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OMB Guideline M-11-34: Ensuring Completion of ARRA Projects by September 30, 2013

The OMB Guideline M-11-34 mandates federal agencies to ensure that ARRA projects are finalized by September 30, 2013. It revises the conditions of discretionary grant agreements, allowing recovery of unspent funds after this date unless waived by OMB. Grants expiring on or before this deadline cannot be extended. For grants expiring later, automatic no-cost extension (NCE) authority will end, and any extension must be approved by OMB by March 2, 2012, under specified criteria that consider project complexity and contractual obligations.

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OMB Guideline M-11-34: Ensuring Completion of ARRA Projects by September 30, 2013

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  1. New OMB Guideline M-11-34 Directed federal agencies to • take steps to ensure grantees to complete ARRA projects by 9/30/2013 • Revise terms of Recovery Act discretionary grant agreements • To the extent permitted by law, to provide for reclamation of funds that remain unspent after 9/30/2013, absent a waiver issued by OMB pursuant to this memorandum

  2. Effect of this Guideline • Grants expiring on or before 9/30/2013 • No extension beyond • Grants expiring after 9/30/2013 • Automatic NCE authority will be eliminated • Potential amendment of award expiration to 9/30/2013 • Extension beyond 9/30/2013 will require prior approval and waiver from OMB; request deadline 3/2/2012

  3. Criteria for Granting Waiver • Project is long-term by design; acceleration would compromise core programmatic goals • Project must undergo complex environmental review that cannot be completed within said timeframe • Contractual commitments between awardee and subrecipients/vendors legally prevent adjusting the timeline for spending • Acceleration may cause unnecessary harm or unreasonable risk to vertebrate animals or human subjects

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