Non-entitlement Units of Local Government (NEUs) Information

Kansas, along with 7 other states (Illinois, Indiana, Missouri, Nebraska, North Dakota, Ohio, and South Dakota) were identified as weak-minor civil divisions (“MCD”) states. MCDs generally play less of a governmental role but are still active governmental units. Kansas was required, by Treasury, to undertake a “facts-and-circumstances” test to determine eligibility of the MCDs based on their legal and operational capacity to accept ARPA funds and a requirement that MCDs provide a broad range of services that would constitute eligible uses under ARPA.

Per review of annual budgets, the Local Government entities below were categorically excluded due to a lack of evidence of operational capacity and a lack of evidence that entities provide a “broad range of services that would constitute eligible uses under ARPA.”

In addition to the Treasury’s eligibility compliance requirements, the majority of townships exceeded the 75% budget allocation cap, which would have resulted in funds in excess of $25M returned to Treasury. The Governor will recommend from SPARK a set aside of SFRF dollars for townships who did not receive LFRF dollars for eligible projects.

To view a list of incorporated cities that will receive funds, NEU identification numbers, total NEU allocation amounts and final NEU payments, view the links below.

To view a list of Minor Civil Divisions who were excluded, click the link below.

On May 24, 2021, the US Department of the Treasury released initial guidance for Non-Entitlement Units (NEUs). The Office of Recovery is in the process of analyzing the guidance and will communicate as details become available. You may view the Treasury guidance by clicking the links below.

What Every NEU Should Expect to Provide:

Based on Treasury guidance, the State will require the following information from each NEU prior to the disbursal of funds:

  • Local government name, Entity’s Taxpayer Identification Number, DUNS number and address 

  • Authorized representative name, title and email

  • Contact person name, title, phone and email

  • Financial institution information (e.g., routing and account number, financial institution name and contact information)

  • Total NEU budget (defined as the annual total operating budget, including general fund and other funds, in effect as of January 27, 2020) or top-line expenditure total (in exceptional cases in which the NEW does not adopt a formal budget)

  • Award terms and conditions agreement (as provided by Treasury to be signed)

  • Assurances of compliance with Title VI of the Civil Rights Act of 1964 (as provided by Treasury to be signed)

To view the Compliance with Civil Rights Requirements Form, please click the link below. 


To view Non-entitlement Unit Award Terms and Conditions, click the link below

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