Transcript Federal Education Grant Reporting Requirements.

A Division of Thompson Media Group
Federal
Education Grant
Reporting
Requirements.
Cloud Accountability has
Arrived!
Bonnie Little
[email protected]
Brustein & Manasevit, PLLC
www.bruman.com
2
Overview
 Reporting


Before FFATA
EDGAR Reporting Requirements
ARRA Reporting
 FFATA
Reporting
 Programmatic Reporting
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Reporting Before FFATA
 What

is “reporting”?
Accountability measure used by granting
agencies to ensure that federal funds are
spent appropriately
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Reporting Before FFATA –
EDGAR Reporting
 Financial

Status Reports
EDGAR 80.41
 OMB-approved
 Grant





forms - Standard Form 425
Life Cycle
Solicitation, application, award issuance
Obligations, draw Federal cash payments
Disburse cash/liquidate obligations
Document transactions
Submit Financial Reports
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Reporting Before FFATAEDGAR Reporting
 Standard




Form 425
Combines SF 269 and SF 272
Deadlines- federal fiscal year quarters
New Certification Language
Previous features retained:
 Object
class categories of expenditure
 Frequency
 Handling of accruals
 Cash management instructions
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Reporting Before FFATAEDGAR Reporting
 Subgrantee


Reporting
Not required to use OMB forms
Grantees may not impose more
burdensome requirements on subgrantees
Reporting Before FFATAEDGAR Reporting
 Performance


Reports
EDGAR 80.40
Frequency depends on awarding agency,
not required more often than quarterly
 EXCEPTION:
“High Risk” grantees may be
subject to more frequent and extensive
reporting. EDGAR 80.12
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Reporting Before FFATAEDGAR Reporting
 Performance



reports must contain:
Comparison of actual accomplishments to
established objectives
Explanation of slippage if objectives not
met
Analysis/explanation of cost overruns or
high unit costs
 Grantees
must immediately report
“significant developments”
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Reporting Before FFATAEDGAR Reporting

“Significant Developments”



Problems, delays or adverse conditions that
substantially impair ability to meet objective of
award
Favorable developments that enable meeting
time schedules and objectives sooner, at less
cost, or produce more beneficial results than
originally planned
Note: If grantees/subgrantees suspect
materials misuse of funds, may need to report
the issue to the awarding agency

Potential fraud, waste or abuse may need to be
reported to Office of Inspector General
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Reporting Before FFATAARRA Reporting
 Section
1512 requires states to submit
quarterly reports



Total amount received and expended
List of all projects or activities funded
Estimate of the number of jobs created and
retained
 www.federalreporting.gov
 www.recovery.gov
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Reporting Before FFATAARRA Reporting
 SFSF




reporting
Distribution of highly qualified teachers
Data systems tracking student achievement
Improved standards and assessments
Turnaround of failing schools
 Some
states received extension on
certain indicators to Dec. 31, 2013

Old deadline: Jan. 31, 2012.
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FFATA Reporting
Background

Reporting needed to



Scope of data collected increase



Assess grant performance/effectiveness
Provide public opportunity to review
Need for better risk management
New technologies
Reported information available through
single, searchable website

USASpending.gov
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FFATA ReportingFederal Agency Reporting
 Federal
agencies have long been
required to report data on prime awards
and prime awardees


Old: Federal Assistance Award Database
System (FAADS), operated by Census
Bureau
New: FAADS-Plus
 Info
updated daily
 Posted on USASpending.gov
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FFATA ReportingReporting by Prime Recipients
 “Prime
Recipients” – receive grant or
contract directly from federal gov’t
 New layer of reporting: prime recipients to
report data on first-tier subawards and
executive compensation


“Subawards” includes subgrants and
subcontracts
Prime recipients of grants and contracts,
both mandatory and discretionary,
awarded after Oct. 1, 2010
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FFATA ReportingReporting by Prime Recipients
 Initial

Prime recipients report first-tier subawards of
$25,000 or more, and executive
compensation, if conditions are met
 Initial



awards of $25,000 or more:
awards below $25,000
FFATA does not apply
Subsequent grant modifications push
award over $25k threshold, award is subject
to requirements
Subsequent grant modifications reduce
award under $25k threshold, continues to
be subject to FFATA
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FFATA ReportingExempt from Reporting
 Contracts,
purchase agreements, vendor
agreements and consultant agreements
for supplies, equipment, and services
 Grants under ARRA
 Federal awards to individuals
 Federal awards to entities with gross
income of less than $300,000
 Classified information
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FFATA ReportingPrime Recipient Registration
 Prime
recipients that receive grants must
register in two systems:

FFATA Subaward Reporting System (FSRS) –
to be displayed on USASpending.gov
 Accessible
recipients

to federal employees and prime
Central Contractor Registration System
(CCR)
 Entities
that do business with federal gov’t
 Links to Dun & Bradstreet (DUNS)
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FFATA Reporting
 First

tier subawards
A grant or contract from a prime recipient
to a subgrantee or subcontractor.
 Second

tier subawards
A subsequent subgrant or subcontract
between the subawardee and another
entity
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FFATA Reporting- What











