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

Robert P. Bloomberg
Director, Office of Grants & Contracts
Tufts Medical Center
800 Washington Street (Tupper 10)
Boston, MA  02111
Tel.   617.636.1142
Fax.  617.636.8568

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

"The purpose of this Guidance is to provide Federal agencies and
funding recipients with information necessary to effectively
implement the reporting requirements included in Section 1512 of the
American Recovery and Reinvestment Act of 2009 (“Recovery Act,” or
“the Act”)."

--
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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