ARPA flowchart for new proposals 

ARPA funds can be used in many ways to address health and economic impacts and the Coronavirus State and Local Fiscal Recovery Funds: Overview of the Final Rule provides guidelines for creating an ARPA proposal that is not already pre-approved (p. 32).  Follow the steps below to ensure your proposal will be ARPA eligible. 

Step 1. Identify group(s) or entity(ies) impacted by your proposed need 

Step 1a: Preexisting group? 

Check to see if your group falls into any of the groups already identified by ARPA.  If your group fits in any of these categories, skip to step 1f. 

Step 1c: Individual or Class? 

Next, you will have to choose whether the group the proposal helps is an individual or class, because this affects how you document the impacts of covid:  

• Individual - If the group is impacted at the “individual” level, then beneficiaries will have to provide documentation of how they were impacted by covid, e.g., a person lost their job, a household requires food assistance, or a small business lost revenue.  Sometimes documentation can simply be a self-attestation. 

• Class – If the group is a class, i.e., a group of households, small businesses or non-profits, then you would have to document how that class was impacted, and the beneficiaries only need to provide documentation that they are a member of that class.  For example, you could provide data about how Evanston downtown businesses were impacted, and Andy’s Custard would then only have to provide documentation that they operated downtown.   

Step 1d: Define the class 

If you are defining a class, you may define the class based on: 

• a population  

• a geographic area 

• an income level, including at levels higher low- and moderate-income, e.g., the households with incomes above low-income might still have experienced disproportional impacts 

Step 1d: Impacted or disproportionally impacted? 

Decide whether: (a) the group is impacted/disproportionally impacted: 

• “Impacted” entities are those impacted by the disease itself or the harmful consequences of the economic disruptions resulting from or exacerbated by the COVID- 19 public health emergency. For example, an individual who lost their job or a small business that saw lower revenue during a period of closure would both have experienced impacts of the pandemic. 

• “Disproportionately impacted” entities are those that experienced disproportionate public health or economic outcomes from the pandemic; Treasury recognizes that pre- existing disparities, in many cases, amplified the impacts of the pandemic, causing more severe impacts in underserved communities. For example, a household living in a neighborhood with limited access to medical care and healthy foods may have faced health disparities before the pandemic, like a higher rate of chronic health conditions, that contributed to more severe health outcomes during the COVID-19 pandemic. 

To establish that a group is disproportionally impacted, you may: 

• Use academic research or government research publications (such as Evanston’s EPLAN and the citations provided in the supplementary information in the final rule), through analysis of their own data, or through analysis of other existing data sources.  

• May also consider qualitative research and sources to augment their analysis, or when quantitative data is not readily available. Such sources might include resident interviews or feedback from relevant state and local agencies, such as public health departments or social services departments.  

• Should consider the quality of the research, data, and applicability of analysis to their determination in all cases.  

Step 1f: Describe the group and need: 

• Describe the group:  

• Describe the need: 

• Is this group: impacted / disproportionately impacted? 

• Is this: an individual / a class? 

• For classes, what evidence is there of disproportionate impacts? 

Step 2: Design a response that addresses the impact 

Step 2a: Describe the response 

Describe the programs, services, or other intervention. 

Step 2b: Check that the response addresses the impact 

The response must be reasonably designed to benefit the individual or class that experienced the impact. 

When defining a class, make sure that the class is related to the proposal. Consider: 

• Defining smaller and more specific classes, e.g., Downtown businesses vs. Evanston businesses. 

• If the response is provided in a neighborhood, defining classes based on geographic area  

• If the response is to a particular group of people, define the class based on a population 

Note that the response can also be provided to other groups beyond the defined class, if also appropriate for those groups, however it should primarily benefit the impacted group. 

For disproportionately impacted communities, recipients may design interventions that address broader pre-existing disparities that contributed to more severe health and economic outcomes during the pandemic, such as disproportionate gaps in access to health care or pre-existing disparities in educational outcomes that have been exacerbated by the pandemic. 

Step 2c: Make sure the response is reasonably proportional to the impact  

“Reasonably proportional” refers to the scale of the response compared to the scale of the harm. For example, it may not be reasonably proportional for a cash assistance program to provide a very small amount of aid to a group that experienced severe harm and a much larger amount to a group that experienced relatively little harm. Recipients should consider relevant factors about the harm identified and the response to evaluate whether the response is reasonably proportional. For example, recipients may consider the size of the population impacted and the severity, type, and duration of the impact. Recipients may also consider the efficacy, cost, cost-effectiveness, and time to delivery of the response.