Transcript PowerPoint Presentation Template
American Recovery and Reinvestment Act An Update
MAGPPA Wednesday, February 17, 2010 JCJC Advanced Technology Center
Department of Finance and Administration 1
Agenda
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American Recovery and Reinvestment Act – An Overview Mississippi’s Visibility Mississippi Reporting Model Definitions Who Reports What (several topics) FederalReporting.gov
Executive Reporting Memos and Instructions Reporting Observations NGA Task Force (Data Model, Jobs, Communication) M-10-08 Revised Jobs Reporting What Is Our Status?
Quality Assurance Plan (Decentralized Reporting, Responsibilities, Leveraging Activities Fraud, Waste, and Abuse Administrative Cost Stimulus360 – Mississippi’s Reporting Solution (Overview) Gearing up for April 10 Reporting Assistance Q&A
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American Recovery and Reinvestment Act
What is it?
Direct response by the Congress and the President to the economic crisis
When effective?
Passed by Congress February 13, 2009 Signed by the President February 17, 2009
What are the immediate goals of the Act?
Create new jobs as well as save existing ones Spur economic activity and invest in long-term economic growth Foster unprecedented levels of accountability and transparency in government spending
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American Recovery and Reinvestment Act
How are these goals to be accomplished?
Provides $288B in tax cuts and benefits for millions of working families and businesses Increased federal funds for education and health care as well as for entitlement programs (Medicaid, Unemployment Benefits) by $224B Made $275B available for federal contracts, grants, and loans Requires recipients of Recovery Act funds to report quarterly on the amount of monies spent, the status of the projects, the number of jobs affected by the Recovery Act Posts, pretty much in raw data form, all the quarterly reporting details on Recovery.gov so the public can track the spending of the $787B The $787B was the starting point – other monies have been added and some refocused Current Congress is discussing other options for extending ARRA funds but generally most expire in FY2012
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American Recovery and Reinvestment Act
What are some specific areas of focus?
Broadband internet access – reaching out to the areas of the US that are presently not covered Infrastructure – road and bridge repair; high speed rail projects; airport and other transportation hub projects Computerization of health information records to reduce errors and reduce health care costs Energy focus – weatherization of homes and businesses and government facilities; “greening” of America through use of renewable energy sources Education support – LEAs and IHEs and other entities Law Enforcement General government support
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American Recovery and Reinvestment Act
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Source: http://en.wikipedia.org/wiki/American_Recovery_and_Reinvestment_Act_of_2009
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American Recovery and Reinvestment Act
Stimulus 2?
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Mississippi’s Visibility
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Round 6 focuses on the One Year Anniversary of the Recovery Act and is set to begin in late February.
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Mississippi Reporting Model Definitions
Centralized vs. Decentralized
Mississippi’s 1512 Reporting Model – Decentralized State’s prime recipients “push the button” to submit Mississippi’s Software Tool – Stimulus360 Centralized tool but reporting still
decentralized!
Deployment scheduled to support April 2010 (2010Q1) 1512 Reports
Used To Date and Basis of Stimulus360
Excel Template from FederalReporting.gov
Use GRANTS/LOANS template
DO NOT
Use CONTRACTS template (for Federal Agencies Only!)
Remember
: 1512 Reporting is
over and above
by the Federal granting agency!
other reporting required Other issues: FederalReporting.gov requires “Copy Forward” be used in certain circumstances > > results in double work since state agencies are required and other entities requested to produce copies of the 1512 reports for stimulus.ms.gov
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Mississippi Reporting Model Definitions
Prime Recipient Definition
Who Is the State SAAS Agencies Includes State Ports (Gulfport, Yellow Creek) Includes the Board for the Institutions of Higher Learning Includes the Board for the Community and Junior Colleges How is PRIME defined at this level?
