EDA already has a robust set of policies and procedures in place to manage risk and minimize fraud, waste, and abuse throughout the award cycle for all awards, including ARRA. In the pre-award process, numerous internal controls have been put in place. First, all applications for EDA assistance (including assistance under ARRA) are reviewed and evaluated by EDA regional office staff for consistency with EDA regulations and programmatic requirements, and staff record appropriate milestones in EDA’s grants management system, the Operations Planning and Control System (OPCS). Subsequently, each regional office’s Investment Review Committee (IRC) meets to discuss the merits of proposed projects deemed eligible and consistent with the mission. The Regional Environmental Officer weighs in on any environmental issues and the Regional Counsel highlights any legal issues. The IRC then makes a recommendation to the Grants Officer, and his or her decision is transmitted to Headquarters for quality assurance review. EDA Headquarters staff determine a) if the award is consistent with EDA’s award criteria and program objectives and b) if a search of the Dunn and Bradstreet database identifies any red flags in the applicant’s financial history. In the post-award process, EDA staff review required financial and progress reports in order to identify and follow up on any performance issues. In addition, staff review the recipient’s A-133 audits to highlight any potential red flags and work with the recipient to put in place a corrective action plan, if required. For construction projects, EDA engineers review weekly payroll records, progress reports, and other required documentation to ensure that Davis-Bacon wages are paid, any required environmental permits have been issued, construction is proceeding on schedule, and cost overruns are minimized to the extent possible. EDA engineers enter construction-related milestones into OPCS to assist with project monitoring and conduct site visits as travel funds permit. EDA carefully tracks expenditures to verify that funds are used for their designated purpose. Construction grants do not receive advance payments, and appropriate grant spending reports must be prepared by grantee in order to be reimbursed for their costs. EDA uses functionality within the Commerce Business System (CBS) to monitor funds control; EDA prepares status of funds reports on at least a monthly basis to determine if funds are being obligated according to the spending plan. Reports are prepared by budget staff and reviewed by accounting staff before they are submitted to management, and EDA Grants Officers’ performance plans address the requirement to obligate funds according to spending plans. EDA established separate Treasury Account Fund Symbols to ensure ARRA funds are clearly distinguishable. EDA is reviewing ARRA reporting requirements and will establish procedures for preparing and reviewing required reports based upon guidance from OMB and the Department, using data from CBS and OPCS to prepare reports. EDA has procedures in place for reconciling data in CBS to OPCS on a monthly basis and preparing and reviewing the weekly ARRA Financial and Activity Report. EDA is using all available staffing tools to hire staff to implement ARRA and to correctly charge salaries and expenses related to these new positions to the ARRA account. EDA will monitor progress in meeting short-term employment goals. Longer-term program evaluation will be conducted by EDA as it compiles Government Performance and Results Act (GPRA) data for all EDA projects, including those awarded with ARRA funds. Under GPRA, EDA tracks the creation of jobs (not including short-term construction jobs) and private investment three, six, and nine years after investment award. To coordinate all policies, procedures, and special reporting requirements pertaining to ARRA, EDA has established a senior-level governance body.