As ARPA Program Manager for the City of Gainesville, I built and managed the governance infrastructure that filtered 77 proposals through the city’s strategic plan, competitively selected partners, and deployed funds across 32 projects and 36 nonprofit subrecipients. The architecture has produced twenty-one consecutive clean quarterly Treasury reports and a closed Phase 1 Internal Audit.
The American Rescue Plan Act of 2021 was the largest direct federal transfer to local governments in over fifty years. At $350 billion nationally, it gave cities capital pools that often dwarfed their annual discretionary budgets. Gainesville’s $32.4 million allocation arrived in two tranches with hard federal deadlines (all funds obligated by December 31, 2024, all funds spent by December 31, 2026) and strict compliance requirements under the U.S. Treasury’s Final Rule.
The risks were well known. The National League of Cities documented three common failure modes for cities at this scale: treating ARPA as a windfall to fund wish lists, underinvesting in governance and compliance, and failing to build partnerships that could amplify one-time dollars into lasting capacity. Most cities had never managed a federal program this large. Audit findings, missed deadlines, and reallocation crises were predictable.
The City Manager named me ARPA Program Manager and asked me to build the governance architecture that would prevent every one of those failure modes — before the first allocation moved.
I authored the city’s ARPA Program Manual and maintained it through five versions, translating evolving U.S. Treasury Final Rule guidance into local operating policy: procurement standards, reporting requirements, reallocation protocols, subrecipient monitoring, and decision rights. Treasury issued fourteen versions of its compliance guidance between June 2021 and April 2025; the discipline was tracking each one and making sure the city’s operating policy moved in step.
I built a two-tier governance structure: an ARPA Action Committee of senior city leaders served as the recommending body, and the City Commission held final approval authority on every allocation. The Action Committee has met twenty-three times since August 2022, with minutes archived for the public record. No allocation moved without both layers.
Every nonprofit subrecipient was selected through competitive RFQ (including the fund administrator and the ARPA general consultant), eliminating any appearance of preferential awarding. Thirty-six nonprofits ultimately received subrecipient grants under monitored compliance terms.
When a housing development couldn’t secure financing, when community conditions demanded a faster response to homelessness, when a federally-required milestone slipped — the framework I built allowed the city to redirect funds within compliance bounds rather than hold capital hostage to failing deals. Reallocation became a feature of the system, not an exception to it.
The architecture is now four years into operation. Through the most recent reporting cycle, the program has produced twenty-one consecutive quarterly Project & Expenditure reports to the U.S. Treasury: on time, on format, with zero audit findings.
The city’s Internal Audit office completed Phase 1 of its ARPA review and closed it; no Phase 2 was deemed necessary. Thirty-six nonprofit subrecipients have been monitored without a compliance failure. Federal-funder credibility (the kind that determines whether a city is positioned for future federal awards) is now established record, not aspiration.
The program remains active through the December 31, 2026 SLFRF spend deadline, and the same governance architecture continues to operate against final closeout reporting. This case study will be updated when the program completes.
Federal compliance lives or dies on documentation. Three artifacts anchor the program’s audit trail: the operating manual that translated Treasury guidance into local policy, the Commission record that approved every dollar moved, and the quarterly reporting record that documents program execution against the spend deadline.
Principal-authored against the U.S. Treasury Final Rule, ongoing compliance and reporting guidance, and quarterly Treasury updates as issued. Defines procurement, reporting, reallocation, and subrecipient monitoring standards. Distributed with quarterly Commission status reports as the canonical operating reference for city program managers running SLFRF-funded projects across the portfolio.
Sample Version · Effective 2023-04-18Every penny of the $32.4M allocation approved by the City Commission. Twenty-three Action Committee meetings convened since August 2022, with minutes archived; the program runs through December 2026. Curated index of allocation, reallocation, and quarterly reporting agenda items below.
Jump to Index ↓Twenty-one consecutive quarterly Project & Expenditure reports filed with U.S. Treasury, every one publicly archived on the city’s Commission consent agenda. The most recent quarterly reports the program 95.0% spent against the December 2026 SLFRF deadline.
95.0% Spent · Apr 2026 SnapshotSelected agenda items spanning initial allocation, competitive subrecipient awards, the audit phase, quarterly reporting, and adaptive reallocation. Full archive available through the City’s public meeting portal.
Audit findings happen when compliance is treated as a downstream reporting task. I designed the governance architecture (manual, committee structure, decision rights, monitoring cadence) before the first allocation moved. Twenty-one consecutive clean quarterly reports and a closed Internal Audit are downstream evidence of upstream discipline.
Treasury issued fourteen versions of its Final Rule compliance guidance between 2021 and 2025. Each version had to be read, interpreted, and converted into local operating policy that staff and subrecipients could follow. The Program Manual went through five versions tracking that translation. This is the work most organizations underestimate; it’s where most audit findings originate.
Recommending body and approving authority were structurally separated: an Action Committee of senior leaders recommended; the City Commission approved. Twenty-three Action Committee meetings and every Commission allocation are part of the public record. Federal compliance survives when the governance trail is durable, transparent, and reproducible, not just internally consistent.
One-time capital fails when leaders refuse to redirect from projects that aren’t working. The framework I built allowed the city to reallocate within Treasury rules when housing financing fell through, when community conditions shifted, when a milestone slipped. The discipline was redirecting capital fast — and documenting every move so the audit trail held.
Managing $32.4 million in one-time federal capital under hard deadlines and public reporting is structurally identical to managing foundation grant deployment, bond proceeds, M&A integration budgets, healthcare grant compliance, or any other restricted-capital pool that arrives with strings attached.
What translates: the discipline of building governance before money moves; the habit of converting evolving regulatory guidance into clear operating policy; the documentation rigor that produces a defensible audit trail; the willingness to reallocate when projects fail; and the partnership leverage that turns one-time dollars into multi-year capacity.
The ARPA program is the proof. The capabilities are the asset.
The ARPA program reflects the same operating discipline I bring to every complex institutional challenge: design the governance, build the system, document the trail, and produce results that hold up under audit.