State is the State Lead Agency Sets the rules for State Agencies receiving sub-allocations (part of PRIME) Sets the rules for the sub-recipients Collects all the info Files the 1512 Report for the Federal Award
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Mississippi Reporting Model Definitions
Prime Recipient Definition
Who Is Not the State (i.e. “non-State”) Everyone Else Institutions of Higher Education (Universities and Colleges) CAFR Component Units Cities and Counties Local School Districts Municipal and County Ports and Airport Authorities Financial Authorities (Development Bank, Business Finance Corp) MIB, Prison Industries
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Mississippi Reporting Model Definitions
Prime Recipient Definition
If non-State entities are PRIME recipients File 1512 on their own April 2010 Reporting Follow same process as January 2010 for 2009Q4 Send a copy to [email protected]
July 2010 Reporting Provided option to move to STIMULUS360 Reports posted on www.stimulus.ms.gov
If non-State are sub-recipients of the State Follow the procedures of the State Lead Agency for each specific Federal Award
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Mississippi Reporting Model Definitions
Who Are the Mississippi Players
Statewide Office of the Governor Stimulus Coordinator for the State Amanda Jones, Counsel to Governor Haley Barbour Department of Finance and Administration/OFM Monitoring Internal Controls/Quality Assurance Department of Finance and Administration/MMRS Tools Data Repository Policies and Procedures Repository Department of Finance and Administration/OB&FM State Fiscal Stabilization Funds Lead Agency on behalf of the Governor Office of the State Auditor Single Audit Monitoring for all but State level Performance Audits Investigation of Fraud and Abuse
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Mississippi Reporting Model Definitions
Who Are Agency / Governmental Entity Players
Many Players Executive Director Program Manager for the Federal Award Finance and Accounting Staff 1512 Report Preparers Recommendation – No more that 1 Federal Award per Preparer 1512 Report Reviewers Recommendation – No more than 2-3 Federal Awards per Reviewer Internal Auditor
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Mississippi Reporting Model Definitions
Key Issues
Communicate with sub-recipients (and if a State Agency with other State entities receiving sub-allocations) Set standards and timelines and stick to them Keep up with the constant changes by the federal granting agencies Stuff changes every day Question everything within the context of OMB’s most recent guidance Watch out – OMB will likely issue additional changes in March effective for April reporting No decisions can be made in a vacuum Program and Finance/Accounting staff must be on the same page!
Every decision reduced to writing Document! Document! Document!
Maintain copies of other documentation supporting your decisions Make sure the documentation is for a resource authorized to make their answer stand up Work papers must be orderly, accessible, and auditable!
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Who Reports What….
Who is a Prime Recipient?
What does the Prime Recipient report?
What does OMB say about this?
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Who Is A Prime Recipient?
State is the Prime Recipient when a State Agency (Lead Agency) receives an award directly from a Federal Agency When State Agency (Lead Agency), as the Prime Recipient, awards a grant to another State agency, that State agency has received a sub allocation Agency receiving sub-allocation provides their data to the Lead Agency for the 1512 Reporting in accordance with procedures set by the Lead Agency Data for the Lead Agency and other State Agency receiving the sub allocations are combined to complete the Prime Recipient 1512 Reports Data included will be sub-recipient data of each and the vendor data of each Counties and Cities are generally sub-recipients of State Agencies or prime recipients in their own right LEA’s and IHE’s also are sub-recipients of State Agencies as well as prime recipients in their own right Non-profits and non-traditional recipients are generally sub-recipients – HUD is most likely the exception here
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What Does The Prime Recipient Report?
Prime’s sub-recipients
DOES NOT
report Sub-sub-recipients!
Prime’s vendors Sub recipients’ vendors
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1512 Reporting Model
Federal Agency Prime Recipient (Lead Agency) Sub-recipients Vendors Vendors Sub-allocated to state agency (Reports Data to Lead Agency as Part of Prime Recipient) Sub-recipients Vendors Vendors
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What Does OMB Say?
A
sub-recipient
is a non-Federal entity that expends Federal awards received from another entity to carry out a federal program but does not include an individual who is a beneficiary of such a program.
A
vendor
providing goods or services that are required for the conduct of a Federal program. is defined as a dealer, distributor, merchant or other seller Prime recipients or sub-recipients may purchase goods or services needed to carry out the project or program from vendors. Vendors are not awarded funds by the same means as sub-recipients BUT they are subject to the some of the terms and conditions of the Federal financial assistance award.
