American Recovery & Reinvestment Act of 2009
(ARRA): Overview of OMB Guidance and Strategy
in the Implementation of Reporting Requirements
Brown Bag Luncheon Series
September 3, 2009
ARRA – Introduction of Panel
American Recovery and Reinvestment Act of 2009 (ARRA): Overview of OMB Guidance
and Strategy in the Implementation of Reporting Requirements
Topic
Presenter
Email
Telephone
Introduction
Penny Cook
penny.cook@yale.edu
785-6475
ARRA Timeline (February 22 through October 30)
Barbara Siegel
barbara.siegel@yale.edu
785-3680
ARRA Highlights
• Proposals and Awards-Where does Yale Stand?
Barbara Siegel
barbara.siegel@yale.edu
785-3680
Tracy Walters
tracy.walters@yale.edu
436-8455
ARRA Accountability and Reporting
• Federal
• Institutional
• Departmental
Tracy Walters
Steve DiCarlo
Sue Castaldi
tracy.walters@yale.edu
steven.dicarlo@yale.edu
436-8455
737-1389
432-8934
ARRA Reporting Solution
Paul DiBello
paul.dibello@yale.edu
Questions and Answers
All Panel Members
ARRA Reporting Requirements
• Overview
• Human Resource Assistance
• Procurement Assistance
SLIDE 1
susan.castaldi@yale.edu
432-6282
ARRA - Introduction
What will you take away from today’s presentation?
• ARRA timeline and Yale ARRA statistics.
• A general understanding of the new ARRA reporting
requirements.
• What will be the Principal Investigator’s and Departments
role with ARRA Reporting.
Interchangeable terms used for the American Recovery and
Reinvestment Act of 2009 throughout today’s
presentation:
• ARRA
• Recovery Act
• Stimulus Funds
• Section 1512
SLIDE 2
The ARRA Timeline and Highlights
ARRA Timeline
5/6/2009
Extramural
Research
Facilities
Improvement
Program
Deadline
$2-$5 million
4/21/2009
Competitive
Revision
Deadline
3/3/2009
Federal Agencies
report on use
of Funds
2/17/2009
ARRA Signed
into Law
3/1/2009
10/21/2009
Prime
Recipient
Review of
Submitted
Data
by Sub(s)
4/1/2009
5/1/2009
6/22/2009
OMB
Guidance
on ARRA
Reporting
Requirements
6/1/2009
8/17/2009
Early Registration
for Recipient
Reporting
7/1/2009
8/1/2009
2/17/2009
4/15/2009
Administrative
Supplement
Deadline
4/27/2009
Challenge
Grant
Deadline
5/6/2009
High End
Instrumentation
Grants
Deadline
SLIDE 4
5/27/2009
"GO"
Grants
Deadline
6/17/2009
Extramural
Research
Facilities
Improvement
Program
$10-$15 million
10/29/2009
Agency
Deadline
10/10/2009 for Review
Recipient
of
Reporting Submitted
Deadline
Data
7/17/2009
Extramural
Research
Facilities
Improvement
Program
Deadline
$5 - $10 million
9/1/2009
10/1/2009
9/17/2009
Core Facility
Renovation,
Repair, and
Improvement
11/1/2009
11/10/2009
10/30/2009
Reports
Published
on
Recovery.Gov
ARRA Highlights: Where does Yale stand?
• 826 ARRA Proposals for ~$557M in funding submitted by Yale
Proposal
Type
No. of
Proposals
Funding
Proposed
% of
Proposals
Administrative
Supplements
343
~$90M
42%
Conversions1
82
~52M
10%
Most
Common
“New” Types
Challenge
Grants
New2
1.
2.
400
~$415M
48%
Grand
Opportunity
Grants
No. of
Proposals
Funding
Proposed
% of
“New”
Proposals
262
~$219M
66%
37
~$91M
9%
Conversions: Proposals that originally did not respond to ARRA-related funding opportunities
that were converted to proposals to be funded by ARRA, per sponsor request.
New: Funding opportunities only available through ARRA support.
Data current as of 8/28/2009
SLIDE 5
ARRA Highlights: Where does Yale stand?
• 101 NIH (FY09 = ~$19M)
• 31 NSF (FY09 = ~$11M)
• 4 Other (FY09 = ~$241K)
• 136 ARRA Awards at Yale
(FY091 = ~$30M)
Top 10 Awardees for NIH2
Institution
No. of NIHARRA Awards
Institution
No. of NIHARRA Awards
1. Johns Hopkins University
143
4. Washington University
108
2. University of Michigan at
Ann Arbor
141
7. Yale University
101
3. University of
Pennsylvania
132
8. University of
California, Los Angeles
99
4. University of
Pittsburgh at Pittsburgh
108
9. University of North
Carolina, Chapel Hill
95
4. University of Washington
108
10. Duke University
94
1.
