The requirements of funding allocated under the Stimulus Act( the American Recovery and Reinvestment Act of 2009) impose significant and unusual reporting obligations on researchers. In addition, the Recovery Act mandates an unprecedented amount of federal scrutiny on project progress and sponsored program expenditures. Failure to comply with agency terms will pose significant risk of disallowance and reflect negatively on the reputation of the University.
The UAA Grants and Contracts staff is ready to help clarify ARRA requirements so they can be appropriately identified and proactively managed. On-going ARRA informational updates will be provided to the Principal Investigators and their support staff by Grants and Contracts.
ARRA requirements are listed on the Notice of Grant Award (NOGA) and are available on each federal agency's Recovery website. Principal Investigators are responsible for ensuring full and timely compliance with all of the restrictions and obligations imposed by their ARRA awards. While assistance in meeting these requirements should be sought from Grants and Contracts staff, the ultimate responsibility must rest with Principal Investigator directing the project. Please carefully review the additional obligations imposed for ARRA awards. If at any time you have questions regarding the terms of an ARRA award or concerns about compliance, please contact your UAA grant coordinator for assistance.
UAA has established a procedure to completely segregate ARRA sponsored expenditures from non-ARRA funds.
- Note: ARRA awards (including supplements) will be set up by UAA as new Grants/Funds in Banner Finance. The fund numbers assigned will be 252XXX.
- ARRA funds will never be co-mingled with non-ARRA sponsored funds or other funds.
- The work and expenses on regularly-funded parent grants and ARRA supplements must be kept entirely separate–unlike most supplements on sponsored projects.
- All costs must directly benefit the ARRA-supported activity. If the cost is not charged 100% to the ARRA-supported activity, the basis for allocating costs among two or more benefiting activities must be clearly documented in the department’s project file or on the transaction itself.
Keep ARRA expenditures closely aligned with agency-approved budgets and statement of work.
- Read your Notice of Grant Award and award documents carefully. Special individual award terms may apply.- Expend funds according to the award budget. Budget changes permitted by the awarding agency may still occur but each deviation from the approved budget must be clearly documented. We recommend updating the project file at the time of the change describing why the alteration in the budget was required.
- Obtain agency prior approvals when needed. When in doubt, err on the side of caution and obtain a prior approval or consult with Grants & Contracts. Remember that UAA Grants & Contracts must countersign agency prior approval requests.
Spend all ARRA funds timely. We are being evaluated on our “burn rate”.
- Initiate work and associated expenditures promptly after receipt of the award. Pursue progress on all ARRA awards as vigorously as possible consistent with proper stewardship and good scientific practices. Agencies will be closely monitoring “burn rates” and may withdraw funding if they determine progress is unsatisfactory.
- Monitor expenditures carefully as carryover of unexpended funds will not be permitted unless specifically approved by the funding agency.
- Report unanticipated delays (e.g., when progress is significantly impacted by a month or more) on ARRA awards promptly to UAA Grants & Contracts, who will determine if agency notification is required.
Ensure that all compliance approvals are kept current and that work performed is completely and accurately described in your approved protocols.
- Ensure any necessary protocol submissions or modifications are filed and approved in a timely manner to avoid project delays. Be certain there is evidence of any sub-recipient’s compliance approvals, or that they affirmatively inform you that their approvals have been obtained before work begins. Retain such documentation in the Grants & Contract official project file.
Promptly fulfill all special and routine reporting obligations including regular technical reporting.
- Assist with the mandatory Section 1512 ARRA Quarterly Reporting on jobs created or retained, confirm the percentage of project completion and provide a 2,000 character, or less, Quarterly Project Activity Description. Every effort is being made to do this required reporting centrally but Principal Investigators should plan to respond promptly when information is requested by the UAA Grants & Contracts staff.
- Submit all technical progress reports on-time. Report due dates will be listed in your NOGA.
- Respond promptly to UAA Grants & Contracts requests for expenditure verification to enable timely financial reports and reimbursement requests.
Certification Form For American Recovery and Reinvestment Act Funding
- Originating department will e-mail to Procurement Services a Certification Form for American Recovery and Reinvestment Act Funding when issuing a purchase requisition to a single vendor from whom we purchase materials/goods with a value in excess of $25,000.00 or when initiating a purchase requisition to a consultant for services in any dollar amount. UAA account codes requiring this certification for professional or consulting services would be 3005 Professional Fees-Other 3007- Short Term Educational Services 3011 Consulting/Engineering Costs, 3013 Architect/expenditures and 3016 Legal Fees
- Principal Investigators or their support staff will advise vendors or consultants in discussing their participation in this project that the funding source will require them to comply with this extra ARRA reporting requirement.
- This job reporting requirement is a quarterly ARRA Section 1512 element. We must gather this information each quarter that the vendor or consultant is participating in the project.
- Procurement Services will be responsible for checking the Excluded Parties List System (EPLS) to certify that the vendor or subawardee is eligible to do business with the federal government.
- Vendor questions on how to fulfill this requirement can be forwarded to UAA_Contracts@UAA.ALASKA.EDU.
Subaward Agreement use FDP Attachment 4A Form
If a Subaward will be issued to another entity to perform a portion of the ARRA funded grant, UAA will use the form developed by the Federal Demonstration Partnership.
ARRA Subaward Agreement Attachment 4A
Excellent Resources for Faculty and Staff:
National Science Foundation
Agency Recovery Web Sites