Examples: Wage Rate Requirements (Davis-Bacon Act, Section 1606) Use of American Iron, Steel, and Manufactured Goods (Section 1605) JOBS Reporting Section 902 Review of contractor, sub-contractors, and associated contracts and transactions Section 1553 Whistleblower Protection Compliance with Anti-Discrimination and Equal Opportunity Statutes OPEN ENDED REQUIREMENT to comply with any other ARRA requirements when notified E-verify (under State statute)
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1512 Reporting Template
Prime Recipient, Sub Recipient, and Vendor Tabs Award Specific – one report per Federal Award Instructions and help built into the templates (Excel and Stimulus360)
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FederalReporting.gov
Registration
If you have new grants or loans: Do not wait until the reporting deadline to register Do not wait until the reporting deadline to get a DUNS number and register in the CCR Process for DUNS/CCR takes upwards of two weeks!
Requirements for Sub Recipients and Vendors?
Make sure they understand the requirements Make sure Vendors and Sub Recipients have a DUNS number and registered in the CCR Set deadlines for sub-recipient and vendor reporting compliance to ensure that you as the prime can reach the reporting deadline and not be late!
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FederalReporting.gov
Validation for Excel Template
Validation Utility available via FederalReporting.gov for use in testing the acceptability of your report
Reject Criteria
►
Any mandatory fields left blank unsuccessful submission) result in rejection of the report (thus an
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FederalReporting.gov
What Triggers 1512 Reporting?
Federal notice of award Reporting required whether or not funds received or expended Receipt/expenditure of funds triggers audit requirements
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FederalReporting.gov
What Happens If Prime Is Late?
The RATB Knows You will end up posted in the failed to report list on Recovery.gov
You may be penalized You may have the grant revoked You may have other federal funds revoked What Happens If Prime Is Incomplete?
Get it filed by the deadline (or reflected as LATE) Follow the procedures on FederalReporting.gov on Continuous Quality Assurance
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Executive Compensation
Five Most Highly Compensated Officers ► ► ► ► This element applies to the recipient and all sub-recipients and state agencies receiving sub-allocated grants, but not vendors In case of uncertainty – report them!
Just because you list these officers in Annual Reports, etc, that does not satisfy the 1512 requirement Conflicting guidance on this requirement has been issued ► ► Follow OMB if at all possible If federal granting agency insists that their rules be followed, document the rules, who gave the directive, etc., in work papers
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Executive Compensation
The names and total compensation of the five most highly compensated officers of the entity must be reported if: ► The entity received 80% or more of its annual gross revenues in the preceding fiscal year from Federal awards,
AND
► ► The entity received $25,000,000 or more in annual gross revenues in the preceding fiscal year from Federal awards,
AND
The public does not have access to this information through the Securities and Exchange Commission as mandated by the Securities and Exchange Act of 1934 OR through Internal Revenue Service filings as mandated by Section 6104 of the Internal Revenue Code. Neither of these regulations apply to state agencies, but they may apply to sub-recipients.
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Executive Compensation
All three tests
must be met before the names and compensation of the five most highly compensated officers must be reported. All sub-recipients of and state agencies receiving sub-allocated grants from the recipient must be tested.
Total Compensation includes more items than salaries and fringe – need to reference appropriate guidance Very few State Agencies or governmental entities are expected to pass all three tests
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Memos and Instructions
Easy Way To Policies and Procedures
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Memos and Instructions
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Memos and Instructions
All Stimulus communications are published under the link of “Find ARRA Policies and Procedures” at www.stimulus.ms.gov
Notification emails issued to State agencies and other known entities regarding new communications New memos added on a regular basis Memos modified as required (and flagged as “Revised”): Sub-allocations vs. sub-recipients (state agency to state agency) due to the definition of the State (ARRA Reporting Guidance v2 and Memo #1) CFDA Recovery Programs (OMB Supplement #1) (Memo #6) Purchasing Law Changes (Memo #9) Updated chart of enhancements to SAAS with anticipated dates (Memo #13) Additional categories of contracts in the Award/Contract Interface and corrections to the chart of points of entry (Memo #17) Stimulus360 Demo and Required Training… (Memo #30)
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Reporting Observations
The State’s View
Most state agencies filed their reports timely with FederalReporting.gov, but some did not.
