OMB Guidance on reporting FHWA ARRA funds by project, not award

We all know that the 1512 reports are to be filed by award, right? Not so fast, says DOT. They want funds reported by project, not award. So what to do? An e-mail was sent out by DOT this morning to clarify the reporting. It basically says that the DOT rules are not inconsistent with OMB's guidance, so follow the DOT rules for those grants. Here is the actual language:

Subject: INFORMATION: OMB Concurrence with FHWA 1512 Guidance

Good Morning: David Winter of the US Department of Transportation has forwarded the following information concerning Federal Highway Administration grants and OMB Section 1512 guidance. The below information is from John Pasquantino of the US Office of Management and Budget and is resultant of several calls between the Secretary of the Department of Transportation and OMB. The concerns center on using the Federal-aid project as the identifier for the 1512 Award, and subsequently providing the total federal obligations and total ARRA obligations for the Award Amount and Total Federal Amount of ARRA Funds Received respectively. Questions on this matter can be addressed to David at:

David R. Winter, P.E.
Director, Office of Highway Policy Information
Federal Highway Administration
david.winter@dot.gov
(202) 366-4631

OMB has provided the following information in relation to this issue.

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FROM: John Pasquantino, Office of Federal Financial Management, Office of Management and Budget

OMB’s guidance broadly provides Federal agencies and recipients with a framework for meeting reporting requirements of Section 1512 of the Recovery Act. To provide more detailed application of general guidance, Federal agencies under OMB guidance are to develop and issue supplemental guidance tiered to the OMB guidance. Recipients are to look to the Federal agency supplemental guidance for additional detail and guidance on reporting for awards made through the programs administered by that Federal agency. Should questions arise regarding whether to apply the overall guidance or the Federal agency supplemental guidance, recipients should generally comport their responses with the Federal agency supplemental guidance except in cases in which the Federal agency supplemental guidance explicitly contradicts OMB guidance. In general, recipients are encouraged to work with their awarding Federal agency to address any questions regarding applicability of guidance. In this case, we have reviewed FWHA supplemental guidance and have found it to be not inconsistent with broad OMB guidance.