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FederalReporting.gov and CCR.gov - Catch 22 is alive and well
October 9, 2009 at 6:23 pm #82565
Most local governments are required to report their first quarter of stimulus spending to the FederalReporting.gov website by tomorrow Oct. 10th or be at risk for losing their funding. This is a first for most grantees. Most grant applicants don't know much about DUNS numbers and the Central Contractor Registry. DUNS numbers are assigned by Dunn & Bradstreet to uniquely identify businesses. The federal government needed unique Id.'s to set up a central Accounts Payable database for businesses and all of their various branches, divisions and locations, so they settled on the DUNS number, since they needed a public number and couldn't use Taxpayer Id for their websites. So the feds created the Central Contractor Registry. To register in the CCR webiste you need a valid DUNS number and about 8 people's contact information, a valid SIC code and several other odd bits of information that the average grant applicant has no way of knowing without doing a lot of research. Most grant applicants don't know the exact date that their local government was incorporated on, for example. But you have to go into CCR and pump in all of this information for EACH DUNS number you have associted with a grant. Many local governments have one for Transit, another for Utilities, another for Police and so on. You get the picture. Each place you want to receive a payment or applies for a grant can have a different DUNS number. Filling out the CCR is a long and time-consuming process, especially since it times out on you periodically if you have to stop and look up an unexpected "required" piece of information. It loses anything already entered in that section for you if it does. You also have to enter sensitive information like your bank routing and transit numbers in addition to the organization's taxpayer id. Not stuff you want any old grant applicant/intern to be doing for you. Once this is done, you have to wait 48 hours until the CCR can confirm (electronically) that your Taxpayer Id. and Name match IRS's records (provided you have made no errors). Then you can go into the FederalReporting.com database and apply to be able to enter your grants reports. This also takes 48 hours for FederalReporting.com to sync up the DUNS number that you enter with them to the one in CCR.com. So by the time the average person in the local unit gets the information necessary to make the first quarterly grant report, prepares the information, and then tries to log on to FederalReportign.com and finds out their DUNS number isn't registered in CCR.com and then works their way backward through the discovery process, there is no way that they can file their reports in time. In fairness, folks have been trying to get the word out on this for several weeks now, but the process is long and techincal and requires cooperation and actions from multiple parts of an organization; Accounting, Treasury, and the grant receipients all acting in tandem. This can be tough to do. In any event, you can't get from A to Z in this process in the timeframe unless you knew in advance to go in and get all of these registrations done. If you try to start the process when you get the information, there is no way to complete the process in the 10 days allowed. Ergo Catch 22. This is why this classic of American black humor needs to continue to be required reading in American high schools. It is much more instructive that Angela's Ashes or Things Fall Apart, which are the current depression inducers in today's high school seniors. At least when you encounter Catch 22 when working with the government you will have an appreciation for the fact that Catch 22 has been around for a long time and is wide spread practice in government and wasn't invented specifically to frustrate you personally; just everyone generally.
For anyone who escaped high school and college without reading Catch 22, it refers to government bureaucracy that sets up mutually exclusive requirements for someone to qualify for something. The book is set in World War II Italy where American flyers could go home permanently after flying the required number of missions. However the required number of missions went up by the number of missions flown each month. A flyer could go home on a Section 8 mental stress disability by filling out a particular form and submitting it. However the standard for granting a mental disability was that the person had to be too stressed to complete the request form. Only the individual or the unit commander could complete the form. The units were always desperately short of pilots. Both of these provisions were forms of Catch 22.
Clearly ARRA, FederalReporting.gov and CCR.gov have demonstrated that Catch 22 is alive and well and living in the US Government. It is reassuring however to find that I actually did learn something useful in high school after all.
October 9, 2009 at 6:50 pm #82575
Great post, Clark. I enjoyed your dark humor and learned something too. I did not read Catch 22, but think maybe I should. Might be easier if there was a movie though...
I did read that the reporting would start on 10/1 and end on 10/10 and without knowing the finer points that you have detailed in your post, thought it likely that many folks would have difficult complying.
October 9, 2009 at 6:57 pm #82573
Actually, there is an old movie out based upon the book. It is pretty good. The book is bawdy, raunchy, and I laughed until I cried. It is just terribly funny in a shocking sort of way. At first you just laugh and laugh, but the black side of the humor eventually catches up with the horror of the war and by the end of the book, you aren't laughing anymore. The book really is better than the movie.
October 9, 2009 at 7:32 pm #82571
Our original DUNS CCR was setup to allow Revenue to bill the Federal Court House for their water and sewer. The Revenue Collector delegated the maintenance to a staff person who is out on maturnity. The passwords and security were all changed, but the emails still went to him. He could not sign on to approve people's access to FederalReporting.gov, We had to call the support line and sit on hold for over half an hour to get them to reset the CCR log in security. This appears to be pretty typical, since the people who administer the CCR.gov stuff are typically not the same people who do the grants applications and reports. The Transit Authority staff, still can't log in on their grant to report on FederalReporting.gov. Stephanie Poole over at WSTA tells me she is getting reports from her listserv that a lot of Transit Authorities are having trouble with it.
October 13, 2009 at 12:05 am #82569
Victoria L. BeatleyParticipant
Hi Clark, I finally had a moment to take a look at your post. Fortunately (or unfortnuately) for Mesa the FAA is a water customer and they forced us to comply with the CCR requirements several years ago as a "contractor" so we have already gone through that headache. The FAA pays their utility bills electronically, which is nice, but the CCR was a lot of work for $2,500 a year. I am surprised that the ARRA reporting is up and running given how far behind schedule they are on the disbursements. Mesa was not awarded any ARRA funds which may actually be an okay outcome given the level of effort required.
October 13, 2009 at 12:37 pm #82567
We also set up our CCR entries for our general government & water utilities DUNS number several years ago so that we could bill Water & Sewer to the Federal Court House. But since Murphey's Law also must always apply, the Revenue Collector delegated the maintenance of the account to a staff member who is out on maturnity leave. The security had all been changed and he could not log on to verify/authorize new FederalReporting users. That got resolved with a phone call, but the Revenue Collector had to sit on hold for a half an hour to get help. I think the big issue with CCR, is just that they want too many contact persons; eight is a little excessive. We pay vendors every day and require only the W9 and one contact person in AP. The feds got a little carried away. The ARRA required people to file their first quarter reports on their grants no later than Oct 11 or risk losing their funding. I don't begrudge the feds, the need for the CCR and electronic payments. Those are good things, it is just that they require too much information and need to interface systems real-time or near real-time if they are going to make cross-verification mandatory on short turnaround transactions. I can relate to their cross-agency coordination issues, but some interfaces need to happen for sheer practicality's sake for them and for us. 96 hour turnaround for tax id and registration id verification is pretty stone age.
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