Grants Accounting

American Recovery Reinvestment Act (ARRA) Procedures

(Revised May 19, 2010)

There are significant new requirements for awards funded by ARRA. These include:

Section 1512 Reporting, which requires quarterly reports within ten days of the
close of each quarter.

  • Since OMB defines ARRA funds as higher risk, A-133 audit will include additional
    compliance requirements.  No extensions for single audit submissions will be granted
    through 2011.
  • For awards to construct or repair public building or public works, the following provisions
    • Davis-Bacon wage rate requirements apply to contracts over $2,000
    • “Buy-American”  - all materials purchased must be US produced or manufactured,
      unless qualify under the following exceptions:
      • Non-availability due to materials not produced in the US in sufficient and
        reasonably available quantity and of sufficient quality
      • Unreasonable cost – increasing the cost of the overall project by more
        than 25%
      • Inconsistent with public interest

Initial Banner Set-up

As part of the RANF process, the term “ARRA” will be added to the Banner Grant Code and
Fund Code description to identify that the new award is made under the ARRA and ensure
no commingling of ARRA funds with non-ARRA activity.  A list of ARRA awards can be
readily compiled from Banner form_FRIGRNT.

Section 1512 Reporting Guidelines

These guidelines apply to prime recipients of ARRA funds and could also apply to “first-tier”
sub-recipients if the prime recipient has delegated reporting responsibilities.

Principal Investigator (PI) responsibilities include:

  1. Identification of status of project
    • not started
    • less than 50% completed
    • more than 50% completed
    • completed.
  2. An abstract or summary of the project in no more than 2700 characters

The assigned Grant Accountant will provide:

  1. The total amount of ARRA funds under the award
  2. The amount of ARRA funds received that were obligated and expended
  3. The amount of unobligated award balance
  4. Calculation of jobs created or retained
  5. For any subaward > $25,000:
    1. the name of the entity to which the subaward was issued
    2. the amount of the sub-award
    3. the transaction type (fixed price v. cost reimburseable)
    4. the CFDA (presumed to be the same as the direct award)
    5. a unique identifier for the sub-ward entity (and its parent entity if
    6. Jobs created or retained

In addition, Grants Accounting is responsible for the quarterly submission according
to the following schedule:

By the last day of the quarter end, the assigned Grant Accountant will e-mail a request
to each PI who is a prime recipient of an ARRA award to obtain the aforementioned PI’s

  • By the last day of the first week of the reporting month, the Senior Grants Accountant
    assigned to ARRA reporting will compile all of the required information
    and send to Associate Controller for review by the 7th of the month.
  • The Associate Controller will review and approve the spreadsheet and prepare
    for upload on behalf of the Controller.
  • Compare quarter end financial reporting (such as NSF’s FFR) to ARRA report to ensure
    consistency and reconcile any significant variances.

The Controller’s office is the only unit registered to submit Section 1512 reports under the ARRA
centralized electronic reporting system.  The Controller will complete the ARRA entry.  See file: L:\Grants\ARRA\Quarterly Procedures for specific details.

For those grants where GVSU is a “first-tier” sub-recipient of ARRA funds, the PI will be responsible
for completing the information requested by the prime award.  A copy will be requested by the
assigned Grant Accountant for review and internal filing.

Grants Accounting will maintain a hard copy file of all quarterly report information.

Other Important ARRA Information

Whistleblower Protections

Recovery Act Fraud Hotline

Page last modified November 2, 2016