Has anybody in small business wondered where the American Recovery and Reinvestment Act (ARRA) money was and if it would ever trickle down to small business? It has taken a while to get the money flowing on some of these programs (other than construction projects). We are starting to see ARRA funds used for funding of some STTR and SBIR topics. There are some additional stipulations attached to funds coming from the ARRA, however. The contractor must have a funds control system that tracks and reports ARRA funds separate from non-ARRA funds. The contractor must also keep track of jobs created by the ARRA funds or jobs supported by the funds. It is required that the costs claimed are allowable, allocable and properly supported. The contractor is also required to flow down these requirements to subcontractors. These requirements are in addition to the usual DCAA and FAR requirements for government contracting. So the question is; "will the government really be able to monitor these additional requirements"? Well, we had a client last week that received a notice from their contracting office notifying them that a team was coming to their facility to do a "review" of these requirements associated with the ARRA funds. The review is requesting to see "backup documentation" in support of these requirements. Sounds like a system audit. So if you are receiving ARRA funds (or proposing to receive these funds) be prepared for a "review" of your backup documentation. This is beginning to happen.
