyboard accessibility and screen reader capability. 

Be sure your review process and the individuals who will be contemplating them are set up to be equitable, so you can defend the decisions your municipality makes. 

Reviewers should reflect the communities you serve. Identify potential conflicts and review the concept of implicit bias within your review team. Bias and conflict of interest must be removed to obtain equitable reviews.

Randomize reviewer assignments and remove demographic data to achieve equitable reviews and results. Using grant management software will allow for these tasks to be done easily and provide an easier experience for the review team. 

Management of Payment Integrity Risks

If payment integrity is compromised, your organization’s credibility will be, too. You want the correct person/entity to receive the correct amount of funding each time. Even if everything is correct, you still have bad characters and fraud to worry about.

Strengthening your grant management process will help you avoid these pitfalls.

Clearly state eligibility requirements, geographic focus, and any grant restrictions. Mention how much the grant is for and what’s expected of the applicant. If offering multiple grants, provide the different types and sizes.

The applicant should know if they are eligible or not and what the grant aims to provide.

We hear about companies & agencies dealing with data breaches all too much. Secure data collection is vital to promoting public trust. 

Avoid using multiple systems to store and collect grantee data. The perk to using grant management software is having this added layer of protection. Grantee information is encoded for maximum security reassuring their privacy is safe.

Ensuring Robust & Transparent Reporting

Reporting is a requirement for ARPA. Your reports should give internal teams a snapshot of the program but go in depth enough to help back up decisions and final impact. Frequent monitoring of your reporting lets you know if you’re on target or missing the mark.

To start, be sure to collect the data that matters. If it's not in your application, you won’t have it to use when you pull reports down the road.

To ensure you have not just what you want to monitor, but all the data you need to stay compliant, make sure you fully understand the rules and regulations of ARPA. Circle back to the OMB’s Compliance Supplement for important compliance information.

Beware of these common pitfalls and address them in your report shall they arise.

  • Misuse of grant funds
  • Failure to achieve objective
  • Violations of laws, regulations, or grant conditions
  • Misrepresentation of results
  • Weaknesses in the process and how to rectify them

Sharing your report is invaluable to not only stakeholders and donors, but the public as well. It’s the best way to convey transparency with the public and the communities you serve.

In addition to posting the reports and results on your municipal website, consider holding an open meeting to answer questions and fill in the gaps that paper reports just can’t do. 


Your ARPA funding will garner equitable results and promote public trust with these three requirements. With an extensive grant management system, it can be much simpler than you think to accomplish this and manage your funding.


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