FY09 award figures from NIH (http://projectreporter.nih.gov/files/ARRA-projects.xls) ; FY09 award figures from NSF and Other are
based on total awarded amount as these agencies obligate their funds up front.
2.
Data Source: http://projectreporter.nih.gov/files/ARRA-projects.xls
Data current as of 8/31/2009
SLIDE 6
ARRA Highlights: Where Does Yale Stand?
• ARRA Notices of Award: Terms and Conditions
– Please be sure to identify and read the terms and
conditions of your ARRA Notice of Award.
• For example, Yale investigators have seen NIH combine an
equipment grant with an administrative supplement into one
award.
– Notice of Awards may include additional reporting
requirements for ARRA that are over and beyond the
reporting requirements discussed today.
– Additional award changes may include budget
reductions, etc.
SLIDE 7
ARRA Highlights
• Effective Practices upon receipt of ARRA Awards:
– Be sure to read all Notice of Awards.
– Be sure to discuss with GCA when you become aware of any
unusual requirements.
– Extensions of time may be required for the Prime Award in order
to match the project period of the new ARRA Supplement.
– Work with the Principal Investigator upfront to ensure labor
schedules and cost allocation methodologies are planned in
advance. Due to the associated high risk assigned by OMB and
OIG to Stimulus awards, the Federal government is expected to
be more aggressive with both program and financial audits, as
well as with expenditure reviews.
SLIDE 8
ARRA Reporting Requirements
Overview of ARRA Reporting Requirements
• OMB Memorandum M-09-21, Implementing Guidance for the
Reports on Use of Funds Pursuant to the American Recovery and
Reinvestment Act of 2009*, dated June 21, 2009:
– Answers questions and clarifies issues related to the mechanics and
chronology of recipient reporting required by ARRA;
– Provides clarification on what information will be required to be reported
into the central reporting solution at www.FederalReporting.gov and what
information will be reported on www.Recovery.gov;
– Instructs recipients on steps that must be taken to meet these reporting
requirements, including the incorporation of subrecipient reporting
requirements under Section 1512(c)(4) of the Act; and
– Establishes a common framework for Federal agencies and recipients to
manage a data quality process associated with ARRA recipient reporting
requirements.
* Memo M-09-21 can be found at the following link:
http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf)
** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09
SLIDE 10
Overview of ARRA Reporting Requirements
What reporting is required under Section 1512?
– A list of projects and activities funded by award to include:
•
•
•
Description
Project status as a percentage of completion
Estimates on jobs created or retained (Prime, Subawards and Vendors) ;
»
»
–
Total amount of funds received; and of that, the amount spent on
projects and activities; Aggregate reporting required in three
classifications:
•
•
•
–
Subawards to institutions
Subawards to individuals
Cumulative expenses of all other categories of expense
Details on sub-awards and other payments
•
•
SLIDE 11
Description of positions
Reporting of cumulative percentage for both prime, subawards, and vendors
Separate reporting of vendors greater than 25K
Number of Subawards and amounts paid
Overview of ARRA Reporting Requirements
•
Federal Agency
NIH/NSF
Yale University
(Prime Recipient)
Vendor A
University A
(Sub-recipient)
Vendor B
Prime Recipient Basic Requirements:
–
–
–
–
–
–
–
–
–
–
–
–
–
–
–
–
–
–
Federal Funding Agency Name
Award identification
Recipient DUNS
Parent DUNS
Recipient CCR information
CFDA number, if applicable
Recipient account number
Project/grant period
Award type, date, description, and amount
Amount of Federal Recovery Act funds expended to
projects/activities
Activity code and description
Project description and status
Job creation narrative and number
Infrastructure expenditures and rationale, if applicable
Recipient primary place of performance
Recipient area of benefit
Recipient officer names and compensation (Top 5); when
applicable
Total number and amount of small subawards, which are
less than $25,000
** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09
SLIDE 12
Overview of ARRA Reporting Requirements
•
Federal Agency
NIH/NSF
Yale University
(Prime Recipient)
Vendor A
University A
(Sub-recipient)
Vendor B
Sub-Recipient Basic Requirements (also
referred to as FFATA Data Elements):
–
–
–
–
–
–
–
–
–
–
Subrecipient DUNS
Subrecipient CCR information
Subrecipient Type
Amount received by subrecipient
Amount awarded to subrecipient
Subaward date
Subaward period
Subrecipient place of performance
Subrecipient area of benefit
Subrecipient officer names and compensation
(Top 5); when applicable
*Prime recipient reports unless delegated to subrecipient
** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09
SLIDE 13
Overview of ARRA Reporting Requirements
Federal Agency
NIH/NSF
Yale University
(Prime Recipient)
Recipient Vendor Basic Requirements
Vendor A
University A
(Sub-recipient)
– DUNS or Name and zip code of Headquarters
(HQ)
– Expenditure Amount
– Expenditure Description
Sub-Recipient Vendor Basic Requirements
Vendor B
– DUNS or Name and zip code of Headquarters
(HQ)
*Prime recipient reports unless delegated to subrecipient
** Slide adapted from the OMB Presentation Recovery Act Overview Webinar 7-20-09
SLIDE 14
Overview of ARRA Reporting Requirements
• When do ARRA Reporting Requirements begin?
