The Recovery Act places great emphasis on accountability, transparency and reporting of all ARRA funds distributed. Mandatory quarterly reporting to a central government wide portal and other additional terms and conditions are addressed below.
The Office of Research and Sponsored Programs (ORSP) is responsible for review and acceptance of all sponsored awards, including those funded by ARRA. Upon receipt of fully executed ARRA Award, ORSP documents are properly labeled as ARRA funding. Award Notification/Documents are drafted and sent to the ORSP Accountant and the UM Accounting Office. The ORSP Accountant creates a separate ARRA Reporting file for each award that is maintained in addition to the fully executed award file. The ORSP Accountant is responsible for initial ARRA Quarterly report setup, report compilation, report submission to the State of Mississippi Stimulus360 and submission to the Accounting Office.
The Accounting Office establishes a separate account within the University’s accounting system (SAP) for each project as Award Notification/Documents are received. The accounts are specifically labeled “ARRA” to ensure proper segregation from other funds. Within each account, expenses for the project are charged using unique general ledger codes. The Accounting Office is responsible for incorporating overall financial data into ARRA Quarterly Reports, report review, approval in Stimulus360 and submission into FederalReporting.gov.
Accounting and ORSP personnel have attended classes and viewed webinars on ARRA funds and reporting. They are also required to review updated guidance issued from OMB, Federal Agencies and the State of Mississippi.
Additionally, review of terms and conditions of ARRA awards as they are received by the ORSP aids in training for award administration. Any new guidance gathered from specific award documents is communicated to the ORSP Accountant, Accounting Office and the project Principle Investigator (PI).
Once the ORSP has a fully executed award and determined that it is ARRA funded, an Award Notification and associated documents are compiled and sent to the ORSP Accountant, Accounting Office and the award PI. The PI is provided a listing of ARRA requirements and acknowledges the requirements as part of the award acceptance process. Any modifications after that point are communicated to the appropriate offices as they are received by ORSP.
The ORSP Accountant will contact each PI by email in advance of the quarterly reporting deadline in order to gather the appropriate information to complete the report data elements.
The University will separately identify each subrecipient and inform them of the Federal award number, CFDA number, amount of ARRA funds, and reporting responsibilities in the subaward agreement prepared by ORSP.
Section 1512 of the Act requires that quarterly reports are to be submitted into FederalReporting.gov no later than 10 days after the end of each quarter beginning October 2009. The reports must contain the following information:
- All associated project information, including-
- The name of the project or activity;
- Recipient DUNS number;
- Funding Agency, Awarding Agency and Program Sources codes;
- CFDA Number;
- Amount of award;
- Award date
- A description of the project or activity;
- An estimate of the number of jobs created/retained by the project or activity;
- A description of the quarterly activities;
- For infrastructure projects, the purpose, total cost, rationale of the agency for funding the infrastructure and the name of the person to contact with any concerns;
- The primary place of performance; and
- Applicability of reporting on recipient highly compensated officers.
- The amount of ARRA funds received/invoiced from the agency;
- An evaluation of the completion status of the project or activity;
- The amount of ARRA funds expended on the project or activity;
- Total Number or Payments and Total Amount of Payments to Sub Awards, Individuals or Vendors less than $25,000/award;
- Detail of expenditures to Sub Awards, Individuals or Vendors greater than $25,000/award.
The ORSP Accountant will do an initial report setup based on ARRA award documents. The PI will then be contacted to complete other programmatic data elements. At the end of each quarter, the ORSP Accountant will extract sub award, individual and vendor data from SAP. Jobs data will also be calculated from HR/payroll reports generated from SAP. The best available information at the end of the quarter will be used in order to ensure accuracy and timely submission of reports. The PI will also be contacted by the ORSP Accountant prior to the end of each quarter for an update on quarterly data elements; i.e. project completion status, quarterly activities, and any additional information on jobs created or retained for that quarter.
Subrecipients are informed of reporting requirements in the subaward agreement from the University. The University has not delegated reporting authority to their subrecipients and will report all necessary information on their behalf. The subrecipient will report to the ORSP Accountant the best available information, which will be included in the University’s quarterly report. The University will enter “Subrecipient Data Elements” at FederalReporting.gov.
For payments over $25,000, the ORSP Accountant will contact vendors for the necessary information to enter “Vendor Data Elements” at FederalReporting.gov.
The ORSP Accountant will gather and compile the programmatic, jobs, and payment information for each quarterly report. After review, the report will be entered into Stimulus360 for the State of Mississippi. The ORSP Accountant will then send each completed report to the Accounting Office with a notice that all reports have been entered into Stimulus360.
The Accounting Office will review each report received. The remaining financial data, “Total Federal Amount ARRA Funds Received/Invoiced” and “Total Federal Amount of ARRA Expenditure”, will be extracted from SAP and entered by the Accounting Office into the report. That remaining data will be entered into Stimulus360 and each report will be marked as “Approved.” The Accounting Office will then upload the completed reports into FederalReporting.gov.
During the reporting review period, days 11-21 after the end of the quarter, report information will be reviewed for accuracy and any corrections necessary will be made during the open window. Agency review will be days 22-29. If any issues are identified by an agency and the reports are opened for edit, the University will make any corrections necessary before the date of publication (day 30).
For report preparation, the following are generated from SAP:
- Expenditures – KE5Z – Profit Center: Actual Line Items
- Payroll – ZPAYREPORTS – Payroll Reports Selection
The reports are extracted from SAP into an excel file and maintained as ARRA Report Details for each individual ARRA project. The files are saved by PI name on the computer of the ORSP Accountant. The Report Details are printed and filed in the ARRA Reporting file for each project. All data is extracted as of quarter end and any information found not reported on the previous quarter will be included in the next quarterly report. Each ARRA Reporting file maintained by the ORSP Accountant also includes printed copies of each quarterly report filed, report correspondence, approval of equipment purchases, subrecipient and vendor information if applicable, and necessary award documentation.
Additional terms and conditions important to note are:
- Buy American – Use of American Iron, Steel, and Manufactured Goods (ARRA Sec. 1605)
- Wage Rate Requirements (ARRA Sec. 1606)
- Preference for Quick Start Activities (ARRA Sec. 1602)
- Limit on Funds (ARRA Sec. 1604)
- Whistleblower Information
- How to report Fraud, Waste and Abuse or Mismanagement involving ARRA Spending
The University maintains all necessary registrations with Dun & Bradstreet (DUNS), Central Contracting Registration (CCR), FederalReporting.gov, and the State of Mississippi Stimulus360. If you have any questions, please contact us at area ( at ) olemiss ( dot ) edu.