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ARRA - Use of Funds Reporting Guidelines 
Through our regulatory consulting partners, Wilkinson, Barker, Knauer, LLP, we understand there is now some guidance as to how the government will bring transparency to ARRA fund disbursement.

The Office of Management and Budget (OMB) on June 22 issued a memorandum outlining the reporting on use of moneys distributed from the ARRA pool of funds. This has implications on all loan and grant recipients as well as to their contractors and vendors.

Rather than try to dissect the entire document, service providers should download the OMB memorandum and consult with grant writers, legal & regulatory counsel and financial advisors. It is somewhat extensive and provides guidance on reporting fund distribution granularity (i.e. who gets ARRA funds and how much do they receive), the reporting process (fulfilled through http://www.federalreporting.gov/) and the reporting schedule (quarterly with very specific dates). In addition, the document also provides general guidelines on reporting the number of jobs created or retained as a result of the ARRA investments.

‘Government transparency’ has been a catch phrase of the Obama administration from the beginning. It appears that transparency is being extended to ARRA recipients as a condition of award. This may be a small price to pay for the intended benefit of local job creation, broadband expansion and rural development.

It is recommended that service providers review this memorandum and share the implications with your perspective contractors, indirect fund recipients and vendors. Let us know what you think about the reporting guidelines and what this means to you.


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