Guidance, Reporting, Compliance

FFIS Reports

September 16, 2009: Reporting Requirements Under ARRA and FFATA
Power Point Presentation

Issue Brief 09-24 Detailed ARRA Reporting Guidance Released, July 9, 2009

Issue Brief 09-16 Putting Subaward Transparency Requirements to Test in ARRA,
April 9, 2009

ARRA Audits

August 16, 2010: Federal Officials Teach How to Prepare for a Recovery Act Audit The Maryland Governor's Grants Office posted an audio recording and presentations slides of "Preparing for a Recovery Act Audit" training hosted by Maryland that featured federal officials responsible for management and oversight of ARRA. For more information, see:

GAO Reports on ARRA and States

September 20, 2010: GAO Releases ARRA Report on Accountability GAO released the latest in a series of reports on the uses of and accountability for ARRA funds in 16 states and the District of Columbia. According to the report, as of September 3, 2010, $154.8 billion of the approximately $282 billion in ARRA funds for programs administered by state and local governments have been paid out by the federal government. This latest report includes five new recommendations to strengthen accountability and improve management and provides an update on previous recommendations. The full report is available at:

May 2010: GAO Releases ARRA Report on Accountability The Government Accountability Office (GAO) released the latest in a series of reports on the uses of and accountability for ARRA funds in 16 states and the District of Columbia. The report also comments on the jobs estimates in the recipient reports. The full report is available at:

March 4, 2010: GAO Issues Report on ARRA Program Implementation at DOE GAO recently released a report on the major factors affecting the Department of Energy's (DOE) implementation of ARRA programs. GAO addresses numerous issues facing both federal and state officials in administering these programs. Click here to read the report: 

March 2010: GAO Releases ARRA Report on Accountability
GAO released a report on the use of ARRA funds by states and localities to strengthen accountability. The report is available at:

December 29, 2009: GAO Releases Report on ARRA MOE Provisions GAO released a report on the maintenance of effort (MOE) requirements and similar provisions included in ARRA. Specifically, the report provides information on the provisions, the guidance federal agencies have issued to implement the requirements, and how responsible federal agencies are in determining whether recipients meet these requirements. To view the report, go to:

December 10, 2009: GAO Releases Report on State/Localities Use of ARRA Funds to Ensure Accountability GAO has released its fourth report that addresses selected states' and localities' uses of ARRA funds and the approaches taken by the selected states to ensure accountability of ARRA funds. The report updates the status of agencies' efforts to implement prior recommendations but does not include new recommendations. To view the report, see:

November 30, 2009: GAO Releases Correspondence on ARRA Contract Oversight GAO released correspondence that addresses contract oversight activities of the Recovery Accountability and Transparency Board as well as observations on contract spending in select states. To view the correspondence, go to:

November 19, 2009: GAO Finds Good and Bad in Stimulus Reports An official with GAO told Congress that while recipient reporting of federal stimulus dollars went relatively smoothly, errors were made. In a report released on November 19, 2009, GAO cited projects in which jobs were reportedly created but no funds expended; projects with nearly $1 billion spent but no jobs created; and inconsistency in the guidance and counting of Full-Time Equivalents (FTEs). GAO aimed several of its recommendations at the Office of Management and Budget (OMB), which spearheaded the regulatory process for ARRA. Specifically, GAO said that OMB should "(1) clarify the definition and standardize the period of measurement for FTEs and work with federal agencies to align this guidance with OMB's guidance and across agencies; (2) given its reporting approach, consider being more explicit that 'jobs created or retained' are to be reported as hours worked and paid for with Recovery Act funds, and (3) continue working with federal agencies and encourage them to provide or improve program specific guidance to assist recipients, especially as it applies to the full-time equivalent calculation for individual programs." To read the report, go to:

November 6, 2009: GAO Reissues ARRA Report GAO reissued the following report: Recovery Act: Funds Continue to Provide Fiscal Relief to States and Localities, While Accountability and Reporting Challenges Need to Be Fully Addressed (GAO-09-1016, September 23, 2009). To view the revised report, go to:

April 23, 2009: As Initital Implementation Unfolds in States and Localities, Continued Attention to Accountability Issues Is Essential

Summary Report (40+ pp.): 
Full Report (300+ pp.):

IG Reports

January 31, 2011: HHS OIG Issues ARRA Work Plan The OIG released its 2011 implementation and work plan for ARRA oversight activities:

November 2009: IG Reports on ARRA Funds Available Online
When cases of potential fraud, waste, and abuse are reported, the Inspector General (IG) of each agency decides whether to investigate and determine the validity of the allegations. The Inspectors General also work with managers of federal programs and recipients of ARRA funds to help prevent fraud, waste, and abuse. Their findings, status reports, recovery plans, and testimony are included in the following section of the ARRA website, along with reports on recovery oversight from the GAO:

ARRA Section 1512 Reporting Requirements

October 1, 2010: OMB Re-Issues Latest Round of ARRA Guidance The Office of Management and Budget (OMB) reissued the latest ARRA reporting guidance (M-10-34, published on September 24, 2010). Based on significant feedback from ARRA recipients, OMB revised the guidance and returned to the previous method of reporting. OMB has re-posted the guidance to reflect the change:

September 24, 2010: OMB Issues Updated Guidance on ARRA Reporting Requirements OMB provided additional guidance to federal agencies and recipients, effective with the next reporting period set to begin on October 1, 2010, on the recently-enacted Education Jobs Fund, reporting procedures, changes for federal contractors, and improving narrative descriptions in recipient reporting. The full guidance can be accessed at:

May 4, 2010: OMB Releases Additional Information on ARRA Reporting Compliance The Office of Management and Budget (OMB) released a memorandum for federal agencies that outlines additional steps necessary to address recipient reporting non-compliance. To view the memorandum, go to:

April 6, 2010: President Issues Memorandum on Combating Non-Compliance with ARRA Reporting In a move signaling an increase in oversight of recipient reporting requirements under ARRA, the president issued a memorandum in the Federal Register directing agencies to further intensify their efforts to improve reporting compliance by prime recipients of ARRA, where appropriate, by terminating awards; pursuing measures such as suspension and debarment; reclaiming funds; and considering, initiating, and implementing punitive actions. To view the memorandum, go to:

March 22, 2010: OMB Releases Updated Guidance on ARRA Reporting OMB issued a memorandum that provides guidance to federal agencies and recipients intended to improve the ARRA reporting process. To view the guidance, go to:

December 18, 2009: New ARRA Guidance Issued by OMB The Office of Management and Budget (OMB) issued new guidance (M-10-08) regarding Section 1512 data quality and jobs reporting. To view the new guidance, go to:

November 30, 2009: OMB Releases Guidance on Improving Compliance in ARRA Recipient Reporting OMB released a memorandum (M-10-05) on improving reporting compliance under ARRA, focusing on those recipients that failed to meet the reporting deadlines. To view the guidance, see:

October 30, 2009: Public Information on Grant Recipients Grant recipient reporting information is available to the public:

September 24, 2009: OMB Posts Section 1512 Q&A OMB posted additional ARRA Section 1512 recipient reporting questions and answers on its website. The new Q&As are designated with an asterisk and can be found at:

September 14, 2009: RATB Announces Date Changes The Recovery Accountability and Transparency Board (RATB) announced that it was moving the dates by which it would make data from recipients of recovery funds available to the public. All recipients of recovery funds are to report spending information on or before October 10 and then have a short reconciliation period to make corrections. States have expressed concern that the RATB intended to make all information it received on October 10 public immediately and before recipients had an opportunity to reconcile their reports. To address these concerns the RATB has decided to follow the following timeline for displaying recipient data on Data associated with contracts awarded directly by the federal government will be displayed October 15; data regarding grants, loans and other assistance will be displayed October 30; and all changes made by recipients during the reconciliation period will be made public after November 1.

August 31, 2009: Section 1512 Reporting Requirements OMB updated its list of programs that are subject to ARRA Section 1512 recipient reporting requirements. The list is a supplement to OMB's June 22, 2009, guidance on ARRA recipient reporting requirements. The updated list of programs can be viewed at:

August 2009 Agency-Specific Guidance on Section 1512 Several agencies have released agency-specific guidance on how prime recipients should estimate jobs created or retained in order to satisfy ARRA Section 1512 recipient reporting requirements. Agencies with available guidance on jobs estimates include the Department of Justice, Department of Housing and Urban Development, the National Science Foundation, the National Endowment for the Arts, and the Department of Veterans Affairs. All guidance can be downloaded at:

August 17, 2009: Registration for Fund Recipients Registration for funding recipients required to report under ARRA Section 1512 opened on All funding recipients must register prior to fulfilling their reporting obligations. The first reporting period opens on October 1, 2009, with the first quarterly reporting deadline of October 10, 2009. Prerequisites for recipient registration include obtaining a DUNS number from Dun & Bradstreet and registering with Central Contractor Registration (CCR).

August 7, 2009: Reporting Requirements Update OMB updated the list of programs subject to ARRA Section 1512 recipient reporting requirements. This list originally appeared as a supplement to the June 22, 2009, guidance released by OMB. The updated list can be found at:

August 7, 2009: ARRA Notice The Recovery Accountability and Transparency Board released a notice and request for comments in the Federal Register on information collection activities described in ARRA Section 1512 (recipient reporting requirements) and set-forth in the June 22, 2009 guidance by the Office of Management in Budget. The Board is seeking comments on 1) ways to enhance the quality, utility, and clarity of information being collected, and 2) ways for the board to minimize the burden of information collection activities on the public, among other issues. Comments are due by October 6, 2009. The notice can be viewed at:

August 2009: OMB Posts ARRA FAQ OMB recently posted a series of Frequently Asked Questions (FAQs) related to ARRA Section 1512 reporting requirements for recipients of federal financial assistance. OMB also provided clarification to the June 22, 2009, memo on ARRA reporting requirements. The FAQs and clarification can be viewed at:

August 2009: OMB Webinar Training During the week of July 20, 2009, OMB hosted a seven-part series of webinars on ARRA reporting requirements. The training included a discussion of the new central reporting solution,, which should be accessible for registration beginning August 17, 2009. Presentation slides and the webinar audio files are available for download at:

August 2009: Reporting Data Dictionary On August 4, 2009, the Recipient Reporting Data Dictionary, which describes the data elements specifically required for Section 1512 recipient reporting under ARRA, became available for viewing on This model is intended for use for the October 10, 2009 reporting deadline.

