Transcript Slide 1

American Recovery and
Reinvestment Act (ARRA)
Transparency, Accountability, and
Reporting
Penny Kelly and Bonnie Douglas
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General Reporting
Requirements
Note: Presentation is based on preliminary
information regarding reporting known as of 8/3/09 and
is subject to change.
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Tracking ARRA Funds
The State (SEA) is required to report
ARRA funds separately
SEA must maintain accurate
documentation of all expenditures
SEA must ensure data quality and proper
expenditure of ARRA funds
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Questions Reports Must Answer:
Who is receiving ARRA funds?
How much are they receiving?
What projects or activities are being
funded?
What is the completion status of the
projects?
What impact on job creation and
retention?
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When Are Reports Due?
ARRA requires that the state’s report on
the use of ARRA funding is due no later
than the 10th day after the end of each
calendar quarter.
Due to the short timeline, LEAs will need
to transmit ARRA data before the day that
the state’s report is due.
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Who Reports?
Prime recipients (States) have the primary
responsibility for reporting all data.
Sub-recipients (Districts) must report to
the state.
Reports are expected to meet the
requirements of recent legislation
regarding reporting.
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Federal Oversight Authority
OMB, Recovery Board, Office of Inspector
General
Establish data quality expectations
Establish data and technical standards
Coordinate any centralized reviews of data
Findings by a Federal agency can result in
termination of Federal funding
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Cautions
No waivers will be granted regarding required
reporting
Reporting elements cannot be combined with
other Federal reporting requirements
Prime recipient (state) must avoid double
counting
Non-compliance with reporting requirements is
considered a violation of the award agreement
Reports may be used to assess compliance with
award agreements
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Prime Recipient
Owns recipient data
Initiates appropriate data collection and
reporting procedures
Implements internal control measures to
ensure accurate and complete information
Performs data quality reviews and makes
appropriate and timely corrections
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Sub-recipients
Own sub-recipient data
Initiates appropriate data collection and
reporting procedures
Implements internal control measures to
ensure accurate and complete information
Reviews information and makes
appropriate and timely corrections
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Required Data Elements
Sub-recipient DUNS
Sub-recipient type
Amount received
Amount awarded
Sub-award date
Sub-award period
Place of performance
Area of benefit
Officer names and
compensation
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ARRA Reporting Variables
All districts and cooperatives must have a Nine
Digit Dun and Bradstreet (DUNS) number
assigned http://fedgov.dnb.com/webform
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Expenditure Reports
Transfer of funds by a cooperative to a
member district’s subgrant does not
constitute an expenditure.
Cooperatives must ensure member
districts have expended funds that were
subgranted and report the aggregated
expenditures on their quarterly and final
expenditure reports.
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ARRA Reporting Variables
All expenditure and other ARRA data must be reported
CUMULATIVELY or year-to-date from the point that
each LEA began expending ARRA funds through the
end of each quarterly reporting period.
Each subsequent quarterly report will also be
cumulative. In other words, the report due January
2010, will include the data reported through September
2009 and be updated to include data that accumulated
through December 2009. ISBE will aggregate all ARRA
expenditures across fiscal years for each LEA.
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ARRA Reporting Variables
Jobs Created and Retained
A job created is a new position created and filled; a job
retained is an existing position that would not have been
continued were it not for ARRA funding.
FTE – Full Time Equivalency
Enter the FTE for each position. This is calculated as total
hours worked divided by the number of hours in a full-time
schedule. The figure should be reflected to two decimal
places.
The number reported should represent a reasonable average
of FTE’s created and retained for the quarter. Such an estimate
would ideally be done by taking FTE’s for each pay period in
the quarter and averaging them. It could also be done at a
single point in time, as long as care is taken that the single
point is representative of the quarter for the position.
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Reporting on Jobs Creation
Required to report an estimate of jobs directly
created or retained
Number of jobs expressed as FTEs
Report includes a job title or labor category
Report only on “direct” jobs
Report on all jobs attributable to an award
ISBE is planning to collect this info as a
component of expenditure reports
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ARRA Reporting Variables
Awards made to a vendor greater than $25,000:
A vendor is defined as a dealer, distributor, merchant, or other seller
providing goods or services that are required for the conduct of the
program.
