In Triplicate: How to implement the Recovery Act, version 2.0

recovery_gov_symbolLate Friday night, the Office of Management and Budget made good on a promise to release an amended or updated version of its guidance (pdf.) in implementing the American Recovery and Reinvestment Act (ARRA) of 2009. There were a number of significant updates to the OMB’s guidance, first issued on February 18 (pdf.) of this year. Generally, the OMB update’s theme centers around data: how it needs to be collected, where it needs to be sent and when it needs to be reported. Section 1512 of the Recovery Act plays heavily in most sections of the update. Some of the highlights include a cancelled monthly financial reporting requirement, more details on how states need to package their information and a new government domain that will serve as a central data hub for reporting.

The canceled monthly financial reporting requirement will force agencies to continue weekly reports in order to keep records up-to-date. “Given the continued demand for timely reporting, the monthly financial report is eliminated and agencies are required to provide regularly updated Weekly Financial and Activity Reports.” The reports will be due every Tuesday.

The date for quarterly recipient reporting also changed to October 10, 2009. Originally, the hope was that a system would be in place by June 10, but now each recipient, i.e. state or municipal entity, must report on their use of federal funds, as well as any contracts and sub-contracts they make. “This level of reporting, as required by the Recovery Act, will provide unprecedented transparency into how and where Federal funds are spent.” In some instances, federal funds will go to a state and then to a local government or local organization, but the current reporting model will not track funds to subsequent recipients beyond these local governments. However, OMB plans to expand the reporting model to also obtain lower-level information once the system capabilities and process have been established.

These data elements were expanded and given more structure in the new update. Elements of the Agency-wide and Program-specific Recovery Plans were finalized and changes were made to the Federal Registry. The table in Appendix 3 of the document, outlines those data elements, which will be of much discussion in the coming weeks and months among local officials. Part of the data element finalization was the creation of a central collection platform. will serve as the gateway for recipients of federal funds to meet the reporting requirements of sec. 1512 of ARRA. The Web site is currently under construction, but it will be a one-stop-shop for states to report their use of stimulus funds. States were encouraged to appoint a single office or point of contact as the Stimulus Accountable Office(r) (SAO). Several states have appointed officials to serve this function, but over the weekend, California was the first state to appoint an inspector general to oversee the estimated $50 billion in federal stimulus money to be disbursed to cities and organizations in the state.

A renewed emphasis on Agency use of other .gov Web sites, like,, and was urged in the new document. Agencies will be submitting information on funds that have been publicly announced through a new process called, Funding Notification Reports (FNRs). Last, but certainly not least, was a reporting requirement intended to help the government justify the $787 billion Recovery Act.

Stimulus projects are about upgrading infrastructure, improving health care, and developing new technologies. But the government is looking for a more tangible ROI: Jobs. The updated guidance also requires an expanded effort to report on jobs created or retained by stimulus projects. State level job creation must be submitted for each project or activity funded through Recovery funds, including a description of the job types created by each project. Job estimates cumulatively created or retained for each quarter, as well as the jobs impacted by sub-recipients also should be reported.

The OMB is looking for public feedback, from government officials to everyday citizens. When they issue their next wave of updates, CivSource will be there to shed some insight.

In Triplicate is a new segment devoted to regulatory issues of consequence to state and local leaders, especially those in budget and finance. See the Editor’s note on In Triplicate.

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