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State agencies told to liquidate SFRF program costs by Dec. 31, 2026; administrative closeout allowed through April 30, 2027

NCPRO (state pandemic recovery office) · November 20, 2025
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Summary

NCPRO staff told agencies that programmatic SFRF costs must be liquidated by 12/31/2026; only administrative closeout costs may be paid between 01/01/2027 and 04/30/2027, and final reports to US Treasury are due 04/30/2027.

Joy (NCPRO) summarized federal and state guidance on State Fiscal Recovery Fund closeout and allowable costs. She said funds obligated or incurred as of 12/31/2024 must be liquidated by 12/31/2026; programmatic costs — including payments to contractors and subrecipients — cannot be paid after that date.

“Administrative closeout costs are allowed from January 1 to 04/30/2027,” Joy said, and she listed allowable administrative activities drawn from the SLRF FAQ, including payroll for administrative staff performing financial reconciliations, review and reconciliation of the general ledger, bank reconciliations, finalizing and submitting expense reports and subaward attachments, auditing and closeout processes, and documentation for proof of payment.

Joy emphasized that the 2022 final rule requires funds to be liquidated by 12/31/2026 and that recipients must ensure goods and services were provided, invoices received, and payments made by that date. She warned that large payments in the last quarter of 2026 and any payments dated after 12/31/2026 will be scrutinized by auditors.

Key dates Joy gave were: programmatic KPI and final programmatic data due by 01/15/2027; state agency final expense reports (administrative closeout costs only) due to NCPRO by 03/15/2027; agencies must return all unexpended balances to NCPRO by 02/28/2027; NCPRO will submit the final report to the US Treasury by 04/30/2027. Joy also noted that the state reporting system (referred to in the transcript as PANGRAM) will remain accessible for auditing purposes through 04/30/2027 and will move into a post‑closeout stage after that date.

Joy answered clarifying questions from participants, confirming that closeout administrative costs must be limited to reconciliation, reporting, and audit activities, and that subrecipients follow the same rules as direct recipients.

The memorandum‑style guidance Joy presented gives agencies a short window to assemble invoices, ensure services and goods were provided by 12/31/2026, and prepare documentation for both internal and federal review.