Peter Orszag

“ For information related to the Recovery Act to be fully transparent to the public, each agency must develop a list of agency systems which will capture significant program-related information related to the use of Recovery Act funds from recipients, either through existing or new reporting requirements. Further, agencies must identify what information each system captures, if it is publicly available in a user-friendly format, and if not, what technological or policy barriers exist to it being made public. ”

“ In the short term, agencies should not change standard reporting for awards, unless there is a legal or other compelling justification. However, if the Recovery Act requires modifications or additions, agencies should integrate new and existing procedures to streamline data collection and to minimize funding recipients’ burden. Cases that may require waivers to existing standards to accommodate Recovery Act reporting requirements will be evaluated by the Recovery Act Accountability and Transparency Board (see Section 3.1) and OMB in the context of a government-wide review of data reporting. ”

“ Public access to these reports is a logical outgrowth to promote transparency since the FAC is a central repository of all reports and beginning in 2008 reports are filed in an electronic format. A current concern with the FAC making the reports publicly available on-line is a report may inadvertently include personally identifiable information (PII) . While the reports are currently subject to the Freedom of Information Act, the FAC sends all FOI requests to the Federal Cognizant agency who is responsible to review, redact as necessary, and send to the requestor. ”

“ Agencies must take steps, beyond standard practice, to initiate additional oversight mechanisms in order to mitigate the unique implementation risks of the Recovery Act. At a minimum, agencies should be prepared to evaluate and demonstrate the effectiveness of standard monitoring and oversight practices.
(1) Performance Management and Accountability
Agencies must adapt current performance evaluation and review processes to include the ability to report periodically on completion status of the program or activity, and program and economic outcomes, consistent with Recovery Act requirements. ”

“ Yes, agencies are required to designate a senior accountable official for Recovery Act activities. This individual should have responsibility and authority to coordinate across agency bureaus, program offices, and programs. It is recommended that the senior accountable official be at the sub-cabinet or Deputy Secretary level, and lead regular reviews of recovery planning, implementation, and performance. The senior accountable official should also designate a person or office for maintaining their agency’s Recovery Act content on their website. ”

“ As with the common government-wide risks, agencies are strongly encouraged to identify common agency risks and corresponding accountability objectives.
Agencies should determine whether final action has been taken regarding weaknesses or deficiencies disclosed by prior audits and investigations in program areas under which Recovery Act funds are authorized. If final action has not been completed, agencies should: (1) expedite such action to preclude the continuance of such weaknesses or deficiencies in the administration of Recovery Act funded programs ”

“ To deliver a website that allows citizens to hold the government accountable for every dollar spent, the law and guidance require Federal agencies to implement mechanisms to accurately track, monitor, and report on taxpayer funds.
More broadly, the guidance establishes requirements for various aspects of Recovery Act planning and implementation. These requirements are intended to meet crucial accountability objectives:
• Funds are awarded and distributed in a prompt, fair, and reasonable manner ”

“ The requirement that new TAFSs be created to record and report Recovery Act financial activity applies to both Division A and Division B of the Recovery Act. If an agency feels that establishing unique TAFSs will impose an extreme burden, will significantly delay funding allocations and awards, AND will negatively impact its ability to fulfill its reporting requirements under the Act, the agency can apply for a waiver from this provision. ”

“ Prime recipients and Federal agencies must establish mechanisms to meet Recovery Act data collection requirements. Agencies should work with prime recipients to ensure that DUNS and CCR requirements for first tier subawardees are met no later than the first time Recovery Act data requirements are due. • In the case where the Recovery Act requirement conflicts with an agency’s standard award term or condition, the agency’s award term or condition should be modified, as necessary, to ensure compliance with the Recovery Act requirement. ”

“ Starting on May 8th, agencies must begin submitting financial data for the population of Recovery.gov. Agencies will submit obligations and expenditures by TAFS, vendor, contact/grant/loan number, program, and other data elements [1] . Agency submissions will take place no later than eight work days after the end of the month. This will allow agencies time to complete their SF 224, FMS 1219/1220, and SF 1218/1221 reporting to FMS. Agency reporting on obligations and expenditures will show cumulative amounts through the fiscal year. ”

