Sorry, folks... I made a mistake. I missed a whole page of the cited FR, and indeed, in Item 3-11of the Elements, it does cite the five most highly compensated officers.
Mea Culpa...
Maggie
On Tue, Jun 23, 2009 at 1:14 PM, Maggie Griscavage <xxxxxx@alaska.edu> wrote:
I just revisited the Fed Register release (Federal Register / Vol. 74, No. 61 / Wednesday, April 1, 2009 / Notices) about Reporting on Grants, Cooperative Agreements and Loans, and there doesn't appear to be any reference to reporting on salaries for the top five (see "Data elements" column) - isn't this just a requirement for "contractors?" And, yes, we might be a prime contractor, eventually!!
Maggie
On Tue, Jun 23, 2009 at 10:14 AM, Bloomberg, Robert <xxxxxx@tuftsmedicalcenter.org> wrote:
Bob,
The requirement to report by recipients (as well as subrecipients) is #17 on the list I’ve reprinted below.
The Call for Comments text you cite qualifies/limits who has to report on the compensation, and I’d seen that before. But the new guidance does not seem to include or refer to those qualifications. So, is the requirement now universal?
Thanks.
Bob
______________________________________________________
Required Data:
The specific data elements to be reported by prime recipients and sub-recipients are included in the data dictionary contained in the Recipient Reporting Data Model. This document will be published on OMB’s website and www.Recovery.gov as supplemental materials to this Guidance. Below are the basic reporting requirements to be reported on prime recipients, recipient vendors, sub-recipients, and sub-recipient vendors. Administrative costs are excluded from the reporting requirements. The basic reporting requirements below may contain multiple data elements as defined in the data dictionary.
Prime Recipient
1.
Federal Funding Agency Name
2.
Award identification
3.
Recipient D-U-N-S
4.
Parent D-U-N-S
5.
Recipient CCR information
6.
CFDA number, if applicable
7.
Recipient account number
8.
Project/grant period
9.
Award type, date, description, and amount
10.
Amount of Federal Recovery Act funds expended to projects/activities
11.
Activity code and description
12.
P roject description and status
13.
Job creation narrative and number
14.
Infrastructure expenditures and rationale, if applicable
15.
Recipient primary place of performance
16.
Recipient area of benefit
17.
Recipient officer names and compensation (Top 5)
18.
Total number and amount of small sub-awards; less than $25,000
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf
> Subject: Re: [RESADM-L] ARRA OMB Implementing Guidance Sec 1512
>
> That officers' compensation requirement was in the call for comments
> in April. If it is still there, I guess not enough people wrote
> against it. Note that it was not among the list if items for the
> Prime Recipient, only for the Subs. I see too that not only will sub-
> awards, as we in universities call them, be reported, but also
> purchase orders for goods and supplies. There is still a requirement
> for CCR information for Subs even though some 300 responders
> complained about this for the FFATA sub award data. I wonder why the
> Feds bother with the "calls for comments" when they never accept them.
>
> Here is the text from the Call for Comments on officers.
> Provide the names and
> highly compensated total compensation of
> officers of the the five most highly
> entity: the names compensated officers of
> and total the subrecipient entity
> compensation. if--
> (1) the recipient in its
> preceding fiscal year
> received--
> (a) 80 percent or
> more of its annual
> gross revenues in
> Federal awards; and
> (b) $25,000,000 or
> more in annual gross
> revenues from
> Federal awards; and
> (2) the public does not
> have access to
> information about the
> compensation of the
> senior executives of
> the entity through
> periodic reports filed
> under section 13(a) or
> 15(d) of the Securities
> Exchange Act of 1934
> (15 U.S.C. 78m(a),
> 78o(d)) or section 6104
> of the Internal Revenue
> Code of 1986 [26 USC
> Sec. 6104].
> ``Total compensation''
> means the cash and
> noncash dollar value
> earned by the executive
> during the
> subrecipient's past
> fiscal year of the
> following (for more
> information see 17 CFR
> 229.402(c)(2)):
> (i). Salary and
> bonus.
> (ii). Awards of
> stock, stock
> options, and stock
> appreciation rights.
> Use the dollar
> amount recognized
> for financial
> statement reporting
> purposes with
> respect to the
> fiscal year in
> accordance with FAS
> 123R.
> (iii). Earnings for
> services under nonequity
> incentive
> plans. Does not
> include group life,
> health,
> hospitalization or
> medical
> reimbursement plans
> that do not
> discriminate in
> favor of executives,
> and are available
> generally to all
> salaried employees.
> (iv). Change in
> pension value. This
> is the change in
> present value of
> defined benefit and
> actuarial pension
> plans.
> (v). Above-market
> earnings on deferred
> compensation which
> are not taxqualified.
> (vi). Other
> compensation. For
> example, severance,
> termination
> payments, value of
> life insurance paid
> on behalf of the
> employee,
> perquisites or
> property if the
> value for the
> executive exceeds
> $10,000.
>
>
> Bob
> ------------------------------
> Robert Beattie
>
> On Jun 23, 2009, at 1:00 PM, Bloomberg, Robert wrote:
>
> I notice that the new guidance includes a requirement to report the
> compensation (total? base? bonuses?) of the top 5 people at both the
> recipient and Subrecipient levels.
>
> How are you reacting to that? Is it a problem for anyone?
>
> Thanks.
>
> Bob
>
>
> From: Research Administration List [mailto:xxxxxx@hrinet.org] On
> Behalf Of Maggie Griscavage
> Sent: Monday, June 22, 2009 9:46 PM
> To: xxxxxx@hrinet.org
> Subject: [RESADM-L] ARRA OMB Implementing Guidance Sec 1512
>
> Forty-one page document, just released June 22, 2009.........
>
>
>
> Subject: ARRA OMB Implementing Guidance Sec 1512
>
>
> http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf
>
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NOTE: EMAIL CHANGED TO: xxxxxx@alaska.edu
G. Maggie Griscavage, CRA
Director
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--
NOTE: EMAIL CHANGED TO: xxxxxx@alaska.edu
G. Maggie Griscavage, CRA
Director
Office of Grants & Contracts Administration
University of Alaska Fairbanks
907-474-7301
907-687-3513 cell
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