As was identified in the Knight Center of Digital Excellence’s “A stimulus workshop debrief: Part two,” a big part of proving your program worthy of stimulus funding is proving it will be compliant with requirements set forth in the American Recovery and Reinvestment Act (ARRA).

At stimulus workshops across the nation, government representatives stated that compliance monitoring and reporting would play a crucial role in setting a standard of transparency and accountability to funding applicants. Clearly, the government is taking this issue very seriously.

In short, a compliant program will meet the deadlines stated in its application and use money as indicated. During the second review of proposals slated for the end of September, a separate compliance team will review proposals for compliance issues. Additionally, Program Officers have already been hired and placed in the field to monitor and provide oversight for specific programs.

What will I need to report?

According to the Office of Management and Budget’s (OMB) guidance document, recipient reporting required by Section 1512 of the ARRA will answer these questions:

• Who is receiving funding and in what amounts?
• What projects or activities are being funded?
• What is the completion status of these projects and activities?
• What impact have projects and activities had on job creation and retention?

Prime recipients, identified by the OMB as state governments, are required to provide quarterly reports, which will be published publicly. Reports should contain the total amount of funding received, how much has been spent on projects and activities to date, a list of projects including answers to the final two questions stated above and details on sub-awards and other payments.

Broadband Initiatives Program (BIP) and Broadband Technologies Opportunity Program (BTOP) recipients must also report information on a quarterly basis, though required information varies depending on the project type. Consult the stimulus workshop workshop’s compliance presentation for more information on the specific requirements for Infrastructure, Public Computer Center and Sustainable Broadband Adoption reporting.

What will happen if my program is not compliant?

According to BroadbandUSA, the penalties for non-compliance are many. Some of the major penalties include:

• Suspension of payments or the entire award itself
• Termination for cause or convenience
• Debarment and suspension
• Deobligation

Compliance issues WILL play a major role in determining whether projects receive requested funding or not. When looking at your program, ask yourself these questions: Have I built a sustainable model that will last well after the funding ceased in two or three years? Is it already in place?

Keep in mind that the documentation is out there to guide you through the proper steps. Be sure to follow it. If you have questions, play close attention to updates on BroadbandUSA or e-mail us at info@knightcenter.org.

Tags: American Recovery & Reinvestment Act 2009, BIP, broadband, Broadband Initiatives Program, broadband stimulus workshop, Broadband Technologies Opportunity Program, BroadbandUSA, BTOP, compliance, compliance issues, compliance reporting, debrief, digital, infrastructure, Internet, KCoDE, Knight Center of Digital Excellence, Office of Management and Budget, OMB, Program Officers, public computer centers, Section 1512, state government, stimulus, stimulus watch, sustainable broadband adoption