“ The Chief Human Capital Officers Act of 2002 provided new hiring authorities which, coupled with those that already existed, have the potential for dramatically improving agencies’ ability to get the right people in the right jobs at the right time. ”

“ To help establish a framework to facilitate accurate reporting from performing agencies to Recovery.gov, OMB will issue a bulletin that provides automatic apportionment authority for performing TAFSs. The bulletin will provide performing agencies with flexibility to incur new obligations within the parameters of their existing apportionments. However, performing agencies will need to use Category B projects to highlight obligations generated from Recovery Act funds. ”

“ Agencies need to assess existing processes for awarding formula allocations and announcing, evaluating and awarding discretionary grant opportunities to comport with the objective to make awards timely.
To enable timeliness of awards, agencies should engage in aggressive outreach to potential applicants to begin application planning activities, including the process for Central Contractor Registration (CCR) and obtaining a Dun and Bradstreet Universal Numbering System (DUNS) number. Outreach can also include efforts to update and validate existing CCR and DUNS registration data. ”

“ Grant-making agencies shall ensure that their recipients comply with Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and any program-specific statutes with anti-discrimination requirements. ”

“ Per Section 3.5 above, agencies will eventually be required to report on their risk mitigation efforts in these areas to OMB or the Board, including performance measures for the accountability objectives with associated performance ranges. If programs fall outside of what is considered to be an acceptable performance range, those programs should be required to explain why a shortfall exists and / or provide a corrective action or get-well plan. ”

“ Audits and investigation of Recovery Act funds occurring to identify wasteful spending and minimize waste, fraud, and abuse; 2. Qualified personnel overseeing Recovery Act funds; 3. Opportunities to use competitive awards maximized; 4. Timely award of dollars; 5. Timely expenditure of dollars; 6. Timely completion of planned work; 7. Cost overruns minimized; and 8. Improper payments minimized. 3.6 For risks that are common to all agencies, are there specific risk mitigation actions that all agencies must initiate? ”

“ Regarding the reporting requirements in 3 (d) , usual methods for reporting jobs created by a contract do not take into account the time frame over which the jobs are created. As a result, they are likely to be inconsistent with macroeconomic estimates of jobs created at a point in time. For this reason, departments and agencies should use conventional jobs estimates for internal planning purposes only. Uniform reporting requirements for estimates of job creation will be specified at a later time. ”

“ No. To maximize transparency of Recovery Act spending required by Congress and the Administration, agencies must not co-mingle Recovery Act funds with other funds in apportionment requests they prepare for OMB; SF 133 budget execution reports; or data feeds or reports they provide to Recovery.Gov. Within their financial systems, agencies must separately track apportionments, allotments, obligations, and expenditures related to Recovery Act funding.
Agencies in some cases may need to use Recovery Act funds in conjunction with other funds to complete projects. ”

“ The Grants.gov synopsis shall link to the full announcement on the agency website within thirty (30) days of enactment. In the interim, the synopsis should link to an agency instruction on when the full announcement is expected to become available. • Consider weighting selection criteria to favor applicants for assistance with demonstrated ability to deliver programmatic result and accountability objectives included in Recovery Act. ”

“ OMB will approve or disapprove an emergency collection of information within a reasonable time period, provided that such time period is consistent with the purposes of the PRA. An inconsistent time period is one that does not permit OMB to evaluate independently whether the proposed collection of information: • Is necessary for the proper performance of the agency functions ”

“ Agency plans will be due to OMB no later than May 1st. Agencies should work with their OMB representative to set an appropriate submission date and review process. Consistent with sound program management principles, each agency receiving recovery funds must develop formal documented plans for how the recovery funds will be applied and managed. ”

“ Part 5 requirements for pre-solicitation and award notices, publish pre-solicitation and award notices of orders under task and delivery order contracts on FedBizOpps; o Include special formatting for pre-solicitation and award notices in FedBizOpps and award reporting in the Federal Procurement Data System (FPDS) to distinguish Recovery Act actions; o Include terms and conditions in contract documents necessary for effective implementation of Recovery Act data collection and accountability requirements ”