Most other State of Mississippi governmental entities filed timely with FederalReporting.gov but some were late and others did not file at all.
Greatest area of concern is with filing by non-profits and other non governmental entities.
All State agency recipients provided a copy of their 1512 reports to [email protected]
(some after some prodding) Other Mississippi ARRA recipients – some provided 1512 Report copies but most did not.
Many questions still exist as to who sets the rules that are supposed to trickle down to the States – OMB or awarding agency
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Reporting Observations
The State’s View 33
Reporting Observations
Government Accounting Office (GAO)
What was good (October Reporting)?
Ability of the reporting mechanism to handle the volume of data was a solid first step in moving toward accountability and transparency in using federal funds.
States had quality review processes in place.
OMB, RATB, and federal agencies provided guidance to states, primes, and sub-recipients.
There was a good faith effort to report complete and accurate data.
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Reporting Observations
Government Accounting Office (GAO)
What required immediate improvement (October Reporting)?
Varying interpretations of reporting guidance —some federal agencies issued their own guidance that did not necessarily track with OMB guidance.
Variation in determining the performance period for calculating jobs.
Variation in understanding how to calculate a full-time equivalent jobs number.
Confusion about the definition of a job retained and how to count it.
Confusion about definitions of data elements.
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National Governors Association (NGA)
Task Force
Purpose Created in November 2009 during a meeting of state stimulus representatives in Washington, D.C., to discuss the challenges that states faced during the initial 1512 reporting process. Created two state task force groups to review data models and job calculations as these were top two areas of significant disparity.
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National Governors Association (NGA)
Task Force
Data Model Task Force Objectives Identify data elements that would benefit from being defined at the federal agency level and recommend a standard template for agencies to use.
Identify data elements that need additional guidance for the upcoming reporting period, provide analysis of how states are currently implementing, and make recommendations for standard guidance to increase consistency between states.
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National Governors Association (NGA)
Task Force Recommendations
Create a standard Notice of Award template that includes the following Data Elements: Funding Agency Code Awarding Agency Code Program Source (TAS) Sub Account Number for Program Source (TAS) Award Number Recipient DUNS Number CFDA Number Government Contracting Office Code Award Type Award Date Award Description Project Name or Project/Program Title Activity Code (NAICS or NTEE-NPC) Amount of Award Infrastructure Purpose and Rationale Include indicator to identify if grant should have infrastructure expenditures
What Happened?
M-10-08, issued by OMB on 12/18/2009, requires Federal agencies to provide the fields in red . It should be noted that this has still not consistently happened!
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National Governors Association (NGA)
Task Force Recommendations
Remove Congressional Districts from data model. ACTION TAKEN: A match is done against Congressional District reported and the address/zip on the CCR entry and will reject the Congressional District if the match is not valid.
Remove “invoiced” from ARRA Funds Received/Invoiced fields.
ACTION TAKEN: Clarified in FAQs to M-10-08 Clarify that ARRA Expenditures includes expenditures regardless of whether federal draw-down or reimbursement has taken place.
No specific action taken; however many grants are cost recovery and this is how they are operating (ex: FHWA) Clarify that amount and number of sub-awards, including those less than $25,000/award, should include aggregate values since inception, not “cumulative for the reporting period.” ACTION TAKEN: Clarified in FAQs to M-10-08
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National Governors Association (NGA)
Task Force Recommendations
Confirm that only Prime Recipient vendor payments under the $25,000
National Governors Association
Prime and Sub Recipients vendor payments.
(NGA) Task Force Recommendations
Confirm that the $25,000 amount is a true minimum threshold for purposes of reporting sub recipient vendor information.
