The end of the CSLFRF program is now in sight, and for many recipients, closeout is no longer theoretical — it’s an active compliance, reporting, and risk-management exercise.
The program, authorized under the American Rescue Plan Act, delivered $350 billion to state, territorial, local, and tribal governments to support pandemic response, economic recovery, public services, infrastructure, and other eligible uses. But as recipients approach the final phase of the award, the central question is changing. It’s no longer simply, “Can we spend the funds?” It’s now, “Can we prove every dollar was eligible, obligated on time, spent properly, reported accurately, and documented well enough to withstand review years from now?”
Definitions matter
Before your organization can assess closeout readiness, it’s important to clear up a few common misconceptions:
- Obligation doesn’t equal payment. Funds generally had to be obligated by Dec. 31, 2024, but that doesn’t mean all costs were already paid by that date.
- Spending doesn’t equal reporting. Even if funds are fully spent, recipients must continue submitting required Treasury reports until closeout is completed or Treasury confirms otherwise.
- Closeout doesn’t mean “we’re done.” Closeout is the formal process of ending the federal award, but audit, monitoring, record retention, and documentation responsibilities can continue after funds are expended.
What you need to know about the CSLFRF closeout process
Spending the last dollar doesn’t automatically close a CSLFRF award. Treasury has been inviting eligible recipients to close out on a rolling basis, and recipients can’t simply declare themselves closed out without completing Treasury’s process.
Treasury expects recipients to have complete and accurate project and expenditure reports, current portal contacts and user roles, active SAM.gov registration where applicable, and documentation that supports reported obligations and expenditures.
When preparing your documentation, ensure consistency across Treasury projects and expenditure reports, the general ledger, financial statements, schedule of expenditures of federal awards, and single audit submissions. Inconsistencies across those records may create unnecessary questions during closeout or audit.
Reporting continues until closeout is complete. Until Treasury requests and confirms closeout, you should assume that reporting and compliance obligations continue through April 30, 2027.
Know the nonnegotiable deadlines for CSLFRF closeout
The key CSLFRF deadlines should drive your closeout strategy:
- Dec. 31, 2024 — Deadline to obligate CSLFRF funds.
- Sept. 30, 2026 — Deadline to expend funds for surface transportation and Title I projects.
- Dec. 31, 2026 — General expenditure deadline for other eligible CSLFRF costs.
- Post-Dec. 31, 2026 — Administrative closeout costs, if previously obligated.
- April 30, 2027 — The final CSLFRF reporting deadline. Liquidation may extend into 2027 if allowable and properly documented. Recipients should confirm against the latest Treasury reporting guidance before publication.
Any CSLFRF funds not expended by the applicable deadline are currently required to be returned to Treasury.
Subrecipients may be the greatest closeout risk
For recipients that passed funds to subrecipients, closeout risk may sit outside your finance office. Subrecipient delays can quickly become recipient repayment risk.
Questions you should be asking now:
- Have you distinguished properly between subrecipients and contractors?
- Can each subrecipient realistically spend-down by the applicable deadline?
- Have final invoice deadlines been communicated clearly?
- Is there enough time to review invoices, correct errors, and request missing documentation?
- Are subrecipient agreements, monitoring files, risk assessments, and final reports complete?
As the recipient, you’ll remain responsible for the federal award, even when funds are carried out through subawards. Documentation related to subrecipient agreements, monitoring, certifications, and expenditure support should be organized before closeout pressure peaks.
Build a realistic spend-down plan for CSLFRF awards
Closeout readiness requires more than knowing the expenditure deadline. You should have a working spend-down plan that includes:
- A project-by-project liquidation timeline.
- Assigned roles and responsibilities.
- Internal deadlines for invoices, approvals, corrections, and reporting.
- Decision points if projects stall.
- A contingency plan for unspent or excess funds.
This is especially important because Treasury has emphasized continued monitoring and potential recoupment for noncompliance. If you wait until late 2026 to identify stalled projects, you may have limited options to reclassify, redirect, and properly document remaining funds.
If you have excess funds, act intentionally
If you discover that obligated funds won’t be fully expended as originally planned your response should be deliberate, documented, and anchored in Treasury guidance. Identify excess funds now, evaluate what uses remain allowable, and determine what’s operationally achievable before the applicable expenditure deadline. Treasury has provided guidance on reclassification in certain circumstances, but you must still ensure that any revised use is eligible and tied to an obligation incurred by the obligation deadline. The key isn’t simply to “find somewhere to put the money.” The key is to document why the revised use is allowable, how it aligns with Treasury rules, and how you reached that decision.
Documentation will decide the outcome
Closeout success is proven — not assumed. The strongest closeout files will connect each dollar to allowability, obligation, expenditure, reporting, and support. At a minimum, you should be prepared to support:
- Evidence of obligation by Dec. 31, 2024.
- Revenue loss methodology and calculations, if applicable.
- Standard allowance records, while remembering that expenditures still need to support an eligible government service or use.
- Procurement files, contract documents, and change orders.
- Subrecipient versus contractor determinations.
- Subrecipient monitoring records.
- Policies and procedures in effect at the time decisions were made.
- Payroll, invoices, purchase orders, approvals, and payment records.
- Reconciliations between the general ledger and Treasury reports.
It’s not too late to strengthen the file. If decisions were made contemporaneously but not fully documented, you should document the rationale now, clearly identifying the basis for the decision and the records that support it.
Prepare for CSLFRF award audit and monitoring
Closeout isn’t the end of scrutiny. Recipients should expect that CSLFRF awards may be subject to single audit testing, Treasury review, pass-through monitoring, or future information requests. Treasury has also stated that it’s committed to recouping funds used in violation of CSLFRF rules and guidance.
Record retention requirements should be built into your closeout plan. There’s a five-year retention period tied to final expenditure reporting, funds being expended or returned, or closeout requirements; be sure to confirm the applicable retention trigger under Treasury guidance and your award terms.
The practical test is simple: If someone new joined your organization two years from now, could they find and explain the CSLFRF file?
For further information, check the Treasury SLFRF Closeout Resource Hub.
Are you ready — and do you have the right CSLFRF closeout support?
For many organizations, the challenge isn’t effort, it’s capacity. Finance teams, grant managers, project leads, and subrecipients are managing closeout alongside ongoing operations and competing federal grant demands. As closeout approaches, take a clear-eyed view of your readiness: Are your internal teams stretched? Are subrecipients prepared? Are reporting and financial records fully reconciled, and are documentation gaps understood and addressed? Do you have contingency plans if spending slows? Just as importantly, consider whether outside compliance, financial, or project management support could help mitigate last-minute risk.
The last dollar isn’t the finish line
CSLFRF closeout isn’t simply the final administrative step — it’s the moment when program design, financial management, reporting discipline, and documentation converge. Success isn’t measured by whether the last dollar is spent, but by whether every dollar can be clearly justified, consistently reported, and confidently defended years after the program ends.
