July 29, 2009
CHIEF FINANCIAL OFFICER MEMORANDUM NO. 01 (2009-2010)
SUBJECT:
AMERICAN RECOVERY AND REINVESTMENT ACT (ARRA)
REQUIREMENTS
The American Recovery and Reinvestment Act of 2009 (“ARRA”) has made billions of dollars
available to the State of Florida. ARRA mandates special accountability and transparency
requirements for the expenditure of all ARRA appropriations. In order to ensure that the State of
Florida fully complies with the accountability requirements of ARRA, this memorandum establishes
special requirements for recording ARRA receipts and the reporting of payments (regardless of
amount) made from ARRA funds. All existing Department of Financial Services (DFS) payment
processing requirements remain in effect.
ARRA Funds Agency Representation
Each Agency receiving or expending ARRA funds must represent in writing to the State of Florida
Chief Financial Officer that internal controls and procedures are in place to ensure a proper
accounting and reporting of ARRA funds. Agency Representation Letters must be signed by the
agency head. DFS Division of Accounting and Auditing will send each agency a request for an
Agency Representation Letter at the beginning of each state fiscal year. Signed representation letters
must be submitted to the Division of Accounting and Auditing no later than September 1.
ARRA Expenditure Requirements
At the beginning of each fiscal year through the Agency Representation Letter referenced above, each
agency will provide, for each ARRA award, the specific data elements used in FLAIR to separately
account for the expenditures. The data elements may include, but are not limited to, special category,
grant number, project number and/or other cost accumulator. If an agency receives additional ARRA
awards during the fiscal year, the agency is responsible for providing the Bureau of Auditing the data
elements in FLAIR to separately account for the expenditures before the first payment is made.
In addition to the existing payment processing requirements, DFS may request documentation that
substantiates any payment of ARRA funds to a vendor or subrecipient or information reported under
Section 1512 of ARRA. This documentation may include, but not be limited to, the agreement/
contract, procurement documentation or price/cost analysis, invoices, reports evidencing receipt of
goods or services, agreement/contract monitoring reports, or agency reports detailing disbursement
transactions that support the amount of ARRA funds expended and reported quarterly.
DFS may also request additional documentation that demonstrates Agency compliance with the
following ARRA requirements.
•
Recipients and their subrecipients must maintain current registration in the primary
registrant database for the U.S. Federal Government, Central Contractor Registration
(CCR) at all times during which they have active federal awards funded with ARRA funds.
•
ARRA related agreements must include provisions (as applicable) addressing requirements
necessary for compliance with ARRA, including but not limited to:
¾
¾
¾
¾
Amount of ARRA funding
2 CFR 176, subpart A reporting requirements
2 CFR 176, subparts B and C requirements
Additional sub-recipients reporting requirements contained in 2 CFR 176,
subpart D.
Accounting for ARRA Revenues
As specified in Agency Addressed Memorandum (No. 18, 2008-2009), to account for ARRA
revenues originally receipted from the Federal Government, the following revenue category has been
established in FLAIR:
000750
Federal ARRA Grants
All ARRA grant revenue must be recorded in FLAIR using this new revenue category for fiscal year
ending June 30, 2009, and each fiscal year thereafter. Subsequent transfers of ARRA funds to
another account code within the agency, or to another agency, should be coded with existing transfer
categories. New categories will not be established for the transfer of ARRA funds to other funds/
agencies within the state entity. However, if an agency uses a Transaction Code 94 in FLAIR to
transfer ARRA funds, the new 000750 category code should be used in the receiving account code.
Schedule of Expenditures of Federal Awards (SEFA) Reporting
Agencies are required to report ARRA expenditures separately on the 2008/2009 SEFA (and fiscal
years thereafter). Further SEFA instructions are available on the following website:
http://www.myfloridacfo.com/aadir/statewide_financial_reporting/financing.htm
Recommendations
Agencies should consider the following supplemental requirements to enhance accountability and
transparency related to ARRA in addition to the above requirements.
•
•
Agencies should consider issuing cost reimbursement agreements.
Agencies should also consider issuing new agreements for ARRA funds rather than
amending existing agreements to include ARRA funding.
Questions regarding this memorandum may be directed to Cheri Greene at 850-413-5593,
Cheri.Greene@myfloridacfo.com, or Jeff Cagle at 850-413-5504, Jeffrey.Cagle@myfloridacfo.com.