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ARRA Policy

Title

AMERICAN RECOVERY AND REINVESTMENT ACT POLICY

Department

ADMINISTRATION AND FINANCE

Purpose

 

 

 

The American Recovery and Reinvestment Act of 2009 (ARRA) was signed into law on February 17, 2009. This policy addresses the accountability, transparency and compliance requirements related to the administration, expenditure, accounting and reporting of federal stimulus fund

Statement

 

 

 

 

 

 

 

 

 

 

Worcester State University’s Policies, Processes and Procedures have been reviewed for compliance with the American Recovery and Reinvestment Act of 2009, (Pub L. 111-5). Sources for guidance on implementation and oversight of ARRA are found in the laws, regulations, and the provisions of Office of Management and Budget (OMB), the U.S. General Accounting Office (GAO), Office of the Comptroller (CTR), and the Executive Office of Administration and Finance (ANF), as well as the Division of Higher Education guidance for all requirements in Titles XIV, XV, and XVI of Division A of the ARRA.

Description

 

 

 

Internal Controls related to the objectives and risks of handling ARRA funds have been established. In the WSU Internal Control Plan, see http://www.worcester.edu/teamsites/Policies/Wiki%20Pages/Home.aspx -Select Administration and Finance, then Select Internal Control Plan).

 

1.) Spending Plans for ARRA Funded Projects will have approved budgets by the Prime Recipient or the appropriate Federal Agency.

 

An additional level of review by the Budget Director, Procurement Director, ARRA    

Compliance Coordinator and Associate V.P. of Administration & Finance have been established to determine project eligibility under ARRA specifications, with approval by the Vice-President of Administration & Finance.

 

2.) ARRA awards and expenditure activities will be accounted for and properly recorded and allowable.

 

Typically, the federal stimulus transactions will be processed through the Commonwealth’s            MMARS financial system (Massachusetts Managements Accounting and Reporting System). Each CFDA number (catalog of federal domestic assistance) will be assigned a separate appropriation line within the MMARS financial system.  Worcester State College assigns a unique source code for each MMARS appropriation within the College’s Colleague Financial system. Information from MMARS is posted and reconciled to the Colleague Financial System providing an additional level of review. The Massachusetts Comptroller’s Office has established revenue source codes, program codes, receivable codes and location codes unique to the stimulus funds to assist in the segregation of funds.

3.) Reasonable assurance will be given that levels of effort are met.

 

Payroll is processed through the Commonwealth’s HRCMS payroll system (Human Resources Compensation Management System Information). Timesheets are collected for full time benefitted positions and the federally eligible students in the Federal Work Study program. The Office of the Comptroller has issued guidance on the stimulus funds in regards to the Commonwealth’s financial payroll system (HRCMS). In addition, the University complies with appropriate Federal funder requirements.

4.) Comply with all regulations, and performance and reporting requirements related to ARRA.

 

ARRA Coordinator and Associate Vice-President of Administration & Finance regularly  

check Commonwealth (Mass.gov and Comptroller) and federal (Office of Management and    Budget, General Accounting Office and federal awarding agencies) web sites for updates and  guidance.

 

5.) Ensure sub-recipient compliance with award responsibilities.

 

All contracts and purchase orders will include the Commonwealth of Massachusetts Contract Attachment. The key requirements clearly stated for each vendor and sub-recipient upon which the receipt of ARRA funding is conditioned. All bidders and contractors are checked for debarment. Vendors are primarily selected from state vendor approved lists such as the MHEC (Massachusetts Higher Education Consortium), and /or OSD (Operational Services Division). In addition, two notices were included with the ARRA contract attachment, Know Your Rights Under the Recovery Act, and How to Post Recovery Jobs.

 

6.) Funds, property and other assets are protected from unauthorized use or loss.

 

In compliance with the American Recovery and Reinvestment Act, and to insure that ARRA funded equipment can be accounted for and identified as such, all equipment will be coded within the Receiving Asset Module with the following block AARA.  A  Y/N for yes or no will allow us to query the data base, and identify that equipment purchased using ARRA funds, see Asset Management Via Facilities site: http://www.worcester.edu/teamsites/Policies/Wiki%20Pages/Home.aspx - Select Administration and Finance, then Select Facilities – Asset Management).

 

7.) Processes have been established for tracking, documenting and monitoring the progress of ARRA programs that will aid in the evaluation of ARRA program objectives, e.g., at the time reports on Federal awards are prepared.

 

ARRA Coordinator and Associate Vice-President of Administration & Finance regularly attend the weekly conference calls sponsored by the Comptroller’s Office for updates on implementation issues and coding requirement.  An ARRA shared drive has been established within the University that contains the information and updates on all ARRA projects.

 

 

8.) Quality Assurance Checklist will be prepared quarterly to monitor Award and Program Information, Vendor Reporting, and Sub-recipient vendor information for each ARRA funded program and per each sponsored agreement or grant. 

 

ARRA Coordinator will prepare the Quarterly reports in the ARRA Reporting Database and reviewed by the appropriate Supervising Department Head. Communication, documents, financial data and reports regarding stimulus funds will be saved electronically in a central location on Worcester State University’s share drive designated for ARRA.  Originals will follow established document retention of 6 years after final payment for a particular stimulus project or program.

 

Additional Information

 

Additional award guidance for each program may be found at the funder’s website. The following links provide guidance on the subject areas referred to above:

U.S. Department of Education’s “EDGAR” website link: [[|http://www.ed.gov/policy]]

OMB Circulars Link:  ttp://www.whitehouse.gov/OMB/circulars/

OMB Circulars Applicable to All Federal Awards:

A-21 Cost Principles for Educational Institutions

A-110 Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations

A-133 Audits of States, Local Governments, and Non-Profit Organizations

    *June, 2009 A-133 Compliance Supplement-*Updated annually

 

OMB Circulars Which May Impact Federal Awards

A-87  Cost Principles for State, Local and Indian Tribal Government

 

A-102 Grants and Cooperative Agreements With State and Local Governments

 

A-122 Cost Principles for Non-Profit Organizations

               

Regulations applicable to federal  funds include:

 

Federal Acquisition Regulations:   http://www.acquisition.gov/far/

 

5 CFR 1315  Prompt Payment Act: http://www.fms.treas.gov/prompt/regulations.html

 

Massachusetts Comptroller’s Office Related policies:

·         CMR 815 2:0  Grants and Subsidies

http://www.mass.gov/Aosc/docs/CTRInfo/Comptroller_Regulations/815/815-2_Grants.pdf

·         Federal grants and cost accounting procedures

o    Establishing a Federal Grant in MMARS

o    The Use of DUNS Numbers in Federal Grants

o    Cash Management Improvement Act and Automated Central Draw Policy

·         Contracts

o    State Grants and Federal Subgrants

·         Quality Assurance

Approved by

ELT

Approval Date

11-16-2010

 

Revised Date

 

 

 

Last modified at 12/19/2011 2:07 PM  by Hoxha, Anisa