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American Recovery and Reinvestment Act (ARRA)American Recovery and Reinvestment Act (ARRA)

Reporting RequirementsReporting Requirements

Presented by:

Darryl GrantDarryl GrantProcurement Analyst

Division of Acquisition Policy & Evaluation

October 13, 2009

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Unique Reporting Unique Reporting RequirementsRequirements

* FAR Subpart 4.1500 implements Section 1512(c) of the Recovery Act

* Specific reporting requirements in FAR 52.204-11 include, but not limited to-

1. The dollar amount of contractor invoices2. The supplies delivered and services performed3. An assessment of the completion status of the work4. An estimate of the # of jobs created and retained5. Names and total compensation of each of the five most highly

compensated officers for the calendar year in which the contract is awarded; and

6. Specific information on first-tier subcontractors

* First reporting period is Oct. 1 – Oct. 10, 2009- Contractors should include data from date of award through

Sept. 30, 2009

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Frequently Asked Frequently Asked Questions (FAQ’s)Questions (FAQ’s)

* Reporting requirements only apply to ARRA funded contract actions

* Contractors primarily responsible for the accuracy of the report

* Information in reports will be used for a variety of purposes including compliance with award conditions, detection of waste, fraud and abuse and mgt. oversight

* 1st point of contract for reporting problems should be the ARRA Reporting Service Desk

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Who must register?Who must register?

* Contractors receiving ARRA funded awards

* Federal Agency Users obligating ARRA funds

* Advance Registration recommended

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Registering in Registering in FederalReporting.govFederalReporting.gov

* Registering as a Federal Agency User– Select “Register Now”– Enter Federal Agency email address

• Your email address will serve as your User ID– Select Department of Health & Human Services

on drop down menu– Registration confirmed via email (temporary

password provided)– Log in with User ID and Create New Password

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Contractor Reporting Contractor Reporting RequirementsRequirements

* Days 1-10• Contractors submit reports• Report must be entered as an Initial

Submission• After Day 10, justification (online) required

for lateness (should be rare)• Justification can be viewed by public• No new initial reports accepted after Day 21

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Contractor Reporting Contractor Reporting RequirementsRequirements

• Days 11-21• Contractors may make corrections• Upon completion of Day 21, reports locked and

transmitted to Final Submission Status Phase

• Days 22-29• Contractor may make corrections if CO submits

comments

• Day 30• System posts all reports as final

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Data Quality Review by Data Quality Review by CO CO

* Days 11-21• Validate contractor submits report by deadline

(Oct. 10, 2009)• May review reports for “significant errors and

material omissions”• Notify contractor offline of any significant errors

and/or material omissions identified• Document in the contract file

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Data Quality Review by Data Quality Review by COCO

* Days 22-26• Conduct formal review of Contractor reports

• Validate submission• Review for significant errors and material omissions

• Document review on Checklist for Contractor Reports • Approval of comments at one level above CO required

prior to submitting comment in www.federalreporting.gov

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Significant Errors and Significant Errors and Material OmissionsMaterial Omissions

* Significant error - data not reported accurately and where such erroneous reporting results in significant risk that the public will be misled or confused by the contractor’s report. Examples include:

– Cumulative invoiced amount reported is in excess of the obligation; – Contractor incorrectly selects fully complete, to describe an incomplete

project; or; – Contract award/obligation amount was for a relatively small dollar amount,

such as $100,000, and the contractor reports the number of jobs created and retained cumulatively as 100,000.

* Material omission is defined as data that is not responsive to a specific data element. For instance, where the contractor is required to provide a narrative description, it must be sufficiently clear to facilitate understanding by the general public.

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ARRA OversightARRA Oversight

* Guidance on Completing IC Review of Contractor Reports Summary Sheet

– Spreadsheet to be pre-populated by OALM with the ARRA Contract Number/Order Number, Contractor Name, Requirement Title and Buyer/CO for all contracts and orders funded in whole or in part with ARRAR funds

– Pre-populated spreadsheet emailed to OA Directors with copies to respective IC Points-of-Contract and IC Executive Officers within three (3) business days after the close of each quarterly reporting process

• Responsible for working together to complete spreadsheet• Summarize any significant errors or material omissions with their

respective contract/order on the spreadsheet – Respective IC Executive Officer or his/her designee and OA Directors

shall certify that reviews of reports have been conducted   – Complete, certified spreadsheet to be returned to OALM within ten (10)

days of the request for information. 

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Subsequent ReportsSubsequent Reports

* Reports due no later than the 10th day after the end of each calendar quarter – Jan. 10, 2010– April 10, 2010– July 10, 2010– Oct. 10, 2010

* Subsequent reporting periods will report cumulative data

* All awards issued after Sept. 30, 2009 will be reported during the next reporting period (Jan. 1. 2010 – Jan. 10, 2010)

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Useful LinksUseful Links

User Guide

https://www.federalreporting.gov/federalreporting/downloads.do#docs

FAQs for Contractors on Reporting

http://www.whitehouse.gov/omb/recovery_faqs_contractors/

FAQs Agency Review of Contractor Reports

http://www.whitehouse.gov/omb/recovery_faqs_agency_review/

General FAQs

http://www.whitehouse.gov/omb/recovery_faqs/

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Questions?Questions?