IRS Form 990 Preparation

By: Jeffrey A. Stefan, CPA

On December 18, 2009, OMB issued a memorandum titled, Updated Guidance on the American Recovery and Reinvestment Act – Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates. This guidance should be of particular interest to auditees that are recipients of federal assistance awards under the Recovery Act and required to report under Section 1512 of the Act.

Among the matters required to be reported by recipients under Section 1512 of the Recovery Act are estimates on the number of jobs created and retained. The new OMB guidance focuses on this particular aspect of the 1512 reporting and incorporates lessons learned from the reporting period that ended September 30, 2009 (the first reporting period under the Recovery Act). It replaces Section 5 “Reporting on Jobs Creation Estimates by Recipients” of the OMB June 2009 guidance document titled, Implementing Guidance for the Reports on Use of Funds Pursuant to the Recovery Act and reflects important simplifications to the manner in which job estimates are calculated and reported. Specifically, the memorandum states that:

• Recipients will now report job estimates on a quarterly, rather than cumulative, basis. As a result, recipients will no longer be required to sum various data on hours worked across multiple quarters of data when calculating job estimates.
  
  
• Recipients will no longer be required to make a subjective judgment on whether jobs were created or retained as a result of the Recovery Act. Instead, recipients will report on jobs funded with Recovery Act dollars.
  
  
• A simplified formula is provided to calculate job estimates and additional examples are included to assist in the understanding of how to apply the formula.
  
  
• Recipients should implement the updated methodology to the greatest extent possible for the January reporting period and that questions on the guidance should be directed to recovery@omb.eop.gov.

Contact: Jeffrey Stefan, jstefan@tatetryon.com