March 27, 2025
Treasury, FEMA & Other Agencies Implement President Trump’s Executive Orders
Treasury Notifies ARPA Recipients of “Compliance Reviews and Recoupment Efforts”
Nearly every city in Georgia received COVID-19 relief funds through the American Rescue Plan Act (ARPA) and is required to report on the use of these funds periodically through April 2027. On Tuesday, March 25, the U.S. Department of Treasury notified every ARPA recipient of their plans to conduct compliance checks and recoup funds obligated or expended impermissibly. This notice likely comes as recipients gear up to submit their first report since the December 31, 2024, obligation deadline. The April 2025 report opens next Tuesday, April 1 and will be due on April 30.
The information cities input in the April 2025 report will be used by Treasury to determine obligation status; if it is found that not all funds were obligated by December 31, 2024, those funds are subject to recoupment. The importance of the April 2025 report cannot be overstated.
What Should My City Do? Review the March 25 notice and ensure that you understand the consequences of non-compliance. Check that you have no issues accessing the portal and gather any documentation on your city’s ARPA obligations and expenditures so you are ready to go on April 1. Find more information in the What Cities Need to Know About ARPA This Spring presentation from last week’s Talk It Up Thursday webinar.
FEMA Resiliency Investments at Risk
Last week, President Trump issued an Executive Order to decentralize disaster preparedness responsibilities and bolster state and local investments in resilience to natural disasters and emergencies. This week, Secretary Noem of the US Department of Homeland Security called for shrinking and possibly eliminating the Federal Emergency Management Agency (FEMA). According to POLITICO, agency cuts would affect preparedness and rebuilding efforts to keep the agency’s mission focused narrowly on immediate, life-saving operations.
While states develop emergency plans and operations according to their unique needs, FEMA has long provided – in addition to immediate aid – resources for flood mitigation, hazard mitigation, infrastructure resilience and more recently, cybersecurity. In Georgia, FEMA funds come through the Georgia Emergency Management Agency. Beyond pass-through funds, FEMA administers the Assistance to Firefighters Grants, which provided over $11 million in direct funding to local fire departments across Georgia last year.
Through May 15, 2025, FEMA is accepting public input on experiences with FEMA responses to disasters. This Request for Public Input allows stakeholders to suggest potential programmatic and organizational improvements to FEMA based on their experiences working with the agency.
Agencies Respond to Executive Orders
Federal agencies are implementing President Trump’s sweeping executive orders around deregulation and uprooting priorities seen as in conflict with current Administration priorities. Last week’s update described an internal USDOT memo and a FEMA email notice mandating reviews of grant awards before funds could be disbursed. Here are further agency responses to those orders that may impact cities:
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USDA Stakeholder Announcement: Diversity, Equity and Inclusion criteria removed from scoring process for numerous Rural Development programs.
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Updated EPA General Terms and Conditions: Possible termination of grant award if it “no longer effectuates the program goals or agency priorities,” among other T&C changes.
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FCC “Delete, Delete, Delete” Proceeding: Effectively opens all Commission rules for review, elimination, or modification, and as telecommunications providers expand broadband networks, may lead to preemption of local authority on issues such as infrastructure siting and franchising.