Second Quarter Guidance from NIH - December 21 email to ARRA award recipients on reporting for the January 2010 reporting period
From: NIH ARRA Reporting (NIH/OD) Sent: Monday, December 21, 2009 4:05 PM Subject: Second Update on ARRA s. 1512 Recipient Reporting for the January, 2010 Reporting period
Attention ARRA Recipients:
This is an update to the previous guidance provided by NIH on December 11 (redlined version provided below).
New guidance was posted on Friday evening by the Office of Management and Budget which represents a major change. We also are providing a response to the numerous NIH ARRA grant recipients who wish to post their missing report or make corrections to the October 2009 reports. The guidance from OMB is in two parts: the first part explains awarding agencies’ responsibilities providing their recipients with the resources needed for reporting and reviewing the reports submitted by their recipients for completeness and correctness; the second part of the guidance explains how jobs created and retained should be reported in the January quarter and onward.
Missing reports and corrections for the October 2009 reporting window: We are very grateful for the due diligence shown by NIH ARRA Grant recipients who have attempted to post their first quarterly reports after the close of the reporting window in October. Unfortunately, NIH cannot accept late reports, and there is currently no mechanism in place for those reports to be posted late to the FederalReporting.Gov web site. NIH has relayed to HHS that a number of NIH ARRA grant recipients have asked for an opportunity to submit missing reports and make corrections to their posted reports.
Changes in Jobs Creation Calculation: The Office of Management and Budget has released new guidance on reporting the number of jobs created or retained that represents a substantial change from the previous guidance. For the second quarterly reporting period and subsequent quarters, recipients should report the number of jobs created or retained for the current reporting period only, whereas the previous guidance had directed recipients to report cumulatively across quarters. The new guidance also permits recipients to report jobs that will be reimbursed by ARRA funds at some point in time, whereas the previous instructions to recipients indicated that jobs could be reported only if they had been paid for by ARRA funds.
It is important to note that recipients are still required to report other fields, such as total funds received, and total federal ARRA expenditures, cumulatively across quarters.
Continuous Corrections Now Available on FederalReporting.gov: New guidance released by the Recovery Accountability and Transparency Board (Press Release, Recovery Board, 12/15/09) will allow ARRA award recipients to correct mistakes on FederalReporting.gov continually throughout each quarterly reporting period, effective February 1, 2010. This guidance is not retroactive to the October , 2009 reporting period.
New Edit Checks: Additional business rules, error checks and alert messages have been incorporated into the Federal Reporting.Gov web site, including:
Congressional Districts Error Check: FederalReporting.gov has new internal controls that have been implemented to compare recipients’ congressional districts with the zip code entered into the corresponding reports. If these two do not match, the system will not allow the report to be submitted until the correct congressional district has been entered.
Federal Expenditures Errors: During the first quarterly reporting period, NIH flagged recipient reports which entered federal expenditures which were greater than the award amount. In the upcoming second quarterly reporting period, FederalReporting.gov has created internal logic checks that will not allow recipients to submit reports with this error. If the amount of federal expenditures is greater than the amount of the ARRA award, the error must be fixed before submission. FederalReporting.gov will also not allow recipients to report that they have completed a project when they have not yet received ARRA funds.
‘Errors, Omissions, Non-Reporting Awards’ Reports Available: FederalReporting.gov will soon be adding three new reports to their downloading features. Users will now be able to view three downloads that list reports that are known to contain inaccuracies (Significant Errors), were deliberately omitted from the first quarterly reports because they appeared to contain incorrect and/or invalid data (Omissions), or failed to submit recipient reports as required by ARRA (Non-Reporting).