On February 17, 2009, the President signed into law the American Recovery and Reinvestment Act of 2009.  President Obama, Governor Paterson and State Comptroller DiNapoli have made it clear that every taxpayer dollar spent on economic recovery must be subject to unprecedented levels of transparency and accountability through periodic reporting and publication on a special website developed specifically for this purpose.  The Act includes specific requirements in support of these objectives that all State agencies receiving recovery funds must be aware of.

This Bulletin transmits OSC accounting requirements for programs and activities, appropriations, fund and subfund accounting, journal voucher, and voucher preparation related to funding provided in the American Recovery and Reinvestment Act of 2009.  OSC intends to closely monitor voucher payments and journal voucher(s) charged to Recovery Act appropriations to ensure complete accountability, reporting and effective and efficient use of Recovery Act funds.

At this time, the list of Recovery Act funds allocated to NYS can be found at:
http://www.economicrecovery.ny.gov/DirectAid/aidnewyork.htm.

This listing, and any future additions, will be used to establish minimum reporting requirements for programs and subprograms financed with Recovery Act funds. This listing is expected to be updated as more information becomes available so State agencies are encouraged to visit this website for updates.

This Bulletin will be amended from time to time as more information becomes available.

All Journal/Revenue Transfers, Reports of Monies Received, and Budget Certificates sent to OSC for processing must be clearly labeled ‘ARRA’.  Supporting documentation must be attached to these documents.  This will allow OSC to priortize the review and processing of these documents.

To maximize transparency of Recovery Act spending required by Congress and the administration, agencies must not comingle Recovery Act funds with other funds in data feeds or reports they provide to Federal or State government agencies responsible for collection of data associated with the use of Recovery Act funding.   

At this time, we understand that Federal agencies intend to assign unique grant award numbers to Recovery Act allocations.  Federal agencies have been advised that supplements to existing award agreements are not recommended as there is a greater risk that the grant recipient will be unable to track and report Recovery Act funds separately.

Reporting Requirements on Use of Funds

The following information relates to reporting requirements of State agencies who will receive further information from their Federal grantor agency(s).

As required by Section 1512 of the Recovery Act, not later than 10 days after the end of each quarter, any entity that receives recovery funds from a Federal agency, is required to report to that agency the following data elements:

1. The total amount of recovery funds received from federal agencies;

2. The amount of recovery funds received that were obligated and expended to projects or activities. This reporting will also include unobligated balances to facilitate reconciliations to grant authorizations.

3. A detailed list of all projects or activities for which recovery funds were obligated and expended, including--

• The name of the project or activity;
• A description of the project or activity;
• An evaluation of the completion status of the project or activity;
• An estimate of the number of jobs created and the number of jobs retained by the project or activity; and
• For infrastructure investments made by State and local governments the:
  • Purpose
  • Total cost
  • Rationale of the agency for funding the infrastructure investment with funds made available under this Act, and
  • Name of the person to contact at the agency if there are concerns with the infrastructure investment.

4. Detailed information on any subcontracts or subgrants awarded by the recipient are to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 (P.L. 109-282), which allows for aggregate reporting on awards below $25,000 or to individuals, as prescribed by the Director of OMB.

A new website has been created to provide citizens with information on the uses of recovery funds.  State spending of Recovery Act funds will be reported (by State agencies) to the Federal grantor agencies and used to update the information on Recovery.gov.  Agencies should periodically check http://www.recovery.gov and other websites noted below to keep abreast of implementation guidance and details about the reporting requirements that will be released by the Federal Government in the coming weeks.

Some of the stated goals of the Act are to establish rigorous internal controls, oversight mechanisms, and other approaches to meet the accountability objectives of the Act and to enhance, as necessary, standard processes for overseeing and awarding grants to meet the very tight timeframes to finance and report-on the progress of recovery initiatives.  To this end;  and to facilitate the complete, accurate and timely reporting of grant funds made available under the Act, the following guidelines for appropriation accounting and control will be adhered to:

• Recovery Act funds must be tracked and accounted for separately. 
• State appropriations will be established using the program naming convention found in appropriation bill copy.
• Segregation records will contain the federal program name as it appears in the American Recovery and Reinvestment Act of 2009 (H.R. 1). 
• To ensure that all awards provided by the Recovery Act are clearly distinguishable from non-Recovery Act awards in the State’s Central Accounting System, distinctive appropriation records will be established and used to ‘track’ spending from such awards.  OSC will use special identifiers (activity code) in the appropriation record to satisfy many of the selection and reporting requirements of the Act. 
• Special appropriation records will be established pursuant to allocations from existing federal fund appropriations and reappropriations or new appropriations, as appropriate.
• Interchanges, transfers, and suballocations affecting Recovery Act appropriations will be reviewed carefully by DOB and OSC staff to ensure that the reporting requirements of the Act are preserved.
• Agencies that administer Recovery Act funds are expected, to the extent practical, to charge voucher payments to appropriations financed with Recovery Act funds in the first instance and must make every effort to abstain from charging such payments to State funds for later transfer to federal fund Recovery Act appropriations, or vice versa. 

