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3.20 The American Recovery and Reinvestment Act of 2009

Delegation of Reporting Requirements under the Recovery Act

For all Federal programs identified in Section 1512(c) of the Recovery Act, the direct recipient is responsible for reporting on funded activities and projects at

  • However, the direct recipient may choose to delegate certain reporting responsibilities to the subrecipient with a subaward of $25,000 or more for those data elements related to subrecipient activities.
  • As direct recipient, you must clearly communicate the details of the delegation and closely monitor reporting to avoid mistakes or double counting (i.e., separate reporting by the direct recipient and the subrecipient on the same activity).
  • The direct recipient should design and implement a process and policy for reporting (including delegation of reporting) through The process and policy will help to minimize potential reporting errors and mistakes.
  • Make sure that any policy developed clearly identifies which user (prime or subrecipient) is authorized to correct data after first submission.