A vendor:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the
Federal program; and
(5) Is not subject to compliance requirements of the Federal program.
If a sub-recipient (i.e. district or cooperative) awards ARRA funds greater
than $25,000 to a vendor for services needed to carry out the project or
program, the sub-recipient must report the identity of the vendor by
reporting the DUNS number, if available, or otherwise the name and zip
code of the vendor’s headquarters.
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Federal Funding Accountability and
Transparency Act (FFATA)
Not later than January 1, 2008, the Office of Management and Budget shall, in
accordance with this section, section 204 of the E-Government Act of 2002 (Public
Law 107-347; 44 U.S.C. 3501 note), and the Office of Federal Procurement Policy
Act (41 U.S.C. 403 et seq.), ensure the existence and operation of a single
searchable website, accessible by the public at no cost to access, that includes for
each -(A) the name of the entity receiving the award;
(B) the amount of the award;
(C) information on the award including transaction type, funding agency, the
North American Industry Classification System code or Catalog of Federal
Domestic Assistance number (where applicable), program source, and an
award title descriptive of the purpose of each funding action;
(D) the location of the entity receiving the award and the primary location of
performance under the award, including the city, State, congressional
district, and country;
(E) a unique identifier of the entity receiving the award and of the parent entity
of the recipient, should the entity be owned by another entity; and
(F) any other relevant information specified by the Office of Management and
Budget.
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Reporting MOE
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Reporting Requirement
Districts that choose to supplant
must track these funds separately
so that it can be substantiated that
the supplanted funds were used for
other ESEA programs.
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New Guidance on Supplanting
If the LEA maintains (or exceeds) its
level of local, or state and local,
expenditures for special education and
related services from year to year,
either in total or per capita, then the
Part B funds are, in fact, supplementing
those local, or state and local,
expenditures and the LEA has met its
MOE and supplement/not supplant
requirements.
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The 50% Rule
“An LEA may treat as local funds up to 50% of
the amount of funds it is eligible to receive…from
that appropriation that exceeds the amount from
funds appropriated for the previous fiscal year
that the LEA was eligible to receive…to carry out
activities that could be supported with funds
under the ESEA regardless of whether the LEA
is using funds under the ESEA for those
activities.”
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For Example
FY 09 IDEA Allocation = $1,000,000
FY 10 IDEA Allocation = $1,000,000
FY 10 ARRA IDEA Allocation = $1,000,000
Total FY 10 = $2,000,000
Difference between FY 09 and FY 10 is
$1,000,000.
The 50% rule allows the district to use 50% of this
amount or $500,000 to supplant local expenses.
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Maintenance of Effort and the 50%
Rule
The District’s MOE is $3,000,000 in FY 09
The District’s MOE is $3,000,000 in FY 10
$2,500,000
Since the 50 % rule allows the District to use
$500,000 to supplant local expenses, the
district can subtract this amount from MOE
and report the new total, $2,500,000, as the
FY 10 MOE.
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MOE Questions
Total IDEA Flow Through and IDEA
Preschool Allocations to LEAs?
What was the LEAs Determination status?
Reduction of state and local funds taken in
dollars?
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Early Intervening Services
(EIS) Reporting
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EIS questions
Was the LEA required to use 15% for EIS due to
disproportionality?
What was the amount the LEA was required to spend?
Did an LEA voluntarily use up to 15% for EIS?
What Amount was voluntarily reserved for EIS?
Total number of children receiving CEIS under IDEA in
FY 10?
Total number of children who received EIS under IDEA
anytime in the past two school years (FY09 and FY10)?
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Helpful Internet Sites
ARRA Recovery Site :
http://www.recovery.gov/
ARRA Department of Education Guidance
http://www.ed.gov/policy/gen/leg/recovery/index.html
ARRA-IDEA Part B Department of Education Guidance
http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdf
State or Federal Project and Payment Information:
http://206.166.105.128/FRISInquiry/
IDEA 2004
http://idea.ed.gov/explore/home
USDE – Office of Special Education
http://www.ed.gov/about/offices/list/osers/osep/index.html
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Contact Information
IDEA Grant Coordinators – Bonnie
Douglas and Penny Kelly
– 217-782-5589
– [email protected] and [email protected]
Funding and Disbursements Consultants –
Kim Lewis or Sharon Conrath at 217-7825589
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