New ARRA Reporting Guidance Released by OMB
Wednesday, September 29 2010 @ 02:59 PM CDT
Last Friday, September 24, 2010, OMB released updated guidance on reporting required by the American Recovery and Reinvestment Act.
Full memo is provided here. This guidance covers a number of specific issues that have been raised by agencies, recipients, and others over the past few months. The guidance is split into the following topics:
- Guidance on applicability of Recovery Act reporting requirements to Education Jobs Fund in Public Law No. 111-226
- Updated guidance on reporting procedures (e.g. non-compliance, recipient reporting extensions, paper reports, mark as final clarification, changes to prior reports)
- Changes for Federal contractors
- Improving transparency of narrative descriptions in recipient reporting (including changes to the Recipient Reporting Data Model)
- Previous guidance had indicated that the award period must have ended before a report can be marked final. This is no longer the case. The new guidance states that "In instances where the award end date is in the future, recipients may still mark an award as final if the requirements listed in this Section are met".
- Pervious guidance had indicated that if all recovery funds have been received and the project status is complete per federal agency requirements and/or performance measures. This has been changed to where a a project may be marked as final when all funds have been expended, and 75% or more of the funds awarded have been invoiced and received. If additional jobs are yet to be funded, the prime recipient may not mark the report as final.
- Narrative descriptions will be reviewed to ensure they have sufficient clarity and detail. Any abbreviations or acronyms that may be unfamiliar to the general public must be explained. Narratives must use complete sentences. Narrative must also adhere to instructions and examples in agency-specific guidance.
- The requirement to report accomplishments has been expanded to prime recipients and sub-recipients. We currently collect the required information in the "status description" on the report. On previous reports, the project description was the only field used to supply information for the 1512 report. This will be expanded to include narrative from both the project and status descriptions. The main issue we have are that the descriptions in the state system may be longer than 2,000 characters allowed in the federal report. Reporters will need to keep the character length of both the project description and status descriptions combined to less than 2,000 characters. If the 2,000 character limit, we will only populate the 1512 report with narrative included in the status description.
- Prime recipients are also expected to provide a summary of sub-recipient accomplishments on their reports in the status description field.
- In instances where Total ARRA Expenditures are less than the Award Amount on a final report filed for a prime recipient, the recipient of the award must explain why the full award has not been expended in the status description on the report.
- A clarification was made to indicate that the award date is the date the award is signed by the Federal Awarding Agency Official.
- A clarification was also made that financial information reported for small sub-awards, sub-awards to vendors, and sub-awards to individuals is cumulative, which is consistent with previous state guidance.