The Coalition for an Accountable Recovery (CAR), of which OMB Watch is a co-chair, just released its analysis of OMB's recent guidance on recipient reporting under the Recovery Act. OMB's guidance only covers recipients of grants and loans (a separate guidance for federal contractors is coming soon), but it starts to flesh out the details of the reporting process, which up until this point have largely been vague and unformed.

That said, as the analysis points out, the new guidance is far from perfect. Here's an excerpt from the analysis:

While the guidance makes important strides in certain respects, it still leaves many issues unresolved. We covered these issues in our previous commentaries. This includes the lack of multi-tier reporting, job quality data, and performance data information; that jobs information is still being reported as undefined full-time equivalents (FTEs); that it is not clear if the information will be publically accessible with easy to use machine-readable tools; and that OMB requires the use of DUNS numbers and poorly considered identifiers for sub-recipients.

On the other hand, the guidance provides a useful framework for reporting to a central data collection service, called FederalReporting.gov. The design of the system is scalable to ultimately have all recipients of Recovery Act funds, including multi-tier sub-recipients, report directly. The guidance also creates a distinction between sub-recipients and vendors, which will prove useful. At the same time, OMB allows prime recipients to delegate direct reporting to sub-recipients - except for jobs data - which will likely cause confusion. There is also significant ambiguity about penalties for reporting non-compliance.

While this guidance is a step in the right direction, there is still much room for improvement.

Here's the full analysis, which is well worth reading.

Image by Flickr user sarosenamy. Used under a Creative Commons license.