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 implements Section 1512(c) of the Recovery Act *Specific reporting requirements in FAR include, but not limited to- 1.The dollar amount of contractor invoices 2.The supplies delivered and services performed 3.An assessment of the completion status of the work 4.An estimate of the # of jobs created and retained 5.Names and total compensation of each of the five most highly compensated officers for the calendar year in which the contract is awarded; and 6.Specific information on first-tier subcontractors *First reporting period is Oct. 1 – Oct. 10, 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 *1 st 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 address Your address will serve as your User ID –Select Department of Health & Human Services on drop down menu –Registration confirmed via (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 Contractors may make corrections Upon completion of Day 21, reports locked and transmitted to Final Submission Status Phase Days Contractor may make corrections if CO submits comments Day 30 System posts all reports as final

8 Data Quality Review by CO *Days 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 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

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 omission is 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 ed 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 10 th 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 – Jan. 10, 2010)

13 Useful Links User Guide FAQs for Contractors on Reporting FAQs Agency Review of Contractor Reports General FAQs

14 Questions?