On October 10, 2009, the first electronic reports will be due to the federal government regarding the receipt and use of funds under the American Recovery and Reinvestment Act of 2009 (ARRA). The federal government will disclose the information from these reports to implement the Obama administration’s commitment to informing the public about the distribution and use of ARRA funds.

The reporting requirements apply to any company (subject to some de minimis exceptions) that is a prime recipient or sub-recipient of funds, grants, awards, or federal contract moneys under an ARRA program and also to any contractor receiving ARRA-designated funds under a government contract. Click here to see a list of the ARRA programs. For government contracts, the Federal Acquisition Regulation (FAR) has been amended to incorporate these reporting requirements.

Although the first reports are not due until October 10, 2009, reporting obligations apply to any ARRA funds received, awarded, or invoiced after March 31, 2009. The October 10, 2009, report will be a "catch up" report for the quarterly periods of April 1 to June 30 and July 1 to September 30, 2009. Thereafter, the reports will be due quarterly by the 10th day after the end of each quarter. The reports will be submitted electronically via the www.federalreporting.gov Web site, which is not yet operational.

Ballard Spahr is available to help you determine whether these reporting obligations apply to your company and, if so, to assist you in preparing for these reporting obligations. It is important to prepare for this before the October 10, 2009, deadline because the information to be provided, while routine, can be significant. You may need to identify whether there are any sub-recipients of these funds (they have reporting obligations to you) and may need to obtain DUNS or CCR numbers and register on the reporting system.

If you have questions, please feel free to contact Mary J. Mullany at 215.864.8631 or mullany@ballardspahr.com.


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