Grants Blog

Archive for the ‘Recovery Act’ Category

Just days before the next Recovery Act reporting cycle begins, OMB has issued further reporting guidance for federal agency personnel and recipients. In the March 22 memo, OMB addresses data quality, technical issues, and the importance of single audits, among other topics.

Some of the specific items covered in the memo include the actions federal agencies must take during the new “continuous corrections” phase of the reporting cycle, a new category of data quality that federal officials must now review, immediate actions that should be taken to review and act on single audit findings, and for recipients, technical issues such as when a report is considered to be the “final” report.

And in the area of single audits, there is an interesting note. Because of the need to quickly review and act on audits, OMB has told federal agencies not to grant any requests for A-133 filing extensions.

OMB says it realizes the April reporting period is fast approaching and that it will respond to questions and concerns in a timely manner.

You can download the new guidance here.

Now that the Recovery Act is one year old, the Government Accountability Office is taking a look back — and a look forward — at how state and local agencies have used the money they received, and the efforts being made to improve accountability for those awards.

Most of the nearly 200-page report deals with specific programs and agencies, including Medicaid, Transportation, and Education, but GAO also addresses issues relating to recipient reporting, and a significant amount of attention to the OMB A-133 single audit process.

GAO seems generally pleased with OMB’s efforts to use single audits, although the office continues to urge OMB — and Congress — to amend the single audit process so that it can be more efficient and timely. And GAO has several agency-specific recommendations, such as encouraging the Education Department to work with OMB on a formula for determining FTE jobs during the summer months.

One new recommendation that should be of interest to most recipients is that OMB develop a “formal and feasible” framework for review of recipient reporting changes during the continual update period and consider providing more time for agencies to review and provide feedback to recipients before posting updated reports on Recovery.gov.

You can read the full GAO report here.

Well, as most of the nation’s capital braced last week for a weekend blizzard, the Office of Management and Budget was busy releasing new guidance on the Recovery Act reporting requirements.

The memo released late Friday afternoon targets three areas: steps that federal awarding agencies must take to ensure the quality of data being reported by Recovery Act recipients; how federal agencies are to deal with recipients who have not reported or who have persistent reporting problems; and how recipients are to calculate and report the number of jobs created or saved with Recovery Act dollars.

For example, federal agencies are now required to provide recipients with a specific list of data about their awards, such as award type, amount, award number, CFDA number, federal agency number, and TAS (Treasury Account Symbol) code. OMB also offers guidance on how agencies are to assess late and non-reporters, and how to submit that list, which will be published on Recovery.gov.

The interesting aspect of the guidance for recipients is that OMB has offered detailed, step-by-step instructions and examples for calculating jobs. Further, recipients are no longer required to report cumulative jobs data, but rather simply job information for the reporting period. 

You can view the new memo here.

Once again, the Office of Management and Budget is directing federal awarding agencies to step up their efforts to ensure recipients meet their reporting responsibilities under the Recovery Act. And for those recipients who don’t comply, federal agencies will be taking action.

In a new memo, OMB Director Peter Orzag says that while a large number of recipients did report on Recovery Act projects in the first reporting period, a significant number failed to do so. He reminded federal agencies that failure to report constitutes noncompliance with grant award terms and conditions, and may have serious consequences.

To address the issue, federal agencies must take further steps to ensure Recovery Act recipients understand their reporting responsibilities as well as the consequences of noncompliance. Agencies must not only identify each recipient that has not submitted timely reports, but must also contact these organizations, assess the severity of the noncompliance and determine what corrective actions are to be taken – up to and including termination of funding.

To read the OMB memo, click here.

Registration on the new FederalReporting.gov website – where grantees must post information about their work under the Recovery Act – is lagging and OMB wants federal agencies to help.

In a just-released memo to federal agencies, OMB outlined three steps that federal agencies must “take immediately” to help recipients and subrecipients register with and submit information to FederalReporting.gov.

First, agencies are to begin targeted outreach to remind recipients of their reporting and registration obligations. OMB noted in the memo that current registration numbers on FederalReporting.gov are below expectations and that this could lead to underreporting as the October 10 reporting deadline approaches.

Second, OMB has told agencies to provide in-kind resources for a new government-to-government initiative set up by OMB and the Recovery Act Accountaiblity Board. This effort will  supplement existing technical assistance resources to specifically help state and local governments meet their reporting responsibilities.

Finally, agencies must label recipient registration and reporting delays as a potential agency risk and idenitify steps to mitigate that risk.

To read the full OMB memo to federal agencies, click here.

That the new website FederalReporting.gov is now live and both federal agencies and recipients of Recovery Act funds are being encouraged to complete the one-time registration.

Although reporting will not begin until October, agencies are encouraged to register now, well in advance of the October date.

The new site is where recipients will submit the required Recovery Act funding and project reports and where federal agencies will review and comment on the information before it is posted to the public Recovery.gov website.

FederalReporting.gov has an FAQ section, a page where you can download reporting templates, general information about the site and about the Recovery Act, and  a live chat feature for those who need assistance registering.

The online newsletter Government Executive has posted a checklist that may be useful for those responsible for monitoring or administering Recovery Act grants.

The list summarizes the major reporting requirements for the next three months, organized by deadline date.

You can view the checklist here.

OMB has published additional guidance for auditing Recovery Act programs and signaled that even more is on the way.

The guidance was published as an addendum to the 2009 OMB Circular A-133 Compliance Supplement and is now available on OMB’s website. The guidance goes into detail on a number of issues  related to auditing these new programs, such as checking allowable and unallowable activities. However, it still does not address one of the more complicated areas of Recovery Act program administration: reporting.

OMB says “at this time, the reporting area indicates only that more substantive coverage of ARRA reporting will be covered in the next Compliance Supplement addendum.”

We’ll let you know as soon as that additional addendum is released.

If you’re interested in learning more about federal grants auditing, check out Management Concepts’ two-day course, Audit of Federal Grants and Cooperative Agreements. Also, our annual Federal Grants Update course is still being offered in locations around the country.

In an effort to improve the transparency of Recovery Act awards, the Obama Administration is restricting lobbying efforts by potential recipients, and making any lobbying activities that do occur visible to the public.

OMB has just issued a memo to federal agencies that updates the lobbying restrictions that were imposed on Recovery Act funds. In essence, after competitive grant applications have been submitted, there can be no oral communication between federal agency officials and anyone regarding that specific project, whether or not they are registered lobbyists. The prohibition applies after the submission of formal applications , and up through the award of competitive grants under the Recovery Act.

There are a few exceptions, however. For example, federal agency officials may asnwer questions that are technical in nature, and the communication is permissible if the federal employee initiates the contact.

But if communication does take place – including written communications – the federal employee must report it and a summary will be posted on a publicly available website.

To read the full OMB memo to agencies, click here.

I’m listening to one of OMB’s Recovery Act reporting training webinars and wanted to alert everyone to an important upcoming date they just announced: on August 17, registration will open on the new FederalReporting.gov site.

All federal awarding agencies, prime recipients, and designated subrecipients must register with the system in order to submit, review, post, and correct the reports required under the Recovery Act.

Entities are encouraged to register early on FederalReporting.gov; ideally at least 45 days before the Ocotber reporting period begins.

I’ll post any additional information about the Recovery Act training webinars throughout the week.