Please access the attached .PDF for a memo released April 3, 2009 by the President's Office of Management and Budget. This document provides some preliminary instructions on the reporting requirements for projects funded by the American Recovery and Reinvestment Act.
UNC GA has produced a complimentary, summary document of the OMB document. The text of this summary document can be found below.
Summary of OMB Guidance to Agencies and Information Collection Activities
OMB Guidance Document, April 3, 2009
Proposed Recipient Reporting Requirements
See appendix 9 and Sections 2.10, 2.11 and 2.13
- Agencies may retain current reporting requirements, in addition to the new data elements (see page 25)
- Reporting to be centralized trough a yet???to???be???build federal portal
- Frequency – cites October 10, 2009 as first reporting to centralized collection point – July
reporting to be determined – see Section 2.11
- Plans to expand subrecipient reporting to all tiers
- Reporting data elements:
- Reporting job creation/retention – expressed as FTE – see Section 2.13
- Narrative description of:
Type of new and retained jobs using labor categories/descriptions
- # of new and retained jobs
- % of project completion (not started, <50%, 50% or more, fully completed)
- Purpose, expected outputs/outcomes, including deliverables or unit of measure
- Other data elements
- For???profit subrecipients – executive compensation
Role of States in the collection and transmission of ARRA reporting – see Section 2.17
For those programs where the State is not the primary recipient, this Guidance does not create any specific role or expectation for States concerning Section 1512 data reporting. In these cases, Federal agencies are still required to initiate oversight mechanisms for quality, completeness, and timeliness of data submission.
Administrative Requirements and Standard Terms and Conditions
- OMB Circular A???110. Agencies are expected to follow administrative requirements located in OMB Circular A???110 ??? See Section 5.5
- OMB Circular A???133. Compliance supplement to OMB Circular A???133 will be updated to
promote ARRA accountability ??? See section 5.7
- Grants and cooperative agreements – in addition to standard agency practice, terms and
conditions that must be included in the competitive or formula grant agreements – see Section 5.9
- Use the agency’s standard award terms and conditions on award notices, where
applicable, unless they conflict with the requirements of the Recovery Act. In the case where the Recovery Act requirement conflicts with an agency’s standard award term or condition, the agency’s award term or condition should be modified, as necessary, to ensure compliance with the Recovery Act requirement.
- Ensure other award terms needed to implement the agency/program???specific provisions and general provisions of the Recovery Act are included on awards. Note that OMB has issued standard award terms for agencies to use in implementing Sections 1512, 1605 and 1606 for grants, cooperative agreements and loans. Agencies must ensure that they use any terms and conditions that implement other Recovery Act provisions, where applicable and as appropriate, such provisions in Sections 1511, 1515, 1553, 1604, and 1609.
- Ensure that there is an award term or condition requiring first tier sub???awardees to
begin planning activities, including obtaining a DUNS number (or updating the existing DUNS record), and registering with the Central Contractor Registration (CCR). Prime recipients and Federal agencies must establish mechanisms to meet Recovery Act data collection requirements. Agencies should work with prime recipients to ensure that DUNS and CCR requirements for first tier sub???awardees are met no later than the first time Recovery Act data requirements are due.
- Make clear that that any funding provided through the Recovery Act is one???time
- Include the requirement that each grantee or sub???grantee awarded funds made
available under the Recovery Act shall promptly refer to an appropriate inspector
general any credible evidence that a principal, employee, agent, contractor, subgrantee, subcontractor, or other person has submitted a false claim under the False Claims Act or has committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar misconduct involving those funds.
- Contracts ??? See section 6.4
- Five new FAR cases were published in Federal Acquisition Circular 2005???32, 74 FR 14621
- Section 1605 – FAR Case 2009???008, American Recovery and Reinvestment Act (the Recovery Act) – Buy American Requirements for Construction Material;
- Section 1512 – FAR Case 2009???009, American Recovery and Reinvestment Act (the Recovery Act) – Reporting Requirements;
- Sections 902, 1514, and 1515 – FAR Case 2009???011, American Recovery and Reinvestment Act (the Recovery Act) – GAO/IG Access; and
- Section 1553 – FAR Case 2009???012, American Recovery and Reinvestment Act (the Recovery Act) – Whistleblower Protections.
Agency risk mitigation factors – see Section 3.8
Grants.gov required use – see section 5.3, agencies may request approval for alternative methods for accepting grant applications during the anticipated peak period to reduce demand of Grant.gov’s limited resources. Check all information in the Synopsis for explicit application instructions.