June 22, 2009: OMB Releases Reporting Requirement Details OMB released detailed information on reporting requirements included in Section 1512 of the Recovery Act, in addition to clarification on job creation estimates by recipients. The guidance addresses the mechanics and chronology of recipient reporting; provides clarification on reporting to and; clarifies the definition and obligations of recipients and sub-recipients; provides a common framework for data quality; and further clarifies job creation estimates by recipients. Included with the guidance are two supplements that model the data flow from recipients to the federal government and provide a complete list of programs subject to Section 1512 reporting. States must file their first recipient reports on October 10, 2009, for all funds received and distributed since February.

The official document, "Implementing Guidance for Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009," can be accessed on the OMB website at:

April 3, 2009: OMB Publishes Updated Guidance to Agencies for Implementing the American Recovery and Reinvestment Act of 2009
On April 3, 2009, OMB published Implementing Guidance for ARRA. This is the second installment of detailed government-wide guidance for carrying out programs and activities enacted in the Recovery Act. This updated guidance supplements, amends and clarifies the initial guidance issued by OMB on February 18, 2009 (Initial Implementing Guidance for the American Recovery and Reinvestment Act of 2009, M-09-10). Updates to the guidance are based on ongoing input received from the public, Congress, state and local government officials, grant and contract recipients and federal personnel.

April 1, 2009: OMB ARRA Grant Reporting See attached ARRA grant reporting guidance from OMB, as it appeared in the Federal Register.

February 18, 2009: OMB Guidance on the Recovery Act OMB has released initial implementing guidance on the Recovery Act which can be found at:

Additional OMB Guidance on ARRA

September 14, 2011: OMB Tells Agencies to Spend Recovery Funds Faster OMB released a memorandum asking federal agencies to accelerate spending of remaining ARRA funds. Specifically, agencies are to take steps to complete all ARRA-related projects by September 30, 2013, submit any waiver requests for projects that will not meet the deadline by September 30, 2012, and put plans in place for recovering all unused funds.  The memo recognizes that 85% of ARRA funds have been paid out and that most remaining funds are already obligated. Click here to view the memo:

May 11, 2009: Admin Cost Guidance
OMB has released guidance on the administrative costs of state grantees under ARRA:

In a related development, senators Lieberman, Collins, Burris and McCaskill have introduced legislation (S. 1064) to allow state and local governments to access .5% of ARRA funds for administrative purposes. The bill mirrors H.R. 2182, which passed the House Oversight and Government Reform Committee last week.

April 23, 2009: OMB Guidance on Buy America and David-Bacon OMB released interim final guidance that clarifies application of Sections 1605 ("Buy America"), 1606 ("Wage Rates") and 1512 (Audit and Reporting) in ARRA. The public comment period runs until June 22, 2009. In particular, the interim guidelines clarify three exceptions to the Buy America requirement: 1) non-availability (lack of sufficient quantities of domestically-available materials); 2) unreasonable cost (compliance inflates project cost by more than 25%); or 3) public interest (where application of the domestic preference would be inconsistent with the public interest). The guidance is available at:

March 2009: Audit Guidance OMB issued its compliance supplement to assist auditors in performing required audits. For the first time, the supplement addressed the treatment of funds under ARRA. OMB notes, however, that additional guidance is required to cover issues unique to ARRA funds. OMB is expected to release additional guidance regarding audits of ARRA funds in late June. The OMB supplement is available at

White House Memoranda

September 2010: Vice President’s Office Releases FY 2010 Year-End ARRA Report The vice president’s office presented the president with the FY 2010 year-end report on the implementation of ARRA. To view the report, click here:

January 13, 2010: Council of Economic Advisers Releases Report on ARRA The Council of Economic Advisers (CEA) released its quarterly report on the impact of ARRA. CEA reports that as of the end of December 2009, $263 billion has gone to households and businesses in the form of tax reductions and another $149.7 billion has been obligated for projects and activities. To view the entire report, go to:

March 20, 2009: Obama ARRA Memo President Obama sent a memorandum to the heads of executive departments and agencies regarding ARRA implementation and responsible spending; it is attached

February 9, 2009: ARRA Memorandum Attached is a February 9, 2009, memorandum from OMB and the White House to federal agencies directing them to prepare for passage of the ARRA. The memorandum is instructive in that it clearly states the priority that will be given to maintaining transparency and accountability during implementation of the ARRA.

Certification Requirements

Recovery Act Requirements For a list of certification requirements for states receiving federal grants funded in ARRA, click here.

Agency Announcements and Guidance





Homeland Security

Housing/Community Development

Human Services





Public Health



Additional Programs