As our colleagues at OMB Watch blogged about yesterday, the Coalition for an Accountable Recovery, of which Sunlight is a member, released more analysis (PDF) they’ve conducted of the Office of Management and Budget’s recent guidance (PDF) on how Recovery Act recipients should report how they used the funds. CAR’s analysis in a nutshell: “While this guidance is a step in the right direction, there is still much room for improvement.”

So far, OMB has provided guidance only for recipients of grants and loans. OMB Watch says that separate guidance for federal contractors is coming soon. OMB has started to flesh out the details of the reporting process, which up until this point have largely been vague and unformed, OMB Watch reports.

CAR lists the good and the bad about OMB’s guidance. First the good:

(T)he 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.

And the bad:

(There is) a 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.

CAP’s full analysis is here (PDF).