ARRA FUNDING UPDATE

• Unprecedented Number of Proposals

• JIT Requests• Extraordinary Reporting

Requirements• Unique Administrative

Characteristics• OMB Implementing

Guidance still not clear

Stimulus Task Force

• Membership– Central and School Administrators– Office of Audit, Compliance and Privacy– Information, Systems and Computing

• Best Practices– Proposal processing– Communications– Compliance/Develop Roles and Responsibilities

• Reduce Burden on PI/BA

– Reporting Requirements

ARRA Reporting Requirements

• Ever changing target– OMB request for comments 4/1/09– Reporting requirements issued 6/22/09– Updated Data Dictionary issued 8/6/09

• Quarterly Reporting– Due 10 days after period end

• Standard data elements for all agencies– Many data elements not previously captured

Data Elements(expected to be captured centrally)

• Award and Award Recipient Information– Name of Federal Agency and Organizational

Element– Award Number

• Institution (Penn) Information– Legal name, DUNS, EIN

• Award Information– Project Period, Reporting period, type of

report

Data Elements (expected to be captured centrally)

• Project/Activity Information– Name of Project– Cumulative amount of cash received– Cumulative amount of expenditures– N. American Industry Classification System

code, if applicable

Data Elements(expected to be provided by PI/BA)

• Description of Project or Activity– Brief narrative description – Currently being requested on PI Certification

• Not always completed• Consideration being given to not setting up award without

this being provided

• Evaluation of completion status– Based on project performance, not on financial

information– Based on per cent complete– Request to PI/BA will be sent 30 days prior to the end

of the quarter

Data Elements (expected to be captured centrally)

• Description of Employment Impact– Description of jobs created and retained

• Based on HR categories

– Estimate of the # of jobs created and retained• To be reported based on salary charges to ARRA

funding, excluding standing faculty• Based on employment date of individual• Must include information from Subawardees and

certain vendors

Data Elements (expected to be captured centrally with assistance from BA) • Subrecipients

– Name and physical location of subrecipient**– Subrecipient DUNS**– Subrecipient type– Total amount of subaward– Total amount of funds disbursed– Project period– Name and total compensation of officers for the five

most highly compensated officers, if not already publicly available

**Subrecipient must be in Central Contractors registryI

Data Elements(expected to be captured centrally with assistance from BA)

• Vendors– Payments under $25K

• Total number of payments• Total amount of payments

– Payments over $25K• DUNS of vendor or HQ zip code and vendor name• Product and Service description• Payment amount• Jobs data

ARRA Funding has arrived!

• More than 100 awards• Greater than $36million• R01’s,R21’s, S10’s, R03’s• Flow-through• NIH and NSF, so far• Account Set-up monitored

– Expectation of set up within 5 business days

Award Set Up

• Spelled out in NOGA

• ARRA related CFDA

• Comments on the AIS

• Specific document number and LOC

• Specific grant fund parent created

• Integrity reports run regularly

• Special communication directly to the PI

What do you need to know?

ARRA requires recipients to account for, track, monitor, report on, provide for audit of, and closeout ARRA funding separately from non-ARRA

What does this mean?

• New awards – awarded under FDP– will normally allow for carryover between budget periods

• Renewals (competing continuations)– Carryover will not be allowed from the prior competitive segment

or into the next segment if awarded with non-ARRA funding

• Supplements/Revisions– Must be separately accounted for– No rebudgeting or carryover between supplement and parent

grant– Separate reporting, including FSR, final progress report and final

invention statement

Carryover Schemes

• 5-R01-HL-012345-05 Non ARRA• 2-R01-HL-012345-06 ARRA• 5-R01-HL-012345-07 ARRA• 2-R01-HL-012345-08 Non ARRA

-05 Yr funds CANNOT be carried forward into -06-05 year MUST be financially closed-06 Yr funds CAN be carried forward into -07-07 Yr funds CANNOT be carried forward into -08-05 Yr funds CANNOT be carried forward into -08

ARRA Grant Compliance

• The applicant organization certifies in the grant application that it is obligated to comply with the terms and conditions of any resulting grant award

• Acceptance of a grant award is signified by drawdown of funds which then obligates the grantee to comply with all standard and special terms and conditions of award (e.g., based on statute, regulation, policy, program requirement) – Failure to comply may cause NIH to take one or more

enforcement actions, depending on the severity and duration of the non-compliance. Enforcement actions may include special conditions, closer monitoring, withholding of support, recovery of funds, suspension, or termination

Accountability and Transparency

• Recovery and Accountability Transparency Board

• Government Accountability Office

• Office of Inspectors General• OMB and the A-133

Compliance Supplement

In Closing….

• Quarterly Reporting– Description of the Project– Evaluation of the completion status

• Subrecipients– Must be in CCR and must be able to comply with

ARRA requirements

• Administrative Characteristics– No carryover between ARRA and non-ARRA funding– No rebudgeting between ARRA and non-ARRA

funding– Separate reporting requirements

More Information

• OMB Webinars – http://www.whitehouse.gov/recovery/webinartrain

ingmaterials/

• NIH ARRA Terms and Conditions– http://grants.nih.gov/grants/guide/notice-files/NO

T-OD-09-080.html

• General Information – www.recovery.gov