Archive for June, 2009
Tucked inside OMB’s latest guidance on Recovery Act reporting are several items of interest that I wanted to point out.
First, there should be an addendum to the 2009 Circular A-133 Compliance Supplement coming out very soon. OMB provided a list of all Recovery Act guidance, including an “Addendum to the Single Audit Compliance Supplement – American Recovery and Reinvestment Act” that should be out by June 30. I haven’t seen it yet, but will let everyone know when it appears.
OMB’s new guidance also said it reviewed the Obama Administration’s new policy on communications with lobbyists regarding Recovery Act funds and is preparing to issue revised guidance. Although there is no official word on what the revisions will be, in In a blog post on May 29, Norm Eisen, Counsel to the President for Ethics and Government Reform, said the ban on oral communications will be expanded to include not only federally registered lobbyists, but other individuals who have already submitted applications for Recovery Act funds. It’s not quite clear what exactly this means or what impact it will have on applicants, but Management Concepts will be analyzing this when it happens.
Finally, under the new reporting guidance, there is no “global requirement” for reporting data for the period ending June 30 but the information must still be collected. This will give federal agencies, OMB, and recipients a chance to clarify logistics and correct problems before the October reporting period. OMB and the Recovery Act Board say they will host forums, meetings, and pilots relating to Recovery Act reporting in July. At the Association of Government Accountants conference in New Orleans last week, my colleague heard that OMB would be presenting a series of training webinars on each “topic” in the Reporting guidance.
As always, our Federal Grants Update course will give you more detail on the ever-changing Recovery Act guidance, as well as other developments in the grants management field.
On 22 June 2009, the Office of Management and Budget issued additional guidance intended to help recipients, pass-through entities, subrecipients, and federal agencies meet the reporting requirements of Section 1512 of the American Recovery and Reinvestment Act.
The guidance was issued as a memorandum to federal agencies, and is available at the OMB website .
From this site you can also download a list of the programs that are subject to the Recovery Act’s reporting requirements, as well as a sample Excel spread-sheet that can be used as a model for reporting.
The guidance addresses an array of issues, ranging from federal agencies’ oversight responsibilities and prime recipients’ responsibilities, to ensuring data quality and defining “jobs” for reporting purposes.
I’ll be posting more information about the new guidance very soon, but I wanted to give everyone a heads-up about the new release.
The Office of Management and Budget has placed the final drug-free workplace guidance for grants and cooperative agreements in a new Title 2 CFR Part 182, a move that continues the government’s efforts to consolidate grants policy into one central location. The drug-free workplace guidance in Part 182 is virtually the same as the common rule currently being used by federal agencies and makes no substantive change to existing policies and procedures.
The office originally announced its intention to move the governmentwide guidance in September 2008. Now with the issuance of the final guidance, each federal awarding agency will publish a rule in its own chapter of 2 CFR to adopt the OMB governmentwide guidance and remove the full text of the November 2003 common rule from its CFR chapter. This agency codification gives OMB’s guidance the force of regulation on that agency’s grants and recipients.
The Federal Register notice announcing the drug-free guidance final move to 2 CFR Part 182 was published June 15 and is available by clicking here.
The Office of Management and Budget just gave federal agencies guidance on how to report both Recovery Act and Transparency Act data to USAspending.gov, the site created as a searchable, single database where the public can find detailed information about federal awards. Much of the new “operational guidelines” are technical in nature, dealing with issues such as required formatting and submission methods. However, OMB also explains one reporting question that arose under the Recovery Act: aggregate reporting for small awards.
The Recovery Act requires reporting on all funding, but allows for reporting of awards under $25,000 and awards to individuals as aggregates. According to OMB’s guidance, an aggregate record is created by taking a group of similar records and tallying the dollars based on a specific set of data fields to create one summary (or aggregate) record. Agencies should strive to submit as much information as possible under $25,000 at a transaction level, OMB says, but if reporting information under $25,000 poses a significant administrative burden on agencies, they can also report these amounts as county aggregates instead.
While aggregate reporting is only required for Recovery Act funds, and not under the Transparency Act, OMB advises agencies to begin including aggregate information for all funding types to provide maximum transparency to the public.
You can read the OMB memo to federal agencies by clicking here.