Some Notes About the New Reporting Guidance
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.