May 18, 2024
Bangor, Maine filed their Q3 2022 SLFRF (ARPA) Project & Expenditure report on time. But there are some sticking points that need a look. Let's dive in.

Note to readers: Many questions remain about the way Bangor is handling their financial award from the American Rescue Plan Act. In today’s e-mail to Bangor City Council, I ask specific questions about the 1 filing the Bangor DID do, which was Quarter 3 2022. Q1 and Q2 are still uncertified and unsubmitted. 214 days out of compliance with the Federal Government and counting.

Dear Councilors, 

In this e-mail I will be sharing my questions and concerns regarding the Q3 2022 the City Manager filed on October 31, 2022.

I have attached the Q3 2022 report to this e-mail.

1. Housekeeping issue – On the last page of the report the City Manager is certifying as the “Finance Director”. Contact information (there are 3 points of contact requested by the Treasury) will need to be updated. Those instructions are in the Treasury’s P&E user guide. 

2. Page 2, Project Overview: 

Under “Does your jurisdiction have projects to report as of this reporting period?” the City Manager has answered: “My jurisdiction has projects to report.” This is inaccurate. As all of you are keenly aware, we do not have projects to report. Unfortunately the City Manager already certified this report and the Treasury does not allow reports to be recalled and resubmitted once certified. Please instruct the City Manager to document her reasoning here and store that with the City’s records as that will be helpful for a future audit. 

3. Page 2, Project Overview (continued): 

Under “Provide a narrative describing the reason(s) your jurisdiction does not have approved projects at this time” the City Manager has answered “We are finalizing the process under which projects will be funded.”  That indicates that there is something written to finalize. I am requesting a copy of all documentation of this process under which projects will be funded that the City Manager has informed the Treasury that we are finalizing, so that I may understand it better as a citizen of Bangor. 

4. Page 3, Revenue Replacement:
Under “Is your jurisdiction electing to use the standard allowance of up to $10 million, not to exceed your total award allocation, for identifying revenue loss?” the City Manager has selected yes. But according to both the Interim Report (attached) and the Q4 2021 report submitted by the City, we were claiming a loss of $1,238,180. With Q1 and Q2 reports still not certified and not submitted, Q3 is the first indication a change in election had been made. I call attention to this because the Treasury specifically states, “Recipients were asked to make this election during the April 2022 reporting deadline.” Since we failed to get our Q1 reporting in, we technically have not made a selection to the Treasury. The City Manager has not replied to my last e-mail to her and indicated that she had in fact gotten our missing Q1 and Q2 2022 reports certified and submitted. Please advise the City Manager to use the same election for Q1 and Q2 as she did for Q3, per Treasury rules: “Recipients continue to be required to employ a consistent methodology across the period of performance (i.e., choose either the standard allowance or the regular formula), and may not elect one approach for certain reporting years and the other approach for different reporting years.” 
You can find the this information on Page 45 of the Treasury’s P&E Report User Guide:
Oct-2022-PE-Report-User-Guide.pdf (treasury.gov)

You can find our Q4 2021 data here, under “Public Reporting”:
Recipient Compliance and Reporting Responsibilities | U.S. Department of the Treasury

I would like to again reiterate how important it is for the City to hire an expert to help administer this program. These types of discrepancies would be avoided and we would be in complete (and accurate) compliance.  

Sincerely,
Michael Beck

Response from the City: “Good Morning Michael – Thank you for reaching out. I see as part of your email that you are requesting documentation from the City. As that is considered a FOAA request, please consider this email receipt of that request.

The CM is currently on vacation and may have clarifying questions upon her return, so it may be the week of the 12th before you hear back regarding your documentation request but if it’s possible to be quicker in responding, we certainly will.”