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Implementing Guidance for the Reports on Use of Funds Pursuant to the American Reinvestment and Recovery Act of 2009
 

These materials provide guidance on the reporting process for grantees who are recipient’s of the American Recovery and Reinvestment Act funds.

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General Overview
July 20, 2009

Overview of Recipient Reporting

Funds Pursuant to the American Recovery and Reinvestment Act of 2009,* dated June 21, 2009, addresses:

Answers questions and clarifies issues related to the mechanics and chronology of recipient reporting required by the Recovery Act;

Provides clarification on what information will be required to be reported into the central reporting solution at www.FederalReporting.gov and what information will be reported on www.Recovery.gov;

Instructs recipients on steps that must be taken to meet these reporting requirements, including the incorporation of sub-recipient reporting requirements under Section 1512(c)(4) of the Act; and

Establishes a common framework for Federal agencies and recipients to manage a data quality process associated with the Recovery Act recipient reporting requirements.

* Memo M-09-21 can be found at the following link: http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf

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Basic Principles and Requirements

Who is required to report under Section 1512?

  1. Prime Recipients who receive Recovery Act funds. General exceptions include:
    1. Mandatory programs
    2. Programs in Division B of the Recovery Act
    3. Programs providing awards to individuals (not sole proprietorships)
    4. Recipients of loan guarantees (unless 100% FFB financed)
  2. Prime recipients may delegate certain reporting responsibilities to sub-recipients
  3. Refer to supplement one of the OMB M-09-21 guidance
    1. List of Programs Subject to Recipient Reporting*
    2. Approximately 300 programs listed

* This supplement can be found at the following link:
http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21-supp1.pdf

What reporting is required under Section 1512?

  1. Total amount of funds received; and of that, the amount spent on projects and activities;
  2. A list of projects and activities funded by name to include:
    1. Description
    2. Completion status
    3. Estimates on jobs created or retained;
  3. Details on sub-awards and other payments

Please see Slide 1 [PDF, 35.4KB ]
Please see Slide 2 [PDF,  31.1KB]
Please see Slide 3 [PDF, 29.9KB]
Please see Slide 4 [PDF, 29.6KB ]

When the reporting is required to begin?

  • Initial reports are due October 10
  • Reporting is cumulative from enactment of the Recovery Act

How will recipients report?

What are expectations for July 10?

  • No global reporting requirement for July 10 as previously planned
  • Webinars during the week of July 20

Can Section 1512 reporting be combined with existing Federal reporting requirements?

Additional Reporting Issues

  • No waivers
  • Non-compliance could be treated as a violation of the award agreement
  • Finally, all the information will be available to the public through www.Recovery.gov

In-bound Recipient Reporting (FederalReporting.gov) Timeline and Activities

Please see Slide 5 [PDF, 52.6KB ]

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Major Recipient Reporting Activities

FederalReporting.gov is the centralized solution for ARRA section 1512
Recipient Reporting.

1. REGISTER

  • Before end of Quarter (Preferably no less than 35 days prior to the end of the
    quarter): Register Online at FederalReporting.gov
  • Registration opens August 17th

2. REPORT

  • Days 1-10 for submission Submit Reports Online at FederalReporting.gov

3. REVIEW (Comment Period)

  • Days 11-21 for Prime Recipient Review
  • ays 22-29 for Agency Reports available for extract/download from FederalReporting.gov

4. RELEASE

  • Days 11-29 for Summary or Detailed Information
  • Final Reports Available Day 30
  • Reports indicate agency review status
  • Not Reviewed
  • Reviewed – No Comments
  • Reviewed – Comments Provided na
    Submsion Published

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Data Quality Requirements

Scope of Data Quality Reviews:

  • Accuracy, Completeness and Timely Reporting
  • Avoidance of two key data issues
  • Material Omissions
  • “Instances where required data is not reported or reported information is not  otherwise responsive to the data requests resulting in significant risk that the public is not fully informed as to the status of a Recovery Act project or activity”
  • Significant Reporting Errors
  • “Instances where required data is not reported accurately and such erroneous reporting results in significant risk that the public will be misled or confused by the recipient report in question”
 

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Data Quality Process

Data Quality Responsibility

  • Prime Recipients - Owns recipient and sub-recipient data
  • Sub-recipients - Owns sub-recipient data
  • Federal Agency
  • Provides advice/programmatic assistance
  • Performs limited data quality review
  • Oversight Authorities
  • Establish data quality expectations
  • Establish data and technical standards
  • Coordinate any centralized reviews
  • Conduct Data Quality Reviews
  • Establish internal controls to ensure accuracy, completeness and timely reporting
  • Establish control totals
  • Establish an estimated distribution chart to help identify outliers
  • Establish data review protocol
  • Establish procedures for cross-validation of data

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Reporting on Jobs Creation

Prime recipients are required to report on all jobs they have created or retained as a result of the Recovery Act, by project or activity.

  • This information will be reported as two separate fields – a numeric field and a separate narrative with an expanded description of the job creation and reporting methodology.
  • Prime recipients will report the number created and retained using a standard calculation, translating both full and part time employees into “full-time equivalents,” or FTEs.
  • This calculation is performed by adding the total hours worked by all employees in the quarter, and dividing by the total hours in a full-time schedule.
  • In some cases recipients will not perform the work themselves, but will distribute the funding via a grant, loan, or contract to another entity. In these cases recipients will provide estimates of the jobs created or retained by those entities.

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Recipient Estimates of Job Impact

Prime recipients are required to generate estimates of job impact by directly collecting specific data from sub-recipients and vendors on the total FTE resulting from the sub-award.

  • In limited circumstances the prime recipient may employ an approved statistical methodology to generate estimates of job impact, collecting data only from a smaller subset of sub-recipients and vendors.
  • These limited circumstances should only include instances where comprehensive collection of jobs data from all sub-recipients and vendors is overly costly or burdensome or disrupts the prime recipients’ ability to accomplish their underlying mission.
  • Federal agencies must provide guidance for required sampling parameters. A process is now underway to develop this additional guidance.

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See entire PDF version:

Implementing Guidance for the Reports on Use of Funds Pursuant to the American Reinvestment and Recovery Act of 2009. Department of Treasury/IRS. 2009. English.