– The first scheduled reports are due October 10.
– Reporting will be cumulative from inception.
• How will recipients report ARRA funds?
– Reports will be submitted via www.FederalReporting.gov.
• Will we be expected to report all Federal awards
including Non-ARRA funds this way going forward?
– No, these new reporting requirements are exclusively for
section 1512 reporting, ARRA Awards.
SLIDE 15
Overview of ARRA Reporting Requirements
Human Resources Assistance
• Contact your HR Generalist or departmental HR Manager as soon as
you are notified of an award to make them aware of potential staffing
needs.
• HR can assist you in developing your position description, defining
position requirements and getting your position appropriately
classified for posting and reporting purposes.
• The Staffing Dept. will review your position requirements and match
to the skill sets of Yale employees currently in layoff status.
• If your position requires skills not currently available in house then it
will be posted on the external website.
-
SLIDE 16
In anticipation of research staffing needs as a result of ARRA Awards, the Staffing
department has pre-screened candidates in our STARS database .
Postings can be waived in cases where you are interested in hiring a qualified
layoff candidate.
If you have an immediate need for a Research Assistant and a qualified IEP staff
member is available, they may be provided to you at no cost during the posting
process.
You may elect a 90 day trial period for hires from layoff which will be paid for by
Human Resources-your HR Generalist and/or Recruiter can assist you.
Overview of ARRA Reporting Requirements
Purchasing Assistance
• To help Purchasing recognize purchases greater than 25k that are
being charged to stimulus funds, indicate ‘Stimulus Funds’ in the
requisition’s Notes section. For SciQuest orders, this would be entered
as an Internal Note under the Yale Internal Info tab.
• For purchase orders over $25K, Purchasing is developing a form to
collect required data from the vendor, including DUNS Number and
Positions Created or Retained. They will collect the data from the
vendor.
• Purchasing will run ongoing queries to identify purchases/payments
that require ARRA reporting data and collect the data from the vendor
regardless of whether the purchase originated from a purchase order
(e.g., SubAward payments).
• Fran Consiglio will serve as a lead within Purchasing for Stimulus
Fund needs, assisting other Buyers and their assistants as needed.
However, please work with the commodity’s primary buyer for your
purchase.
SLIDE 17
ARRA Accountability and Reporting
ARRA Accountability and Reporting
Federal Oversight Requirements:
•
Agency Oversight
–
•
Inspector General
–
•
Agencies must take steps, beyond standard practice, to initiate
additional oversight mechanisms in order to mitigate the unique
implementation risks of ARRA.
OIG offices are receiving supplemental funding for ARRA
oversight.
Audits
– OMB Circulars, specific agency’s policies and procedures, as well
as special Terms and Conditions associated with each award
applies to ARRA funding.
SLIDE 19
ARRA Accountability and Reporting
Institutional Requirements:
•
ARRA awards must be tracked separately in order to meet the
additional reporting requirements.
•
Quarterly Accountability Reports
– Cumulative reporting of data.
– Submitted by the 10th day following the calendar quarter end.
– Current methodology will be to use the data from the most recent
month-end close. For quarter ending September 30, quarterly
reports will provide data from August month-end close.
Higher Risk associated with ARRA funding
– May require Yale to establish lower thresholds for cost transfer
reviews and GCFA approvals.
•
SLIDE 20
ARRA Accountability and Reporting
Institutional Accountability and Reporting:
•
GCA’s Role:
– Review and verify special terms and conditions, as well as additional
reporting requirements within Notice of Awards from Federal agencies
and subaward documents where Yale is a subrecipient of ARRA funds.
– Provide templates of reporting requirements to subaward recipients
where Yale is the prime.
– Verify compliance checks.
– Establish awards in OGM.
•
GCFA’s Role:
– Develop and implement a process and system to meet ARRA reporting
requirements.
– Verify accuracy of data reported within the various systems.
– Work with departments to ensure completeness of data.
– Certify and submit reports via the Federalreporting.gov website within
the established deadline dates.
