Understanding ARRA Reporting Requirements at Yale: A Comprehensive Overview

1. American Recovery & Reinvestment Act of 2009 (ARRA): Overview of OMB Guidance and Strategyin the Implementation of Reporting Requirements Brown Bag Luncheon Series September 3, 2009

2. ARRA – Introduction of Panel American Recovery and Reinvestment Act of 2009 (ARRA): Overview of OMB Guidance and Strategy in the Implementation of Reporting Requirements

3. ARRA - Introduction What will you take away from today’s presentation? ARRA timeline and Yale ARRA statistics. A general understanding of the new ARRA reporting requirements. What will be the Principal Investigator’s and Departments role with ARRA Reporting. Interchangeable terms used for the American Recovery and Reinvestment Act of 2009 throughout today’s presentation: ARRA Recovery Act Stimulus Funds Section 1512

4. The ARRA Timeline and Highlights

5. ARRA Timeline

6. ARRA Highlights: Where does Yale stand? • 826 ARRA Proposals for ~$557M in funding submitted by Yale • Conversions: Proposals that originally did not respond to ARRA-related funding opportunities that were converted to proposals to be funded by ARRA, per sponsor request. • New: Funding opportunities only available through ARRA support. • Data current as of 8/28/2009

7. ARRA Highlights: Where does Yale stand? • 101 NIH (FY09 = ~$19M) • 31 NSF (FY09 = ~$11M) • 4 Other (FY09 = ~$241K) • 136 ARRA Awards at Yale • (FY091 = ~$30M) Top 10 Awardees for NIH2 • FY09 award figures from NIH (http://projectreporter.nih.gov/files/ARRA-projects.xls) ; FY09 award figures from NSF and Other are based on total awarded amount as these agencies obligate their funds up front. • 2. Data Source: http://projectreporter.nih.gov/files/ARRA-projects.xls • Data current as of 8/31/2009

8. ARRA Highlights: Where Does Yale Stand? ARRA Notices of Award: Terms and Conditions Please be sure to identify and read the terms and conditions of your ARRA Notice of Award. For example, Yale investigators have seen NIH combine an equipment grant with an administrative supplement into one award. Notice of Awards may include additional reporting requirements for ARRA that are over and beyond the reporting requirements discussed today. Additional award changes may include budget reductions, etc.

9. ARRA Highlights Effective Practices upon receipt of ARRA Awards: Be sure to read all Notice of Awards. Be sure to discuss with GCA when you become aware of any unusual requirements. Extensions of time may be required for the Prime Award in order to match the project period of the new ARRA Supplement. Work with the Principal Investigator upfront to ensure labor schedules and cost allocation methodologies are planned in advance. Due to the associated high risk assigned by OMB and OIG to Stimulus awards, the Federal government is expected to be more aggressive with both program and financial audits, as well as with expenditure reviews.

10. ARRA Reporting Requirements

11. Overview of ARRA Reporting Requirements OMB Memorandum M-09-21, Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009*, dated June 21, 2009: Answers questions and clarifies issues related to the mechanics and chronology of recipient reporting required by ARRA; Provides clarification on what information will be required to be reported into the central reporting solution at www.FederalReporting.gov and what information will be reported on www.Recovery.gov; Instructs recipients on steps that must be taken to meet these reporting requirements, including the incorporation of subrecipient reporting requirements under Section 1512(c)(4) of the Act; and Establishes a common framework for Federal agencies and recipients to manage a data quality process associated with ARRA recipient reporting requirements. * Memo M-09-21 can be found at the following link: http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf) ** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09

12. Overview of ARRA Reporting Requirements What reporting is required under Section 1512? A list of projects and activities funded by award to include: Description Project status as a percentage of completion Estimates on jobs created or retained (Prime, Subawards and Vendors) ; Description of positions Reporting of cumulative percentage for both prime, subawards, and vendors Total amount of funds received; and of that, the amount spent on projects and activities; Aggregate reporting required in three classifications: Subawards to institutions Subawards to individuals Cumulative expenses of all other categories of expense Details on sub-awards and other payments Separate reporting of vendors greater than 25K Number of Subawards and amounts paid

13. Overview of ARRA Reporting Requirements Prime Recipient Basic Requirements: Federal Funding Agency Name Award identification Recipient DUNS Parent DUNS Recipient CCR information CFDA number, if applicable Recipient account number Project/grant period Award type, date, description, and amount Amount of Federal Recovery Act funds expended to projects/activities Activity code and description Project description and status Job creation narrative and number Infrastructure expenditures and rationale, if applicable Recipient primary place of performance Recipient area of benefit Recipient officer names and compensation (Top 5); when applicable Total number and amount of small subawards, which are less than $25,000 Federal Agency NIH/NSF Yale University (Prime Recipient) Vendor A University A (Sub-recipient) Vendor B ** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09

14. Overview of ARRA Reporting Requirements Sub-Recipient Basic Requirements (also referred to as FFATA Data Elements): Subrecipient DUNS Subrecipient CCR information Subrecipient Type Amount received by subrecipient Amount awarded to subrecipient Subaward date Subaward period Subrecipient place of performance Subrecipient area of benefit Subrecipient officer names and compensation (Top 5); when applicable *Prime recipient reports unless delegated to subrecipient Federal Agency NIH/NSF Yale University (Prime Recipient) Vendor A University A (Sub-recipient) Vendor B ** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09

15. Overview of ARRA Reporting Requirements Recipient Vendor Basic Requirements DUNS or Name and zip code of Headquarters (HQ) Expenditure Amount Expenditure Description Sub-Recipient Vendor Basic Requirements DUNS or Name and zip code of Headquarters (HQ) *Prime recipient reports unless delegated to subrecipient Federal Agency NIH/NSF Yale University (Prime Recipient) Vendor A University A (Sub-recipient) Vendor B ** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09

16. Overview of ARRA Reporting Requirements When do ARRA Reporting Requirements begin? The first scheduled reports are due October 10. Reporting will be cumulative from inception. How will recipients report ARRA funds? Reports will be submitted viawww.FederalReporting.gov. Will we be expected to report all Federal awards including Non-ARRA funds this way going forward? No, these new reporting requirements are exclusively for section 1512 reporting, ARRA Awards.

17. Overview of ARRA Reporting Requirements Human Resources Assistance Contact your HR Generalist or departmental HR Manager as soon as you are notified of an award to make them aware of potential staffing needs. HR can assist you in developing your position description, defining position requirements and getting your position appropriately classified for posting and reporting purposes. The Staffing Dept. will review your position requirements and match to the skill sets of Yale employees currently in layoff status. If your position requires skills not currently available in house then it will be posted on the external website. - In anticipation of research staffing needs as a result of ARRA Awards, the Staffing department has pre-screened candidates in our STARS database . - Postings can be waived in cases where you are interested in hiring a qualified layoff candidate. - If you have an immediate need for a Research Assistant and a qualified IEP staff member is available, they may be provided to you at no cost during the posting process. - You may elect a 90 day trial period for hires from layoff which will be paid for by Human Resources-your HR Generalist and/or Recruiter can assist you.

18. Overview of ARRA Reporting Requirements Purchasing Assistance To help Purchasing recognize purchases greater than 25k that are being charged to stimulus funds, indicate ‘Stimulus Funds’ in the requisition’s Notes section. For SciQuest orders, this would be entered as an Internal Note under the Yale Internal Info tab. For purchase orders over $25K, Purchasing is developing a form to collect required data from the vendor, including DUNS Number and Positions Created or Retained. They will collect the data from the vendor. Purchasing will run ongoing queries to identify purchases/payments that require ARRA reporting data and collect the data from the vendor regardless of whether the purchase originated from a purchase order (e.g., SubAward payments). Fran Consiglio will serve as a lead within Purchasing for Stimulus Fund needs, assisting other Buyers and their assistants as needed. However, please work with the commodity’s primary buyer for your purchase.

19. ARRA Accountability and Reporting

20. ARRA Accountability and Reporting Federal Oversight Requirements: Agency Oversight Agencies must take steps, beyond standard practice, to initiate additional oversight mechanisms in order to mitigate the unique implementation risks of ARRA. Inspector General OIG offices are receiving supplemental funding for ARRA oversight. Audits OMB Circulars, specific agency’s policies and procedures, as well as special Terms and Conditions associated with each award applies to ARRA funding.

21. ARRA Accountability and Reporting Institutional Requirements: ARRA awards must be tracked separately in order to meet the additional reporting requirements. Quarterly Accountability Reports Cumulative reporting of data. Submitted by the 10th day following the calendar quarter end. Current methodology will be to use the data from the most recent month-end close. For quarter ending September 30, quarterly reports will provide data from August month-end close. Higher Risk associated with ARRA funding May require Yale to establish lower thresholds for cost transfer reviews and GCFA approvals.

22. ARRA Accountability and Reporting Institutional Accountability and Reporting: GCA’s Role: Review and verify special terms and conditions, as well as additional reporting requirements within Notice of Awards from Federal agencies and subaward documents where Yale is a subrecipient of ARRA funds. Provide templates of reporting requirements to subaward recipients where Yale is the prime. Verify compliance checks. Establish awards in OGM. GCFA’s Role: Develop and implement a process and system to meet ARRA reporting requirements. Verify accuracy of data reported within the various systems. Work with departments to ensure completeness of data. Certify and submit reports via the Federalreporting.gov website within the established deadline dates.

23. ARRA Accountability and Reporting Institutional Accountability and Reporting: ARRA Award Setup and Tracking Second digit in Award PTAEO replaced with an “S” to signify Stimulus. Short title starts with STIM: Attribute setup to record Y or N for Stimulus funds. Accountholder report showing the Stimulus attribute. Yale as a subrecipient of Federal Stimulus Awards (flow-through) flex field(s) will be created to identify whether Yale via GCFA is required to report directly to the FederalReporting.Gov website or to the Prime.

24. ARRA Accountability and Reporting Account Holder Report: The words Stimulus Award will appear on each page of the Account Holder Report by Person and the Account Holder Report by PTAO in the header section.

25. ARRA Accountability and Reporting Departmental Accountability and Reporting: Award Receipt Review NOA Terms and Conditions. Contact and discuss with your GCA team member if there are any unusual terms or funding anomalies, which may require special attention. Reporting Review award budget, identify personnel, verify charging and charging instructions upfront, and develop an allocation methodology with the Principal Investigator prior to charges posting to the award. Plan ahead; make sure labor schedules and cost allocation methodologies are planned and implemented in advance. Minimize cost transfers to ARRA Awards; Due to the high risk nature of these awards if a transfer is required, make sure the transfer is well documented.

26. ARRA Accountability and Reporting Departmental Accountability and Reporting: Reporting (Continued) Confirm all ARRA awards appear on your list of reports to review. Review quarterly report information for accuracy. Once reviewed, work with the Principal Investigator to verify any edits or changes required in the pre-populated reporting data. Submit quarterly reports to GCFA within the designated time request (anticipated to be 5 to 10 business days from initial release to department).

27. ARRA Reporting Solution

28. ARRA Reporting Solution Other’s Approach to ARRA Reporting Several institutions are requesting departments and principal investigators to fill-in the blank excel forms for ARRA reporting. Yale’s Approach to ARRA Reporting Minimize the time required by the principal investigator and departmental administrator in completing quarterly ARRA reports. Develop a system and process to accumulate as much information available from Yale’s systems to pre-populate the quarterly report form. At present, it is expected that all required information can be pre-populated into the quarterly reporting form, which will only require the department (PI, and business administrator) to verify reports and check for accuracy. SLIDE 27

29. ARRA Reporting Solution Solution is being developed in the Oracle Environment Utilizing the e-business suite tools. Developing own set of tables for data extraction, translation, and population. User interface will be developed with a workflow picklist and will enable data entry and corrections in the Oracle Forms environment. Access to data and security of forms will be provided at the departmental level. Reporting Current expectation is that all data will be pre-populated within the form for department or PI review and verification. Once submitted, the form will appear in the GCFA worklist for final review, verification and approval for uploading onto the federalreporting.gov website. SLIDE 28

30. ARRA Reporting Solution

31. ARRA Reporting Solution • Departmental Worklist Screen shot • Position your cursor on the Award Number and click on the “Open Award” button to open an Award SLIDE 30

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38. ARRA Reporting Solution SLIDE 37

39. Today’s Brown Bag Presentation will be available at: http://www.yale.edu/researchadministration/BrownBagPresentations.html Centralized site for OMB Guidance Documents http://www.recovery.gov/?q=content/recipient-reporting ARRA – Additional Information

40. Questions and Answers