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Understand ARRA requirements, reporting guidelines, and compliance. Ensure federal funds usage and transparency. Stay current with updates and resources for successful reporting. |
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ARRA Reporting Training LSU Health Sciences Center at New Orleans September 29, 2009
American Recovery and Reinvestment Act of 2009 Signed February 17, 2009 Provided $787 Billion in spending and tax relief Intended to Stabilize State Budgets Provided Additional Funds for Research
ARRA Procurement Requirements Section 1605 of the Recovery Act prohibits use of recovery funds for a project for the construction, alteration, maintenance, or repair of a public building or public work unless all of the iron, steel, and manufactured goods (“materials”) used in the project are produced in the United States. Section 1606 of the Recovery Act requires the payment of Davis-Bacon Act U.S.C. 31) wage rates to ‘‘laborers and mechanics employed by contractors and subcontractors on projects funded directly by or assisted in whole or in part by and through the Federal Government’’ pursuant to the Recovery Act. If you think either of these situations might apply, you should contact Purchasing to ensure that these transactions are compliant with these rules.
ARRA Section 1512 ARRA Section 1512 outlines the reporting requirements associated with ARRA Funds Focus on Transparency and Jobs Creations/Retention General Comments about Section 1512 There are no experts Guidance is coming out daily There are many unanswered questions We need to work together to identify issues and seek out answers
Section 1512 Guidance The Office of Management and Budget has issued Guidelines NIH has issued guidelines Counsel on Governmental Relations (COGR) has issued answers to Frequently Asked Questions (FAQ’s) Association of Research Universities including LSUHSC-NO Involved in all aspects of federally funded research Provides advice and information to its membership Helps OMB to develop Federal policies and practices Additional guidance can be found on the SPO website
LSUHSC-NO Reporting Plan SPO will send PI and the business manager a Report Due Reminder on the 5th of the last month of each quarter 1512 templates provided on the Sponsored Project Office (SPO) website PI or their designee will complete select data elements in the reporting templates by the 1st of the month following the reporting quarter PI or designee will provide SPO with Vendor data by the 1st of the month following each reporting quarter SPO will review the data, update the reporting templates for the final general ledger information and will submit the templates to FederalReporting.gov on the 10th of the first month of each quarter.
SPO Website http://www.lsuhsc.edu/no/administration/accounting/Sponsored%20Projects/SPAdefault.aspx ARRA 1512 Report Template link Leads to a list of departments that leads to a list of awards Each Template is prepopulated Each Template provides instructions Basic, Prime Element, Sub Element Prime and Sub Element instructions are from NIH and OMB
Department Data Elements – Prime Tab Final Report – Y or N Total # of Sub Awards to Individuals Total Amount of Sub-awards to individuals Total # of Sub Awards Less than $25,000 Total Number of Sub-awards less than $25,000/award Award Description Project Status Number of Jobs
Department Data Elements – Prime Tab (Continued) Description of Jobs Created/Retained Quarterly Activities/ Project Description Activity Code Infrastructure Contact Name, Contact Information and Address if applicable Infrastructure Purpose and Rationale if applicable Primary Place of Performance
Department Data Elements – Sub-recipient Tab 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. Complete if sub-award is greater than $25,000. Reporting requirements should be included in the sub-contract with the sub-awardee.
Department Data Elements – Sub-recipient Tab (Continued) Elements to be completed are: Sub Recipient DUNS Number Sub Award Number Sub Recipient Congressional District Amount of Sub Award Total Sub Award Funds Disbursed Sub Award Date Sub Award Place of Performance
Department Data Elements – Sub-recipient Tab (Continued) Complete the 5 most highly compensated employees for Sub Recipient if in the recipient’s preceding fiscal year, the recipient received— (A) 80 percent or more of its annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements; AND (B) $25,000,000 or more in annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements; AND (C) The public does not have access to information about the compensation of the senior executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.
Department Data Elements – Vendor Tab A vendor is defined as a dealer, distributor, merchant or other seller providing goods or services that are required for the conduct of a Federal program. The characteristics of a vendor that make it distinct from a sub- recipient are: Provides the goods and services within normal business operations; Provides similar goods or services to many different purchasers; Operates in a competitive environment; Provides goods or services that are ancillary to the operation of the Federal program; and Is not subject to compliance requirements of the Federal program.
Department Data Elements – Vendor Tab (Continued) Email SPO with the Vendor information from Sub-recipient that is less than $25,000. Data Elements to be submitted to SPO. • Number of Vendors less than $25,000 • Aggregate amount of Vendors less than $25,000
Department Data Elements – Vendor Tab (Continued) Email SPO with the Vendor data elements if a payment of greater than $25,000 to a vendor by either the prime recipient or a sub-recipient is made. Payments should not be artificial divided to fall below this threshold. Data Elements to be submitted to SPO: Sub-recipient that the Vendor belongs to if applicable Vendor DUNS Number Vendor Name Vendor Headquarter Zip code + 4 Product and Service Description Payment Amount
Estimating the Number of Jobs Created/Retained ARRA Section 1512 requires that an estimate of the number of jobs created and jobs retained in the United States and outlying areas be reported. This estimate shall include any new positions created and any existing filled positions that were retained to support or carry out Recovery Act projects. For grants and loans, the number shall include the number of jobs created and retained by sub recipients and vendors. The number shall be expressed as ‘‘full-time equivalent’’ (FTE), calculated cumulatively as all hours worked divided by the total number of hours in a full-time schedule, as defined by the recipient or federal contractor.
Estimating the Number of Jobs Created/Retained (Continued) NIH Guidance – Percentage of effort can be used to measure FTEs instead of hours. An alternative calculation based on the allocable and allowable portion of activities expressed as a percentage of the total is acceptable for recipients of assistance agreements that must comply with OMB Circular A-21, Cost Principles for Educational Institutions. For example, a full-time faculty member charging 50% effort on an ARRA award will be counted as .5 FTE. Hourly and part-time employees shall be calculated based on actual hours worked on the sponsored agreement and the institution’s definition of a full workload for employment.
Estimating the Number of Jobs Created/Retained (Continued) Vendor Jobs should not include “material suppliers.” Jobs related to “material suppliers” are not considered direct jobs created or retained. The example given by OMB is that a seller of equipment such as a microscope would be considered a vendor but a seller of supplies such as microscope lens would be considered a “material supplier.”
First Reporting Cycle October 10th, 2009 is the first reporting period. Templates must be completed and sent to SPO no later than October 5th. Please save a copy.