On Monday, OMB released new guidance for the reporting of stimulus-related projects. After reading the document, I walked away with two thoughts - "State governments will be buried under the weight of this," and "The job calculation situation is a nightmare waiting to happen." While we knew that states would be required to report on their own activity as well as the local entities that receive money, this new guidance adds a new layer of complexity. Starting in October, states (e.g. "prime recipients) must track dollars down "to the street", from their door to the "sub-recipient" to the sub-recipient's vendors.

After quickly celebrating new rules that provided them with funds to cover the administrative and management costs of stimulus activities, states now face another set of challenges. Reporting requirements at the prime recipient level will undoubtedly flow down to S&L vendors, who as implementers, will bear a fair amount of the burden.

Some of the required data elements:

This last item also presents a challenge. OMB directs recipients to divide the number of hours work on stimulus projects by the total number of hours in a full-time schedule to come up with recovery-related FTEs. For example, if there are 480 hours in a quarter and an employee works 240 hours on stimulus work, that represents .5 FTE. The calculation for determining jobs created or saved seems fairly simple on the surface, but this could get a little sticky if:

a) a vendor's employee is working on multiple projects and must track stimulus time separately

b) stimulus money partly funds a stimulus project, which makes it difficult to attribute job creation to stimulus vs. non-stimulus activities

Federal contractors - this guidance does not apply to you, but your day is coming. Final FAR rules for recipients of Federal contract awards directly from the Federal government are pending.

OMB's guidance also provides step-by-step instructions for submitting the required information. I'm thinking that detailed instructions on how to collect the data requires much more detail than how to submit it. The silver lining: prime recipients may actually create more jobs to manage and report stimulus data than to complete the actual projects.