American Recovery and Reinvestment Act (ARRA) Reporting Requirements

1. American Recovery and Reinvestment Act (ARRA)Reporting Requirements Presented by: Darryl Grant Procurement Analyst Division of Acquisition Policy & Evaluation October 13, 2009

2. Unique Reporting Requirements * 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- • The dollar amount of contractor invoices • The supplies delivered and services performed • An assessment of the completion status of the work • An estimate of the # of jobs created and retained • Names and total compensation of each of the five most highly compensated officers for the calendar year in which the contract is awarded; and • 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

3. Frequently Asked 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

4. Who must register? * Contractors receiving ARRA funded awards * Federal Agency Users obligating ARRA funds * Advance Registration recommended

5. Registering in FederalReporting.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

6. Contractor Reporting Requirements * 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

7. Contractor Reporting Requirements • 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

8. Data Quality Review by 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

9. Data Quality Review by CO * 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

10. Significant Errors and Material 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 omissionis 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.

11. ARRA 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. 

12. Subsequent 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)

13. Useful 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/

14. Questions?