Posted on February 23, 2009 10:15 PM
OMB Initial Guidance (2/24/09)
On February 18, 2009, the federal Office of Management and Budget released initial guidance on implementing the American Recovery and Reinvestment Act to federal agencies. The memo is available online. It emphasizes that the specific intent of the recovery plan – to strengthen the economy – must be kept firmly in mind in its implementation. Although the memo is meant for use by federal agencies, some information is relevant for other organizations (particularly potential applicants), including:
- Federal agencies will post synopses of funding announcements to www.grants.gov within 20 days of the law’s enactment, and will have full grant announcements posted within 30 days (p. 33 of the document).
- Federal 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” (p. 21). CMAP recommends that potential applicants for recovery plan funds ensure that their federal profiles are complete and up to date.
- Prime recipients of recovery plan funding have specific reporting requirements, but subrecipients of funding do not. “For instance, a grant could be given to the Federal government to State A, which then gives a subgrant to City B…State A is the prime recipient, and would be required to report the subgrant to City B. However, City B does not have any specific reporting obligations…for the purposes of reporting for the Recovery.gov website,” (p. 14-5) although reporting requirements for existing federal programs must continue to be followed. However, it is possible that reporting requirements may be put in place by the state to facilitate the reporting that they must do.
- States and other direct recipients of funds must provide “an estimate of the number of jobs created and the number of jobs retained,” and for infrastructure, “the purpose, total cost, and rationale of the agency for funding the infrastructure investment” with recovery funds (p. 15). While reporting on job creation is mandatory, the document indicates that standard methods of calculating job creation are not appropriate in this case, and “uniform reporting requirements for estimates of job creation will be specified at a later time” (p. 16). CMAP places a high priority on being able to accurately assess and report the benefits of projects undertaken with recovery plan funds, and will be closely tracking guidance on this matter.
- The expenditure of recovery plan funds should be “fully transparent to the public,” (p. 16) but the document recognizes that not all agencies have user-friendly reporting systems. CMAP intends to assist in providing this transparency by tracking projects using methods like the recently-developed interactive TIP mapping system.
- Federal agencies are encouraged to prioritize projects that promote the goals of the recovery plan, using evaluation criteria such as job creation and retention (p. 32). They may also prioritize funding for applicants who show the ability to “deliver programmatic result and accountability objectives” (p. 21). In other words, applicants who can demonstrate that their projects are in line with the recovery plan’s economic objectives – and that they have the ability to measure outcomes – will improve their chances of receiving funding.