Transparency and Accountability: Requirements for Recipients of Recovery Act Funds

The American Recovery and Reinvestment Act (ARRA) of 2009 establishes new requirements for applicants and grantees. To allow direct recipients and sub-awardees to adequately prepare for, and meet these new requirements, HUD is providing the following guidance:

  1. Grantees and first tier sub-awardees receiving HUD ARRA funding must have a DUNS number and must be registered in the Central Contractor Registration (CCR). Find information on how to obtain a DUNS number and register in CCR As they plan their programs, applicants and grantees should immediately advise all planned first tier sub-awardees of the requirement to obtain or update their DUNS number, and register with the CCR.

  2. Each Prime and first tier recipient is required to report the following information to HUD 10 days after the end of each calendar quarter, starting on July 10th, 2009. These reports include:
    1. The total amount of recovery funds received from HUD;
    2. The amount of recovery funds received that were expended or obligated to projects or activities. This reporting must also include unobligated balances to facilitate reconciliations.
    3. A detailed list of all projects or activities for which recovery funds were expended or obligated, including:
      1. The name of the project or activity;
      2. A description of the project or activity;
      3. An evaluation of the completion status of the project or activity;
      4. An estimate of the number of jobs created and the number of jobs retained by the project or activity; and
      5. For infrastructure investments made by State and local governments, the purpose, total cost, and rationale of the grantee for funding the infrastructure investment with funds made available under ARRA, and the name and contact information of the person to contact at the agency if there are concerns with the infrastructure investment.

  3. Detailed information on any subcontracts or subgrants awarded by the recipient must include the data elements in the format required to comply with the Federal Funding Accountability and Transparency Act of 2006 (P.L. 109-282), allowing aggregate reporting on awards below $25,000 or to individuals, as prescribed by the Director of the Office of Management and Budget. The data elements required for the Federal Funding Accountability and Transparency Act are:
    1. The name of the entity receiving the award;
    2. The amount of the award;
    3. Information on the award including the transaction type, funding agency, the North American Industry Classification System (NAICS) code or Catalog of Federal Domestic Assistance (CFDA) number (where applicable), program source, and an award title descriptive of the purpose of each funding action;
    4. The location of the entity receiving the award and primary location of performance under the award, including the city, state, congressional district, and country;
    5. A unique identifier of the entity receiving the award and of the parent entity of the recipient (the DUNS number), should the entity be owned by another entity; and
    6. Any other relevant information specified by OMB or HUD such as the grant number of the parent award under which the sub-award was made, and the funding tier which the subaward was made.

  4. Under this agreement Recovery Act requirements apply down to all recipient tier levels, with the exception of sub-recipient reporting as identified above, which is limited to the Prime recipient and the 1st tier sub-recipient.

  5. Recovery Act funds under this agreement can be used in conjunction with other funding as necessary to complete projects, but tracking and reporting must be separate to meet the reporting requirements of the Recovery Act and OMB Guidance.

  6. For fiscal years ending September 30, 2009 and later, all Single Audit reports filed with the Federal Audit Clearinghouse (FAC) will be made publicly available on the internet. A link will be provided from



Program plans for each of HUD's ARRA programs were submitted to OMB on May 15, 2009. They provide details on program objective and delivery schedules, approved activities, award types and amounts, measures, monitoring and evaluation plans, and potential barriers to effective implementation. All Plans are in Adobe PDF format.


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Content Archived: April 4, 2017