SLIDE 21
ARRA Accountability and Reporting
Institutional Accountability and Reporting:
• ARRA Award Setup and Tracking
– Second digit in Award PTAEO replaced with an “S” to signify
Stimulus.
– Short title starts with STIM:
– Attribute setup to record Y or N for Stimulus funds.
– Accountholder report showing the Stimulus attribute.
• Yale as a subrecipient of Federal Stimulus Awards (flow-through)
– flex field(s) will be created to identify whether Yale via GCFA is
required to report directly to the FederalReporting.Gov website or
to the Prime.
SLIDE 22
ARRA Accountability and Reporting
Account Holder Report:
The words Stimulus Award will appear on each page of the Account Holder Report by Person and the
Account Holder Report by PTAO in the header section.
Changes to page
SLIDE 23
ARRA Accountability and Reporting
Departmental Accountability and Reporting:
Award Receipt
• Review NOA Terms and Conditions.
• Contact and discuss with your GCA team member if there are any
unusual terms or funding anomalies, which may require special
attention.
Reporting
• Review award budget, identify personnel, verify charging and
charging instructions upfront, and develop an allocation methodology
with the Principal Investigator prior to charges posting to the award.
• Plan ahead; make sure labor schedules and cost allocation
methodologies are planned and implemented in advance.
• Minimize cost transfers to ARRA Awards; Due to the high risk nature
of these awards if a transfer is required, make sure the transfer is well
documented.
SLIDE 24
ARRA Accountability and Reporting
Departmental Accountability and Reporting:
Reporting (Continued)
• Confirm all ARRA awards appear on your list of reports to
review.
• Review quarterly report information for accuracy.
• Once reviewed, work with the Principal Investigator to
verify any edits or changes required in the pre-populated
reporting data.
• Submit quarterly reports to GCFA within the designated
time request (anticipated to be 5 to 10 business days from
initial release to department).
SLIDE 25
ARRA Reporting Solution
ARRA Reporting Solution
Other’s Approach to ARRA Reporting
• Several institutions are requesting departments and principal
investigators to fill-in the blank excel forms for ARRA reporting.
Yale’s Approach to ARRA Reporting
• Minimize the time required by the principal investigator and
departmental administrator in completing quarterly ARRA
reports.
• Develop a system and process to accumulate as much information
available from Yale’s systems to pre-populate the quarterly report
form.
• At present, it is expected that all required information can be prepopulated into the quarterly reporting form, which will only
require the department (PI, and business administrator) to verify
reports and check for accuracy.
SLIDE 27
ARRA Reporting Solution
Solution is being developed in the Oracle Environment
•
•
•
•
Utilizing the e-business suite tools.
Developing own set of tables for data extraction, translation, and
population.
User interface will be developed with a workflow picklist and will
enable data entry and corrections in the Oracle Forms environment.
Access to data and security of forms will be provided at the
departmental level.
Reporting
•
•
Current expectation is that all data will be pre-populated within the
form for department or PI review and verification.
Once submitted, the form will appear in the GCFA worklist for final
review, verification and approval for uploading onto the
federalreporting.gov website.
SLIDE 28
ARRA Reporting Solution
GCA Proposal/Award
data into GPAS/InfoED
Storage Group
Reviewer can
Queue report
back to
Automated Data
Extraction
Purchasing/Procurement
enters data into Oracle (HOP1)
ASU enters Award setup
Information into OGM
(HOP1)
Uploads to
Federal Reporting.gov
website
Storage Group
Data Extract
Performed onDemand
Database
Automated Process
extracts data from system
storage and populates
ARRA Database
GCFA User
Requeues back to Dept for
Additional changes
Oracle Form
Oracle Form
Approves & Releases
To GCFA
Dept/Business Office User
Reviews/.Completes missing Info.
SLIDE 29
GCFA User
reviews Database
and updates data - QC
GCFA
Approves
and Releases
Data ready for
upload to
website
ARRA Reporting Solution
Departmental Worklist Screen shot
• Position your cursor on the Award Number and click on the “Open Award” button
to open an Award
SLIDE 30
ARRA Reporting Solution
SLIDE 31
ARRA Reporting Solution
SLIDE 32
ARRA Reporting Solution
SLIDE 33
ARRA Reporting Solution
SLIDE 34
ARRA Reporting Solution
SLIDE 35
ARRA Reporting Solution
SLIDE 36
ARRA Reporting Solution
SLIDE 37
ARRA – Additional Information
• Today’s Brown Bag Presentation will be available at:
http://www.yale.edu/researchadministration/BrownBagPresentations.html
• Centralized site for OMB Guidance Documents
http://www.recovery.gov/?q=content/recipient-reporting
SLIDE 38
Questions and Answers