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

December 29, 2009: GAO Releases Report on ARRA MOE Provisions The General Accounting Office (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: http://www.gao.gov/cgi-bin/getrpt?GAO-10-247

December 10, 2009: GAO Releases Report on State/Localities Use of ARRA Funds to Ensure Accountability The General Accounting Office (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: http://www.gao.gov/new.items/d10231.pdf

November 30, 2009: GAO Releases Correspondence on ARRA Contract Oversight The General Accounting Office (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: http://www.gao.gov/new.items/d10216r.pdf

November 19, 2009: GAO Finds Good and Bad in Stimulus Reports An official with the Government Accountability Office (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: http://www.gao.gov/new.items/d10223.pdf

November 6, 2009: GAO Reissues ARRA Report The General Accounting Office 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: http://www.gao.gov/cgi-bin/getrpt?GAO-09-1016

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

Summary Report (40+ pp.): http://www.gao.gov/new.items/d09631t.pdf 
Full Report (300+ pp.): http://www.gao.gov/new.items/d09580.pdf

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 Government Accountability Office:
http://www.recovery.gov/Accountability/inspectors/Pages/Home.aspx

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: http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-08.pdf

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: http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-05.pdf

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

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: http://www.whitehouse.gov/omb/recovery_faqs/

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 www.Recovery.gov. 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:
http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21-supp1.pdf

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:
http://www.recovery.gov/?q=content/agency-guidance-reporting

August 17, 2009: Registration for Fund Recipients Registration for funding recipients required to report under ARRA Section 1512 opened on www.FederalReporting.gov. 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: http://www.whitehouse.gov/omb/recovery_default/

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:  http://edocket.access.gpo.gov/2009/pdf/E9-18933.pdf

August 2009: OMB Posts ARRA FAQ The Office on Management and Budget (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: http://www.whitehouse.gov/omb/recovery_faqs/

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, www.federalreporting.gov, which should be accessible for registration beginning August 17, 2009. Presentation slides and the webinar audio files are available for download at: http://www.whitehouse.gov/blog/Recovery-Act-Webinar-Training-Materials

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 http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21-supp2.pdf. This model is intended for use for the October 10, 2009 reporting deadline.

June 22, 2009: OMB Releases Reporting Requirement Details The Office of Management and Budget (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 www.recovery.gov and www.federalreporting.gov; 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: http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf

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. http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-15.pdf

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: http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-10.pdf.

May 11, 2009: Admin Cost Guidance OMB has released guidance on the administrative costs of state grantees under ARRA:  http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-18.pdf

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: http://edocket.access.gpo.gov/2009/pdf/E9-9073.pdf.

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 http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc/.

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: http://www.whitehouse.gov/sites/default/files/microsites/100113-economic-impact-arra-second-quarterly-report.pdf

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.

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

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