[Cobo] FW: Revised Guidance for ARRA Reporting

[Mauck, Sheri]

ARRA Grant reporting guidance.


-----Original Message-----
From: Lisa.McKeithan at osf.ok.gov [mailto:Lisa.McKeithan at osf.ok.gov] 
Sent: Monday, October 04, 2010 7:15 AM
To: Lisa.McKeithan at osf.ok.gov
Cc: steve.funck at osf.ok.gov; Janice.wolfenbarger at osf.ok.gov
Subject: Revised Guidance for ARRA Reporting


Here is the update they sent late Friday.  Basically, they are changing the
earlier guidance to aggregate vendor payments during the quarter and gone
back to the 'individual payments over $25,000' must be reported on the
vendor tab.  I am including the email they sent to us and then also the
portion of the FAQ dealing with the vendor payments.....Lisa

Attention:  OMB is re-issuing the latest round of Recovery Act guidance
(M-10-34) that was published on Friday, September 24th.   OMB received
significant feedback from ARRA recipients that a particular element of the
guidance related to aggregation of sub-awards and payments would cause a
major and unanticipated increase in administrative burden.   The impact of
this change to the guidance was not intended and thus OMB has determined
the best course of action is revise guidance on this issue to return to the
previous method of reporting.

OMB has re-posted the guidance document M-10-34 to reflect this change
(found at
http://www.whitehouse.gov/sites/default/files/omb/memoranda/2010/m10-34.pdf
) as well as re-posting FAQs clarifying M-10-08 that outline the reporting
responsibilities for recipients related to sub-awards and vendor payments
(found at http://www.whitehouse.gov/omb/recovery_faqs/#10-08-1).

FAQs...


   1.	What information are prime recipients and sub-recipients with
      delegated reporting responsibility required to report for vendor
      payments?

      A:  All vendor payments must be reported. Individual payments greater
      than $25,000 must be reported separately with the following data
      elements for each payment:
            Vendor identity either through DUNS number OR the Vendor Name
            and the zip + 4 digit code of the vendor's headquarters.
            Payment description and payment amount (required to be reported
            by prime recipients; optional for subrecipients)

      Recipients may report individual payments less than $25,000 either
      separately or aggregated. The aggregated record should not duplicate
      information reported in separate records.

      Example 1:  A recipient paid a vendor 26 payments of $1,000 each
      within the reporting period. Since no payment exceeded $25,000, the
      payments can be reported in the aggregate in the PRIME RECIPIENT TAB
      or separately in the VENDOR TAB, but not both.

   2.	Does the $25,000 threshold for vendor payments apply to payments or
      the award or invoice amount?

      A:  Aggregation is based on PAYMENTS under $25,000 and not on awards
      or amounts invoiced, if different than the payment amount.

   3.	How are aggregated payments reported over more than one quarter?

      A:  Include the total number and dollar amounts for payments to
      vendors under $25,000 for the current reporting quarter and all past
      reporting quarters in the PRIME RECIPIENT TAB.

   4.	How are separate payments to one vendor reported over more than one
      quarter?

      A:  For payments of $25,000 or more, include payments made to the
      vendor for the current and past quarters with the payment amount in
      the VENDOR TAB.

      Example 2:  A vendor received one payment of $25,000 in the previous
      quarter and another payment of $25,000 in the current quarter. The
      recipient would report two payments of $25,000 in the VENDOR TAB.

   5.	What if a vendor's payments were aggregated in a previous quarter and
      then the vendor received a payment of more than $25,000 during the
      current reporting quarter?

      A:  Continue reporting the amounts aggregated in the previous quarter
      with any additional aggregated payments of less than $25,000 in the
      current quarter and list of payments of $25,000 or more for the
      current quarter in the VENDOR TAB.

      Example 3:  Vendor A receives one payment of $5,000 in Q1, one
      payment of $5,000 in Q2, and one payment of $25,000 in Q2. For the Q2
      reporting period, the recipient reports the $25,000 payment
      separately in the VENDOR TAB and includes the $10,000 as a cumulative
      aggregation in the PRIME RECIPIENT TAB.


Lisa McKeithan
Office of State Finance - ISD
Enterprise Systems & Business Analyst
405.521.3772