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ARRA reporting guidlines released

By Mike Belarmino
SPECIAL PROJECTS COORDINATOR

The White House Office of Management and Budget (OMB) has released guidelines for preparing the required reports on the use of American Recovery and Reinvestment Act (ARRA) funds.

Two supplements — a list of all federal programs subject to reporting and a data model for the report itself — were also released, as was the methodology for estimating the number of jobs created or retained with Recovery Act funds.

The first reporting deadline is Oct. 10, 2009 for expenditures through Sept. 30, 2009. Deadlines are quarterly thereafter. Reports need to be submitted via the Internet. OMB has reserved the site www.FederalReporting.gov for Recovery Act report submission, but it is not expected to go live until Aug. 26.

“The reporting requirements may appear confusing and onerous at first glance, but it is essential for counties to comply,” said NACo Executive Director Larry Naake. “We must demonstrate our ability, not only to invest federal funds in worthy county projects that create jobs and spur local economies, but also to do so in a transparent and accountable manner.”

Following are some key points from the guidance document.

1.  All entities receiving Recovery Act funding will be subject to the reporting requirements, and the ARRA-required reporting is in addition to recipient reports required by individual federal agencies. Supplement 1 of the guidance lists the federal agencies that require additional reporting.

For each Recovery Act-funded project, counties will be required to report from 10 to 32 total “data elements.” Some common data elements include the funding agency name, project description and status, jobs created and retained, job narratives and area of community benefit. See Supplement 2 for the data elements.

In addition, limited data will also need to be reported on any vendors counties use to carry out projects or programs. This requirement applies whether a county is a prime recipient (receiving Recovery Act funds directly from the federal level) or a sub-recipient (receiving funds from a non-federal source, such as the state).

According to the guidance, a prime recipient may — but is not required to — delegate the responsibility of reporting information to the sub-recipient. Therefore, it is important that counties in a sub-recipient relationship communicate with their prime recipient partner regarding this process. In some instances, a county may be both recipient types and will need to work on each front to meet the requirements. 

2. There are several registration steps to complete before a recipient may submit a report. First, counties must obtain a D&B Data Universal Numbering System Identifier, or “DUNS number.” Counties may consult http://fedgov.dnb.com/webform to determine whether one already exists for their locality or start the process to obtain one.

The next step is to register for the Central Contractor Registration System (CCR) at www.ccr.gov. A DUNS number is required before attempting to register for the CCR.

Normally, this two-step process can take from one to several days. Yet, because of the high volume anticipated for Recovery Act reporting, counties are encouraged to complete this process well ahead of the projected Aug. 26 availability of the reporting Web site.  

3. Electronic submission using the Internet is the only supported method at this time for recipients to submit data. Counties that have limited Internet access or no Internet access should contact the individual funding agency for guidance on alternative submission methods. Contacting the appropriate agency also holds true if there is any potential issue for a county in meeting the reporting deadline. Otherwise, barring a natural disaster, NO WAIVERS will be granted to counties failing to meet the Oct. 10 deadline.

4. Outlined in the guidance is a timeline that details when data and any necessary corrections must be reported following the end of each quarter. This timeline is especially relevant in the event that a county needs to correct any data submitted or is asked to do so by a reviewing agency during the review-comment period. Counties may consult Section 3 of the guidance for this timeline.

5. The guidance outlines how recipients should count jobs associated with the Recovery Act. Section 5 of the guidance contains the formula that counties should use in determining how many jobs, expressed in units of full-time equivalents (FTE), were created or retained as a result of Recovery Act funds. The measure is cumulative across the project life cycle and does not reset at the beginning of each calendar or fiscal year.

These units are the result of calculating the total number of hours worked on a project funded by the Recovery Act divided by the number of full-time hours in a quarter.

It should be noted that there are two fields for the data on jobs; one is numeric and the other is text. The text field is for brief descriptions of the types of jobs created or retained.

Only direct jobs related to Recovery Act funded projects are to be counted. For example, clerical-administrative staff members who assist in preparing reports are considered critical but indirect support. They would not be counted as created or retained.  On the other hand, jobs that are actually on the site of a specific county infrastructure project funded by the Recovery Act would count.

The reporting guidance and supplemental documents currently can be found at: www.recovery.gov/?q=node/579.