ARRA Reporting Policies
Post-Award and Compliance Resources
Policies and Procedures for Management and Reporting of American Recovery and Reinvestment Act (ARRA) Funds
ARRA awards and proposals are subject to the same policies and procedures as other Hamilton College contracts and grants.
ARRA awards are also subject to additional requirements that are addressed by the following policies and procedures.
Quarterly Reporting
The College is following all guidance issued by the Office for Management and Budget (OMB) and the sponsoring agencies from which it receives ARRA funds. The reports required under Section 1512 of the Act will be submitted beginning in October 2009 and will contain detailed information on the projects and activities funded by the Recovery Act. The College has registered at www.federalreporting.gov for submission of these reports.
The Office of Foundation, Corporate, and Government Relations will be responsible for completing the appropriate data elements and submitting reports no later than the 10th day after each quarter.
Expenditure data will be posted in and reports will be derived from the College’s financial accounting system (My Grants) in the same manner as with other sponsored projects. University jobs data, if applicable to that grant and contract in question, will be calculated from payroll and other data in the University’s payroll/HR system. Subrecipient, and any qualifying vendor/ jobs data will be obtained from that entity’s administrative contact. To ensure accuracy and timely submission of data, the best available financial and jobs data will be reported. This data will primarily be as of the quarter end for which the College is reporting. In cases where quarter-end data might be incomplete or inaccurate, the most current, accurate data available will be reported. As reports are cumulative, any information for the previous quarter not reported by the 10th day after the end of that quarter will be included in the next quarterly report.
Subrecipients are informed of reporting requirements in the subaward from the College. Subrecipients delegated reporting authority will provide job data (see above) directly to the College and will enter “Subrecipient Data Elements” at Federalreporting.gov. This data will be subject to the same day 11-21 review as the University’s data. Subrecipients to whom the College does not delegate reporting authority will be required to submit the best available data to the College, which will be included in the College’s quarterly reporting.
“Project Status” and, when appropriate, “Quarterly Activities/Project Description” will be updated based on information received from each project’s Principal Investigator (PI). The Office of Foundation, Corporate, and Government Relations will be responsible for contacting the PIs prior to the end of the quarter and will receive assistance from the Dean of Faculty’s Office if information is not received in a timely manner. PIs may also be contacted for assistance if the Office of Foundation, Corporate, and Government Relations does not receive timely information from its subrecipient(s) or if information provided by a subrecipient does not correspond to the subrecipient’s awarded budget, including personnel categories.
During the ten day correction window, the data will again be reviewed by the Office of Foundation, Corporate, and Government Relations. Any needed adjustments will be made by the Office of Foundation, Corporate, and Government Relations or the delegated sub and rechecked and by OFCGR before the 21st.
If an agency identifies an issue during its day 22-29 review and opens a report for edit, the College will make corrections to the report as instructed. Any data issues identified beyond the date of publication (day 30) will be corrected or addressed in the next quarterly report.
Training:
The Office of Foundation, Corporate, and Government Relations is responsible for monitoring sources for OMB, State, and Agency guidance related to ARRA funding. The College’s ARRA policies and procedures are maintained by the OFCGR its website, https://my.hamilton.edu/ofcgr and are reviewed and approved by the Dean of Faculty’s office.
The Office of Foundation, Corporate, and Government Relations will read the guidelines for all proposals before submission to ensure the College’s compliance. The OFCGR is responsible for identifying when the potential funding source for a proposal is the Recovery Act. The OFCGR flags ARRA proposals in its grants tracking spreadsheet and inform the PI of the special requirements.
When an ARRA funded award is received, the Academic Business Manager will identify new ARRA in the College’s opening memo, usually noting ARRA in the formal title. The OFGCR will contact the PI and direct him or her to the College’s ARRA policy and will act as the point of contact for ARRA issues. The OFCGR also contacts the PI directly to provide a reminder of the additional requirements, including the importance of conducting the ARRA funded project in a timely manner to meet the objectives of job creation and economic stimulus.
ARRA Segregation:
Each ARRA award will have a separate set of accounts that has been established within the financial accounting system.
PIs are responsible for all aspects of management of their projects, including financial oversight.
Subrecipient Monitoring:
The College is responsible for ensuring that its subrecipients comply with all the requirements of the prime funding source including, when applicable, ARRA reporting requirements. Along with these policies and procedures, for ARRA funded subrecipients the College will:
- If reporting is delegated, OFCGR will request the financial information prior to the subrecipient’s federal reporting, via e-mail or fax. This will allow a review of the financial information, giving the College an opportunity to compare to invoices and other information for reasonableness.
- If it is not delegated, subrecipient and any qualifying vendors will be required to report financial and jobs information to OFCGR. OFCGR will review this information for reasonableness, consulting with the PI as needed, and will include this information in its quarterly reporting.
