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 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 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