The current data model does not provide an opportunity for aggregation of sub recipient vendor data below the $25,000 threshold.
Confirm that the $25,000 threshold is triggered by individual vendor payments over $25,000 and not cumulative payments to a vendor over the life of the award/project. A vendor with detailed transactions above $25,000 can also be represented in aggregation fields under the Prime Recipient tab.
ACTION TAKEN: Several clarifications issued on these items via FAQs for M-10-08.
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National Governors Association (NGA)
Task Force Recommendations
Jobs Calculation Recommendation Count the cumulative number of hours worked on a project or activity as the number of work hours available starting when work began on a project or when the project is scheduled to begin and ending when the project ends.
Numerator should be total number of hours worked – auditable via use of payroll records.
Denominator should be number of work hours available from the time work begins, or a project is scheduled to begin.
Implement any changes AFTER January 10 reporting period. ACTION TAKEN: Changes were effective WITH January 10 reporting period Calculation now includes all jobs paid using recovery act funds whether existing or retained with hours worked adjusted for partial funding based on percent of Recovery Act funding (see M-10-08, Attachment A) Denominator is standard – 520 hours in a reporting quarter for an FTE
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M-10-08 Revised Jobs Reporting
Prime recipients must communicate jobs calculation changes:
State agencies receiving sub-allocations Sub-recipients Vendors Do not include indirect jobs or employees not directly charged to Recovery Act supported projects/activities Jobs reported
must be funded
with Stimulus dollars!
Yes-this very likely means you may have to modify instructions attached to contracts in progress Yes-this means that you will have a different methodology for corrections that have to go back to 2009Q3 than from 2009Q4 forward Yes you can probably expect future “adjustments” to this calculation
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M-10-08 Revised Jobs Reporting
OMB guidance requires estimates to be reported as “full-time” equivalents (FTE) Document all sources of information used in the calculation of jobs created and retained.
W2s Minutes from meetings where job cuts due to lack of funding were discussed Paperwork showing terminations and rehires due to budget issues Documents showing estimated job cuts due to budget cuts Document instructions given to agencies receiving sub-allocations, sub recipients, and vendors regarding jobs calculations.
Jobs calculations MUST be supported and verifiable!
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JOBS
Check your knowledge #1
Your vendor has been conducting training assistance to place individuals in jobs. The vendor added 8 trainers to meet the increased demand. This additional training also resulted in 25 individuals being trained and then placed in positions. During the training, participants received a stipend for their time.
Q:
How many FTEs should your agency note as jobs created from this example?
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JOBS
Check your knowledge #1 A:
Assuming the additional 8 trainers were funded 100% through ARRA monies, they would be included in your calculation. The 25 individuals who were placed in positions are considered indirect jobs as their positions are/were not funded through ARRA dollars, even though they received a stipend. The 25 should not be included in the calculation.
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JOBS
Check your knowledge #2
Your agency is providing ARRA funds to child care vendors. These funds make it possible for individuals to seek and gain employment while their children are in day care. Your vendors have indicated that at least 50 parents have returned to or secured full time employment.
Q:
How many FTEs should your agency note as jobs created?
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JOBS
Check your knowledge #2 A:
Zero jobs created. The individuals gaining employment as a result of day care being provided counts only as an indirect job as their positions are not being funded by ARRA. However, if the daycare provided added staff to meet the increased demand and these FTEs were funded by ARRA, these FTEs can be counted as part of jobs created.
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JOBS
Check your knowledge #3
Your ARRA grant includes two new positions for your agency paid 100% from ARRA funds. Because existing employees are eligible to interview for these positions, you may have a case where you fill the ARRA position with an existing employee, but then have a vacancy in the former position, which you are unable to fill due to a hiring freeze.
Q:
What should your agency note as jobs created?
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JOBS
Check your knowledge #3 A:
If both ARRA positions are filled and are 100% funded by ARRA then 2 is the correct answer regardless of whether the original positions are filled or not (effect of the M-10-08 changes).
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What Is Our Status?
Mississippi – Federal Agency Reported
Source: Recovery.gov 2/15/2010
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What Is Our Status?
