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PROPOSED RESOLUTION
ARPA OPEN COMMUNITIES TRANSFER
WHEREAS, on March 11, 2021, the federal government authorized the American Rescue Plan Act of 2021 (“ARPA”) which includes $1.9 trillion in federal stimulus funds to hasten the United States’ recovery from the economic and health effects caused by the COVID-19 pandemic; and
WHEREAS, specifically, the federal government authorized and allocated a federal award of approximately $1,000,372,385.00 of ARPA State and Local Fiscal Recovery Funds (“SLFRF”) to Cook County to assist the County in its recovery from the economic and health effects of COVID-19; and
WHEREAS, on June 24, 2021, the Cook County Board of Commissioners via Resolution 21-3654 accepted the ARPA federal award allocated to Cook County to assist the County in its recovery from the economic and health effects of COVID-19; and
WHEREAS, on June 24, 2021, the Cook County Board of Commissioners also approved Resolution 21-3657 which authorized the Cook County Budget Director and Comptroller to create and implement a special fund for the ARPA SLFRF award and other accounting measures to track the acceptance and spending of the federal award; and
WHEREAS, on January 13, 2022, the Cook County American Rescue Plan Act Framework (the “ARPA Framework”) was presented to and approved by the Cook County Board of Commissioners via Resolution 22-0637 and such framework provided a comprehensive plan for the County’s expenditure of ARPA SLFRF which included creating new as well as leveraging and expanding existing Cook County policy pillar community programs and initiatives to assist workers and families, small businesses, and impacted industries, as well as other programs to address health disparities, housing and community needs; and
WHEREAS, the Cook County community policy pillar programs include ARPA SLFRF allocations to the following categories: Vital Communities, Open Communities, Healthy Communities, Safe and Thriving Communities, Connected Communities and Sustainable Communities; and
WHEREAS, to effectuate the approach outlined in the ARPA Framework, the Chief Financial Officer and the Budget Director were authorized pursuant to various Resolutions (21-3657, 21-4938 and 22-0637) to expend ARPA funding for the purpose of creating new and also continuing and expanding existing Cook County community policy pillar programs and initiatives; and
WHEREAS, on October 23, 2025, the Cook County Board of Commissioners approved Resolution 25-3759 which authorized the use of $3,000,000.00 of Corporate Funds for Cook County community policy pillar program NT093A - Emergency Mortgage Assistance Modular Homes and such program has been historically spending above their target rate of funding; and
WHEREAS, due to the historical spending rate associated with program NT093A, and the projected shortfall in ARPA spending it is appropriate to request the expenses incurred in NT093A be transferred from the Corporate Fund to the ARPA SLFRF Funds; and
WHEREAS, since the issuance of the ARPA SLFRF award the U.S. Treasury issued guidance on obligation and spending in April, 2022 and the Treasury adopted the SLFRF Final Rule in Federal Register; in November, 2023 the Treasury issued Obligation Interim Final Rule in Federal Register; in March, 2024 the Treasury updated SLFRF Final Rule FAQs - sub-regulatory guidance; the deadline for Cook County to obligate the full ARPA SLFRF award is December 31, 2024 and the deadline for Cook County to spend the obligated ARPA SLFRF is December 31, 2026; and
WHEREAS, Cook County’s actions and strategies to-date are all in alignment with Treasury guidance; however, due to recent shifts in the federal landscape and in accordance with the authority granted in Resolution 21-3657 and in Sections 19, 20 and 21 of the FY 2025 Budget Resolution, Cook County is adjusting its strategy to reduce risk of funds being later called into question and potentially clawed back by the US Department of Treasury; and
WHEREAS, based on recent spending trends across all ARPA SLFRF Cook County Community Pillar Programs, the Bureau of Finance has projected that there may be a shortfall in spending of $83.2M; and
WHEREAS, to mitigate such risk, in close out of the 2025 Fiscal Year, the Budget Director and Office of the CFO recommends reallocating eligible expenses incurred in December of 2024 from the General and Health Funds in an amount up to $53M, and transfer such eligible expenses to the Revenue Replacement Eligible Use Category in the ARPA Fund, which is aggregated in the Open Communities Policy Pillar; and
WHEREAS, the Bureau of Finance will continue to monitor the progress of spending and adjust the appropriations within the policy pillars as projected risk materializes until the deadline for Cook County to spend the obligated ARPA SLFRF Funds, December 31, 2026, and;
WHEREAS, to further mitigate risks attributable to the ARPA Community Programs , the Bureau of Finance has worked with program leads to identify the subrecipients and programs that should have their obligations reduced, and ones that should have their obligations increased to minimize the risk that that not all ARPA SLFRF funds are spent before December 31,2026 and clawed back by the federal government; and
WHEREAS, because of these proposed reallocations the County will have allocated 71% of total ARPA SLFRF Funds to Cook County community policy pillar programs (a reduction from 76%).
NOW THEREFORE BE IT RESOLVED, in accordance with Section 27 of the FY 2025 Budget Resolution as well as Sections 21, 22, and 23 of the FY 2026 Budget Resolution, the Cook County Board of Commissioners authorizes, as part of the FY2025 year-end close, the Budget Director and Comptroller to recognize up to $53M of FY2025 expenditures incurred in the Operating Funds during month of December of 2024, as Revenue Loss; and
BE IT FURTHER RESOLVED, that to facilitate the transfer of funds from the General Fund to the ARPA Fund, the Bureau of Economic Development shall amend the legal agreements in NT093A - Emergency Mortgage Assistance Modular Homes to reflect the use of ARPA SLFRF Funding instead of Corporate Funds; and
BE IT FURTHER RESOLVED, the use of such ARPA SLFRF grant funds in the close out of 2025 Fiscal Year will be provided in the Budget Director’s ARPA reports and in accordance with Section 21 of the FY 2025 Budget Resolution through the Final Appropriation Trial Balance for 2025.
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