• For those awards that are financed through central drawdowns (from the US Treasury) initiated by OSC staff, existing fund/subfund accounting protocols will remain in place.
  • For awards that require supplemental information (e.g. project level detail) not presently available in the Central Accounting System, agencies will continue to initiate their own drawdown requests in accordance with all cash management rules and regulations prescribed in the Single Audit Act and the Cash Management Improvement Act.  New Federal Fund subfunds will be assigned where needed, to account for agency spending and financing activities related to Recovery Act appropriations.

   

Vouchers

As noted above, a fundamental aspect of the Recovery Act is accountability and transparency through frequent reports that will be published on State and Federal websites.  In order to preserve the integrity of reporting of payments made to grant recipients and to uphold the stated objectives of the Act, it is necessary that all Central Accounting System payments made from Recovery Act appropriations be tracked and reported for each payee.  To this end, the following rules are prescribed for vouchers that, in whole or in part, charge payments to Recovery Act funds:

• One to One - One Payee per Voucher with one expenditure line.  

OR

• One to Many - One Payee per Voucher with two, or more, expenditure lines.  

OR

• Many to One – Multiple payees may be paid on a single voucher provided that one, and only one, expenditure line exists. 

Vouchers containing multiple payees with multiple expenditure lines (Many to Many) are NOT permitted and will require separate vouchers using one of the prescribed rules above.  The following are examples of situations that would fall into this prohibited category:

• School districts scheduled to receive Recovery Act payments under more than one program (i.e. Title I and IDEA/Special Education programs).  Two vouchers would be required under the ‘many to one’ rule or if separate vouchers were prepared for each payee, then the ‘one to many’ rule would apply.
• Several counties receiving monies from a Recovery Act funding source and a non-Recovery Act funding source (i.e. split charges to more than one fund/subfund).  Two vouchers would be required under the ‘many to one’ rule or if separate vouchers were prepared for each payee, then the ‘one to many’ rule would apply.

New Statewide Indicator for Recovery Act Payments

To facilitate the processing and reporting of Quick Pay and Non-Quick Pay voucher payments financed with federal Recovery Act funds, it is necessary that all such payments contain the value of ‘U’ in the Indicator-Statewide field on all vouchers submitted for payment.  The use of this indicator will facilitate identifying payees receiving Recovery Act payments.  The Indicator-Statewide field is located in the Payee Reference block in the top of the voucher.

Agencies that bulkload vouchers must ensure the “U” Statewide Indicator is included in all Recovery Act payment transactions. 
Note: The “Indicator-Statewide” is a five position alpha-numeric field.  Up to five one-position codes can be entered. The ‘U’ code can be entered in any of the five positions.  The use of the ‘U’ statewide indicator is in addition to other OSC-prescribed uses of the statewide indicator field as provided in the following bulletins:

If a voucher requires special or expedited processing as a result of the payment charging a Recovery Act appropriation, an email should be submitted to the mailbox STEXPEND@osc.state.ny.us.  This email message should contain the action needed and the reason for such action.  State Expenditures staff will facilitate your request and provide you an update on the result.

Recovery Act reporting requirements include a provision for reporting the name of payees and grant subrecipients that receive payments from State appropriations financed with Recovery Act monies.  Therefore, except for Medicaid payments to the State’s fiscal agent, FMAP adjustments, fringe benefit payments, transfers to other funds representing administrative recoveries or cost allocations, travel and procurement card payment adjustments, rare instances of coding error corrections, and very few other exceptions as approved by OSC, the use of journal vouchers to charge expenditures against Recovery Act appropriations is prohibited and will be strictly enforced by OSC staff.  

Object code 36008 has been reserved to account for all federal grant monies received for Recovery Act programs.  This revenue object code must be used on all Reports of Monies Received and Journal/Revenue Transfers processed into the Central Accounting System. 

Procurement and Disbursement guidelines for ARRA-funded contracts and payments will be issued separately.  State agencies are encouraged to check the Comptroller’s website for additional news that will be released as ‘G’ bulletins.

http://www.osc.state.ny.us/agencies/gbull/index.htm

Questions

Please direct questions about this bulletin as follows: