On September 11, 2009, the Office of Management and Budget (OMB) issued its most recent guidance regarding implementation of Section 1512 of the American Recovery and Reinvestment Act of 2009 (the Recovery Act or Act), which requires recipients of Recovery Act funds to file detailed quarterly reports on their use of such funding. The OMB guidance identifies “essential actions” federal agencies must take in order to assist recipients in meeting the reporting requirements and deadlines under the Act, including providing targeted outreach and assistance to award recipients (such as telephone contacts, e-mail alerts, and webinars), providing additional resources to state and local government recipients, and identifying risk mitigation strategies to avoid the incomplete or inaccurate submission of recipient reports.

All prime recipients (and first-tier sub-recipients that have been delegated reporting responsibility by their prime recipient) must file their first reports at www.federalreporting.gov before the October 10, 2009, reporting deadline. Prior to filing reports, all reporting recipients must first register on the www.federalreporting.gov system. Detailed instructions on registration and reporting, including a downloadable User Registration Guide and a Frequently Asked Questions section, are now available.

Registration began on August 17, 2009, and the system will be available for the filing of reports October 1 – 10, 2009. Reports will be made available to the public on October 11, 2009, at www.recovery.gov. According to the OMB, recipient registration is below expected levels, which has raised concerns that many recipients are not prepared to meet the reporting deadline. Accordingly, entities that receive Recovery Act funds should be aware of the OMB guidance and may wish to take steps to register in advance of the October 1 reporting-start date in order to avoid last minute problems and inaccuracies in reporting.