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ARRA and FFATA Provisions. CCIT Meeting February 16, 2011. ARRA Provisions. Supplemental ARRA Provisions dated 8-21-09 Required for all contracts, grants, purchase orders funded with ARRA going back to 2-17-09, when ARRA was signed
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ARRA and FFATA Provisions CCIT Meeting February 16, 2011
ARRA Provisions • Supplemental ARRA Provisions dated 8-21-09 • Required for all contracts, grants, purchase orders funded with ARRA going back to 2-17-09, when ARRA was signed • Guidance for Adding Supplemental ARRA Provisions on OSC website: http://www.colorado.gov/dpa/dfp/sco/contracts/ARRA/ARRA_Main_Page.htm
ARRA Provisions • Guidance for adding ARRA Provisions • Attach Supplemental ARRA Provisions to contract, grant or PO as an exhibit • List Supplemental ARRA Provisions first in order of precedence clause
FFATA • FFATA Provisions dated 10-15-10 • Reporting beginning 10-31-10 for all contracts, grants, purchase orders entered into during the previous month using Federal funding that is NOT ARRA • Guidance on FFATA Provisions • Attach Supplemental FFATA Provisions to contract, grant, or PO as an exhibit • List Supplemental FFATA Provisions first in order of precedence clause
What if you have both? • Attach both ARRA and FFATA provisions to contract, grant, purchase order • Order of Precedence: • ARRA • FFATA • Other Federal provisions • Special Provisions • Other provisions • FUNDS MUST BE SEGREGATED FOR REPORTING! • ARRA • FFATA
OSC Approach • Include a summary of all the provisions of ARRA and FFATA in the Supplemental Provisions • Focus on reporting and contracting entity’s requirements • Reporting • Central reporting for AARA • Decentralized (each agency) for FFATA
When is ARRA Over? • Recovery Board is statutorily terminated 9-13-13 • If not extended, will have 9 more reporting periods: • 3 in 2011 CY • 4 in 2012 CY • 2 in 2013 CY
But it’s not over ‘til it’s over… • Recovery Board chairman wants deeper reporting http://www.govexec.com/story_page.cfm?articleid=47067&dcn=todaysnews • Chairman wants reporting expanded to cover subsequent layers of subrecipients
Depth of Reporting - NOW ARRA FFATA Subrecipient Recipient Vendor Subrecipient Subrecipient Vendor
Depth of Reporting - Proposed ARRA Subrecipient Recipient Vendor Subrecipient Vendor Subrecipient Subrecipient Vendor Subrecipient And so forth…
Stay Tuned on ARRA…. • OSC will let agencies know if OMB revises its guidance on ARRA reporting
When is FFATA over? • No termination date