Name of entity receiving award
Amount of award
Subcontract/subcontract number
Funding agency
NAICS code (contracts) / CFDA program number (grants)
Program source
Award title descriptive of the purpose of the funding action
Location of the entity (congressional district)
Place of performance (congressional district)
Unique identifier (DUNS) of the entity and its parent; and
Total compensation and names of top five executives (same
thresholds as for primes), if required
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FFATA Reporting - When
 Federal
agencies, including ED, report
prime award information to
USASpending.gov on the 5th and 20th of
each month
 Prime recipients must report first tier
subaward information by the end of the
following month in which the subaward
was made
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FFATA ReportingExecutive Compensation
 Prime
recipients must report the total
compensation and names of 5 most
highly compensated executives for both
itself and first-tier subrecipients, if:


(1) more than 80% of annual gross revenue
is from the federal gov’t, and those annual
revenues are greater than $25 million, and
(2) compensation information is not already
available through reporting to the SEC
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FFATA v. ARRA




Under FFATA, expenditures are not required to
be reported on USASpending.gov, only
obligated subawards must be reported.
Under FFATA, reporting is done on a rolling
basis depending on when a subgrant is made,
rather than reporting on a quarterly basis.
There are certain data elements required
under ARRA that are not required under
FFATA. For example, number and descriptions
of jobs created and reporting requirements
related to infrastructure projects.
FFATA reporting is done through www.fsrs.gov,
while ARRA reporting should continue to be
done through www.federalreporting.gov.
Federal Agency
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Federal Agency
(U.S. Dept. of Ed)
Contract
Prime awardee
(Prime recipient)
of Grants
This webinar does not
discuss reporting
requirements of prime
awardee (prime
recipients) of contracts.
Subaward of grant
(subgrant)
First tier subawardee or
subrecipient of grant
* Prime awardee may have to
report on subawards and
executive compensation under
FFATA
Contract for
goods/services paid
with grant
* No reporting
required under FFATA
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Prime awardee
(Prime recipient)
of Grants
This webinar does not
discuss reporting
requirements of prime
awardee (prime
recipients) of contracts.
Subaward of grant
(subgrant)
First tier subawardee or
subrecipient of grant
* Prime awardee may have
to report on subawards and
executive compensation
under FFATA
Contract for
goods/services paid
with grant
* No reporting
required under FFATA
Subaward/
subgrant
Second tier subawardee
or subrecipient
* No reporting required
under FFATA
Contract for goods/
services paid w subgrant
* No reporting required
under FFATA
FFATA Guidance
 OMB:
April 6, 2010 memo requiring the
reporting of first-tier sub-awards
 OMB guidance containing specific
instructions on the sub-award reporting on
August 27, 2010:

http://www.whitehouse.gov/omb/open
 FSRS
FAQs: https://www.fsrs.gov/#a-faqs
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Programmatic ReportingESEA
 Consolidated
(CSPR)


State Performance Report
Complement state consolidated
application
First part – core ESEA accountability issues
 Due
six months after relevant school year
(Dec. or Jan.)

Second part – other ESEA programs
 Due
2 or 4 months later
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Programmatic ReportingESEA
 Title
I, Part A
 Title I, Part C
 Title I, Part D
 Title I, Part F
 Title II, Part A
 Title II, Part D
 Title III, Part A
 Title IV, Part A
 Title
IV, Part B
 Title VI, Part A, state
assessments
 Title VI, Part A,
assessment
instructions
 Title VI, Part B,
subpart 2
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Programmatic ReportingIDEA
 IDEA
section 618, state reporting
requirements
 State Performance Plan (SPP)



Evaluates state’s efforts to implement Part B
and Part C of the IDEA
Every 6 years
Measurable and rigorous targets
 Annual


Performance Report (APR)
Actual target data and explanation
Discussion of improvement activities
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Programmatic ReportingPerkins
 Consolidated




Due December
Progress in achieving state adjusted levels
of performance in state plan
Disaggregate data
Submitted through CAR Database and
Education Data Exchange Network (EDEN)
 Financial


Annual Report (CAR)
States Report (FSR)
Expenditures and narrative
Interim and final FSR must be submitted
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Programmatic ReportingAdult Education
 Annual


Progress Report
Progress in achieving adjusted levels of
performance, in state place
Submitted using National Reporting System
for Adult Education (NRS) data tables
 Financial


Status Report (FSR)
Expenditures and narrative
Interim and final FSR must be submitted
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Programmatic ReportingEDFacts
 Office
of Planning, Evaluation and Policy
Development, Performance Information
Management Service (PIMS)



(1) electronic submission system that
receives performance data from states,
districts and schools;
(2) analytical tools for analysis of submitted
data; and
(3) reporting tools for ED staff and data
submitters to ensure better use of data
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Programmatic ReportingEDFacts
 K-12
performance data
 SEAs submit data on approx 180 data
groups at the state, district and school
levels

Includes:
 Adequate
yearly progress
 State performance assessments
 Highly qualified teachers
 Public school choice
 Supplemental educational services options
 Graduation rates
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Programmatic ReportingEDFacts
 Federal




program offices use EDFacts data
Yearly state profiles
Programmatic reports to Congress
Statistical research
Identification of issues/ monitoring
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Questions??
Bonnie Little
[email protected]
This presentation is intended solely to
provide general information and does not
constitute legal advice. Attendance at the
presentation or later review of these printed
materials does not create an attorneyclient relationship with the presenter(s). You
should not take any action based upon
any information in this presentation without
first consulting legal counsel familiar with
your particular circumstances.
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