Can American Rescue Plan Act of 2021 (ARPA) State and Local Fiscal Recovery Funds (SLFRF) "premium pay" be used to compensate county officials?
No. The United States Treasury issued its Final Rule on Jan. 6, 2022, which explicitly states: "SLFRF funds must be free of undisclosed personal or organizational conflicts of interest, both in fact and in appearance. Consistent with this policy, elected officials are prohibited from using their official position and control over SLFRF funds for their own private gain." The Final Rule became effective April 1, 2022.