Mississippi – Federal Agency Source of Funds
Source: Recovery.gov 2/15/2010
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What Is Our Status?
Mississippi – Recipient Reported
Source: Recovery.gov 2/15/2010 Mississippi Congressional Districts 110 th Congress
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What Is Our Status? Mississippi – Recipient Reported
Source: Recovery.gov 2/15/2010
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Quality Assurance Plan
Mississippi is a ‘De-Centralized State’ for ARRA 1512 Reporting.
Heads of prime recipient entities are responsible for compliance with ARRA policies and procedures and Section 1512 reporting.
DFA, on behalf of the Governor, developed Mississippi’s Quality Assurance Plan for State Agencies – good model for all Mississippi entities receiving funds in Mississippi – includes instructions and checklists for both preparers and reviewers Office of State Auditor who has monitoring oversight over federal fund recipients not in State level government and has audit responsibilities for all federal funds received in Mississippi (including investigative powers) has similar questionnaires posted on the OSA website
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stakeholders identified in the Recovery Act. Prime recipients, as owners of the data submitted, have the principal responsibility for the quality of the information submitted.” Source: Implementing Guidance for Reports on Use of Funds
Pursuant to the American Recovery and Reinvestment Act of 2009, OMB, June 22, 2009
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Mississippi’s 1512 Quality Assurance Plan: Decentralized Reporting
DFA QA TEAM AGENCY EXECUTIVE DIRECTOR AGENCY COMPLIANCE DESIGNEE AGENCY REVIEWER
This process works regardless of whether a State agency, County, Municipality, School District, IHE, Non-profit
AGENCY PREPARER Drives testing and decisions at an Agency level with oversight from DFA 1512 Team 56
Quality Assurance – COSO
Control Environment –
The control environment sets the tone of an organization, influencing the control consciousness of its people
Risk Assessment –
Every entity faces a variety of risks from external and internal sources that must be assessed both at the entity and the activity level
Control Activities –
These policies and procedures help ensure management directives are carried out
Information and Communication –
Pertinent information must be identified, captured and communicated in a form and time frame that supports all other control components
Monitoring –
Internal control systems need to be monitored – a process that assesses the quality of the system’s performance over time
Internal Control - Integrated Framework, COSO 57
Leveraging Activities to Help Ensure Maximum Coverage without Redundancy
Who Preparer Reviewer Activity Compiles information from: programs, SAAS, subrecipients, suballocants and vendors & completes supporting schedules Prepares reporting template Maintains sufficient documentation for review/ verification Completes preparer’s checklist Re-performs and verifies data elements against supporting docs Completes reviewer’s checklist Documents issues and exceptions Control Components Control Activities Information and Communication Control Activities
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Leveraging Activities to Help Ensure Maximum Coverage without Redundancy
Who Compliance Designee Internal Audit * Activity Assumes responsibility for compliance with all ARRA rules & regulations (i.e., reporting, monitoring and oversight of program compliance) Reviews the check-list prepared by reviewer Oversees corrective action Performs risk based reviews Leverages checklist Ties to source on a sample basis Reports on control and compliance weaknesses Control Environment Information and Communication Control Components Risk Assessment Monitoring
* Internal Audit cannot design or perform specific control activities. Internal Audit’s role is to monitor the overall effectiveness of the controls established and executed by management.
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Leveraging Activities to Help Ensure Maximum Coverage without Redundancy
Who Executive Director External QA Team (DFA for agencies; OSA for others; Some external auditors for certain entities) Activity Ultimately responsible for all agency activity and compliance.
Establishes procedures for recording & tracking ARRA funds Disseminates information, guidance & rules to agencies Reviews compliance with 1512 reporting requirements Emphasizes agency internal controls Monitors agency ARRA compliance Assists GAO in its review & reporting Control Components Control Environment Information and Communication Risk Assessment Control Activities Monitoring Information & Communication Control Environment
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Waste, Fraud and Abuse
Source: Recovery.gov 2/16/2010
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Waste, Fraud and Abuse
See Recovery.gov for the complete list of disclosure protections.
