Just when we thought that the ARRA reporting requirements couldn’t get more intensive and despite the fact that over 80% of the Recovery Act funds have already been spent, an interim rule to change FAR clause 52.204-11 went into effect July 2nd requiring first-tier subcontractors with awards above $25,000 to report on job creation and retention. This new provision will apply only to awards issued after July 2, 2010. Although the rule requires subcontractors to capture the job data and report, prime contractors should be aware of the provision as they are responsible for flowing this requirement down to its first-tier subcontractors and submitting their subcontractors’ data to FederalReporting.gov.
Additionally, prime contractors will now be required to file reporting for new ARRA contracts within 10 days of the end of the quarter in which the contract is awarded, as opposed to the first quarter in which the contract is invoiced. The interim rule is open for comments through August 31, 2010. Welcome to the Brave New World – next stop, DNA samples?
DON’T FORGET, YOUR ARRA REPORTING FOR APR-JUN IS DUE JULY 10th!
As part of Phase II of its Goldstar Initiative, GSA will be issuing mandatory modifications to ALL Schedule Contracts on June 24th to baseline its contractors’ current terms and conditions, along with negotiated exceptions. This process will be much more onerous then a standard mandatory modification. It is extremely important to read the instructions and complete the modification carefully.
The Administration raised the stakes for contractors or grantees that receive stimulus funding but fail to file the required reports. The American Recovery and Reinvestment Act requires quarterly reporting but did not include consequences for those recipients who fail to submit reports. During the last calendar quarter of 2009, more than 1,000 recipients failed to file reports, most of them grantees as opposed to contractors.
On April 6, 2010 President Obama directed Executive Agencies to use every means available to ensure that every recipient of stimulus funds has filed the required reports. The agencies must intensify their efforts to ensure compliance by terminating awards, pursuing suspension and debarment, reclaiming funds, and initiating other punitive actions whenever authorized and appropriate. Agencies are also required to report the names of non-compliant recipients to the Office and Management and Budget (OMB)along with the actions the agency is taking to obtain the reports. OMB also has 30 days to provide agencies with additional guidance on how to handle non-reporting recipients.
It was presumably good news when your organization received some of the stimulus money. Do not turn good news into bad news by failing to file the required reports.
Now that the second quarter of FY10 (or the first, depending on who you ask!) has officially ended, it is time for contractors to start preparing and submitting reporting required under their Federal contracts. Three of the most important upcoming deadlines include:
Follow the hyperlinks above to access the reporting sites. If you have any questions about your reporting requirements or the reporting process, try searching FedPoint or contact Aronson & Company directly for guidance.