Fall 2009 issue of Horizons

goods, unless the federal department or agency granting the funds waives this requirement because it would be inconsistent with the public interest, the product is not produced in America in sufficient quantities, or using American-made products would increase the cost significantly. If such a waiver is obtained, it must be published and include detail of why the requirement is being waived. Otherwise, if the project does not use American goods, then Recovery Act funds may not be used for construction, alteration, maintenance or repair. Finally, the Recovery Act funds will be available for use until September 30, 2010. There are some exceptions to this period of availability; those exceptions are provided in the Recovery Act fund agreements for each recipient and will be specifically communicated to the recipient. The Recovery Act also impacts the way the Single Audit is conducted for organizations receiving these funds. OMBviews theSingleAudit processasbeing themeans of testing whether the transparency requirements of the Recovery Act are being achieved. Additionally, when an organization receives Recovery Act funds, OMB places a heightened focus on internal control of the organization. Under Single Audits, auditees already have a requirement to test and report on internal controls, but with the Recovery Act this emphasis will be greater. For many recipients, controls in place before the Recovery Act funds were received will not be adequate for the large amounts of funding received under the act. Thus, actions will have to be taken before the Single Audit is conducted to ensure proper controls are in place for the Recovery Act funds. Also as discussed above, each of the Recovery Act funds will have to be tracked and identified separately in the Single Audit report, even if they are added on to an existing program. Some Recovery Act funds will be designated as high-risk funds and thus will have to be Impact on the Single Audit

The detailed list of projects should include the name of the project, description of the project, evaluation of the project completion, number of jobs created or retained, and, for infrastructure projects, the purpose, cost, rationale and contact for the project. These quarterly reports must be submitted within 10 days after the end of the calendar quarters. Additionally, all recipients and subrecipients of Recovery Act funds are required to register with the Central Contractor Registration Database (www.ccr.gov). In order to comply with these transparency and reporting requirements, recipients are required to track Recovery Act funds separately from other funds received even if the Recovery Act funds are received under the same grant or project. This separate tracking permits Recovery Act funds to be easily identified later when preparing the Schedule of Expenditures of Federal Awards. Even if the Recovery Act funds are received under a project with the same Catalog of Federal Domestic Assistance number as existing federal funds, the Recovery Act funds are to be reported separately. In addition to the transparency and reporting requirements discussed above, the Recovery Act specifies how the funds may be spent. It also regulates what Recovery Act funds can and cannot be spent on. The Recovery Act specifically establishes that funds may not be spent on gambling establishments, aquariums, zoos, golf courses or swimming pools. Additionally, according to the Recovery Act, Title XVI, funds should be allocated to projects that can be started and completed quickly. Title XVI states that at least 50 percent of the Recovery Act funds should be used on projects that can be initiated no later than 120 days from the date of enactment and on projects that maximize job creation. The Recovery Act funds are intended to stimulate the American economy and as such should be used to purchase American products. Construction projects must utilize American iron, steel and manufactured Permitted Uses of Recovery Act Funds

51 u fall 2009 issue