Source: Recovery.gov 2/16/2010
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ARRA Administrative Costs
OMB is allowing states to recover ARRA administrative costs through a supplemental SWCAP for: Data collection (Stimulus 360) Monitoring (DFA’s ARRA monitoring) Investigations of waste, fraud, and abuse (Auditor’s Office) DFA is in the process of preparing the plan and is proposing to use Section II Billed Services to recover ARRA administrative costs.
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Stimulus360 Mississippi’s Reporting Solution Overview
1512 Aggregation Report • The Prime Recipient updates system with Sub Recipient inputs and reviews aggregate totals from all projects for a specified award during a given time period Add 1512 Update Report • The Prime Recipient creates/updates 1512 reports for each award Run 512 Validation Helper Report • The Prime Recipient validates 1512 reports.
Generate Federal Reporting • The Prime Recipient submits excel or XML files on
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Stimulus360 Solution Overview
The following process is used to generate quarterly 1512 reports. The first 6 steps will be automatically “completed” using 1512 reports submitted as of February 1, 2010.
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Stimulus360 Sample Award Screen
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Stimulus360 Sample Project Screen
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Stimulus360 1512 Aggregation
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Stimulus360 1512 Validation
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Stimulus360 1512 XML Submittal
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Stimulus360 Transparency
The Stimulus360 solution will be used to provide transparency reporting for ARRA expenditures.
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Stimulus360 Transparency
The Stimulus360 solution will be used to provide transparency reporting for ARRA expenditures.
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Gearing Up – April 10 Reporting
NGA Recovery Act Coordinators meet in Washington March 4-5 General Topics to be Addressed NGA Sponsored Best Practices On-going issues Administration Sponsored Minority hiring Federal agency meetings to discuss program and policy issues and reporting Topics Proposed: Additional reporting burdens being imposed by some federal agencies (Energy) Davis-Bacon requirement clarifications when a non traditional entity receives funding and then subs it out to a vendor (ex: manufacturer and energy grants) Issues where federal agencies are not complying with notification requirements Issues where federal agencies cannot tell you a status of reporting before the period closes HUD – what is the accountability structure Impact of FederalReporting.gov changes on State level reporting Impact of federal agency specific reporting on State level reporting (FHWA)
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Gearing Up April 10
Reporting (Projected)
Deadlines
April 1-10 – Reports submitted April 11-20 – Primes complete quality reviews.
April 21-29 – Federal Agencies complete quality reviews.
April 30 – Reports for Grants/Loans pushed to Recovery.gov.
What We Know
Even if there is an “extension” like in January, the report is flagged as “late” if initially submitted after the 10 th As the quarters progress, more and more attention is given to non recipients and late recipients as a significant compliance issue Also, more and more attention is being given to appropriate contracting methods with particular emphasis on open competition
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Assistance
Email questions or comments to: [email protected]
MMRS Call Center available 5 days/week from 8:00 AM – 4:30 PM at 601-359 1343 or via email at [email protected]
OMB Recovery Act Guidance: http://www.whitehouse.gov/omb/recovery_default/ OMB Recovery Act FAQs: http://www.whitehouse.gov/omb/recovery_faqs/ Recovery.gov
http://www.recovery.gov
FederalReporting.gov – Data Model, Templates, User Guide: https://www.federalreporting.gov/federalreporting/downloads.do#rrdm FederalReporting.gov FAQs https://www.federalreporting.gov/federalreporting/topTenFaqs.do
Mississippi Department of Education – FAQs http://www.mde.k12.ms.us/Stimulus/faq.html
MERLIN – Stimulus and 1512 Reporting Recaps https://merlin.state.ms.us/merlin/merlin.nsf/Navigation?OpenForm&Home
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76 Q&A 76
American Recovery and Reinvestment Act An Update
Cille Litchfield DFA-Deputy Executive Director Department of Finance and Administration 601-359-1433 [email protected]
MAGPPA Wednesday, February 17, 2010 JCJC Advanced Technology Center
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