Improving Compliance in Recovery Act Recipient Reporting

It appears that OMB is serious about the ARRA recipients who have still not filed their 1512 reports. Memorandum number M-10-05 was issued on November 30, 2009, and relates to "a number of recipients [who] have not filed as required by Section 1512 of the Recovery Act and OMB guidance."

Are they serious about enforcing the reporting requirements? Well, there is some serious sabre-rattling, at least. Recipients not in compliance with reporting requirements "are subject to Federal action, up to and including the termination of Federal funding or the ability to receive Federal funds in the future." Terminating their ability to receive federal funds in the future might well be a serious enough threat to get these people to submit their reports. We shall see.

The memo instructs federal departments and agencies to identify their recipients that are noncompliant, then contact these recipients and either determine why they did not comply and help them do so, or both. Then they are to assess the severity of the situation and determine what action, if any, needs to be taken. In the case of fraud, the appropriate action may be criminal in nature.

So if a recipient has not completed the required 1512 reports, the feds have been told to go after him. Sounds like the OIGs may be busy!