Recipient Reporting Requirements Section 1512

August 19

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Featured Speakers Presenters

 Judi Fisher, Division Chief, Office of Grants and Contract Management, Division of Policy, Review and Resolution  Nancy Williams, Team Leader, Office of Grants and Contract Management, Division of Policy, Review and Resolution

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Introduction

  Purpose: – – To discuss the reporting requirements in Section 1512 of the Recovery Act. TEGL No.1-09 dated Aug.14, 2009 Webinar topics to include: – Prime Recipient and Sub-recipient Responsibilities – Required Data Elements – Reporting Timeline – Data Quality Review – Job Creation Requirements – OMB’s central electronic reporting system:

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What is required?

    Section 1512 recipient reports required by the Recovery Act of 2009 – OMB managed web-based reporting system – Detailed information about funds received, projects and activities funded with Recovery Act $$ – Cumulative data from inception of grant award Separate from ETA 9130 financial report and other required program reports. Implementing guidance- June 22, 2009 (OMB M-09-21) Same reporting requirements apply to Recovery Act grants from all Federal agencies.

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What ETA Programs are Covered?

         Employment Service/Wagner-Peyser Funded Activities 17.207 Senior Community Service Employment Program 17.235 WIA Adult Program 17.258 WIA Youth Activities 17.259 WIA Dislocated Workers 17.260

National Emergency Grants - Health Coverage Assistance 17.276 Native American Employment and Training 17.265 YouthBuild 17.274 Competitive Grants for Worker Training and Placement in High Growth and Emerging Industry Sectors 17.275

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Who Must Submit Reports?

 

All Prime Recipients (a.k.a. direct grant recipients)

– Receiving Recovery Act funds. – Ultimately responsible for all required data – May delegate to sub-recipients reporting of sub recipient data

Delegated Sub-recipients

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What Information Does The Report Provide?

   

Total amount of activities;

Recovery Act

funds received; and of that, the amount spent on projects and A list of projects and activities funded by name to include:

– Description – Completion status – Estimates on jobs created or retained

Details on sub-awards Payments to vendors $25,000 or more

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        Federal Funding Agency Name Award identification Recipient D-U-N-S Parent D-U-N-S Recipient CCR information CFDA number, if applicable Recipient account number Project/grant period

Prime Recipient Required Data Elements Per TEGL 1-09

          Award type, date, description, and amount Amount of Federal Recovery Act funds expended to projects/activities Activity code and description Project description and status Job creation narrative and number Infrastructure expenditures and rationale, if applicable Recipient primary place of performance Recipient area of benefit Recipient officer names and compensation (Top 5) Total number and amount of small sub awards; less than $25,000

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Prime Recipient Required Data Elements

 Recipient Reporting Data Model Quarter Ending Sept 30, 2009 – Funding Federal Agency Code, Name – – – Awarding Agency Code, Name Program Source (TAS) Award Number – – – Order Number Recipient D-U-N-S Parent D-U-N-S – – – – – – – – – – Recipient Type CFDA Number Government Contracting Office Code, Name Recipient Legal Name/Recipient DBA Name Recipient Address, City, State, Zip Code Recipient Congressional District Recipient Account Number Final Report Award type, date, description, and amount Project Name/Program Title

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– Quarterly Activities/ Project Description – Project Status – Activity Code – Number of Jobs Created/Retained – Description of Jobs Created – Award Amount – Total Federal ARRA Funds Received/Invoiced – Total ARRA Expenditure

Recipient Reporting Requirements Section 1512 Data Elements Con’t

– – – – – – – – Total Infrastructure Expenditure and Purpose Infrastructure Contact Name, Address, City, State, Zip Code, Email, Phone Primary Place of Performance, Address, City, State County, Zip Code, Congressional District Prime Recipient indication of reporting applicability Prime Recipient Top 5 compensated Name Total Number and Amount of Sub awards to individuals Total Number and Amount of Payments to vendors <$25,000/award Total Number and Amount of Sub awards <$25,000/award

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Aggregate Reporting

  

Sub-awards less than $25,000 Sub-awards to individuals Payments to vendors less than $25,000

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Sub-Recipient Required Data Elements Per TEGL 1-09

   Sub-recipient D-U-N-S Sub-recipient CCR information Sub-recipient type Amount received by sub-recipient    Amount awarded to sub-recipient Sub-award date   Sub-award period Sub-recipient place of performance  Sub-recipient area of benefit  Sub-recipient officer names and compensation (Top 5) *Prime recipient reports unless delegated to sub-recipient

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

Sub-Recipient Required Data Elements

Recipient Reporting Data Model Quarter Ending Sept 30, 2009 – Sub-recipient Name, Address, City, State, Zip Code, County – Sub-recipient Congressional District – Sub-recipient type – Amount of Sub-award – Total Funds Disbursed – Sub-award date – Sub-recipient place of performance – Sub-recipient officer names and compensation (Top 5)

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Vendor Required Data Elements

   Prime Recipient Data: – Payments greater than $25,000 – D-U-N-S or Name and zip code of Headquarters – Expenditure amount – Expenditure description Sub-Recipient Data: – D-U-N-S or Name and zip code of Headquarters Prime recipient reports unless delegated to sub recipient

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When Must Reports Be Submitted?

  Quarterly within 10 days after the end of each reporting quarter.

Initial reports are due October 10. – – Cumulative from inception of grant award (including funding and activity for quarter ending June 30, 2009) Must maintain data for quarter ending June 30, 2009

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How Will Recipients Report?

 

REGISTER

– Online at www.FederalReporting.gov

– Must be registered with CCR and have a DUNs number – Before end of Quarter – Recommend 35 days prior to the end of the quarter – Registration opened August 17, 2009

REPORT

– www.FederalReporting.gov

is the centralized location for all ARRA Section 1512 recipient reporting

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Caution!

   No waivers to reporting requirements will be granted Non-compliance will be treated as a violation of the award agreement – Sanctions could apply Information reported will be posted for public view at www.Recovery.gov

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Reporting and Review Timeline 1.

2.

3.

REPORT

 Days 1-10, Reports Submitted Online at www.FederalReporting.gov

REVIEW (Comment Period)

 Days 11-21, Prime Recipient Review/Revision – Ensure complete and accurate information –  Days 22-29, Federal Agency review and comment – Coordinate any corrections with sub-recipients Notifies recipient of errors through www.FederalReporting.gov

– Notification unlocks report for corrections  Corrections must be made by the 29th day after quarter ends

RELEASE

 Days 11-29, reported information will be posted to www.Recovery.gov

 Final Reports available Day 30 at www.Recovery.gov

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In-bound Recipient Reporting (FederalReporting.gov) Timeline and Activities No less than 35 days

prior to the end of the quarter

1 – 10 days

after end of Quarter

11 – 21 days

after end of Quarter

22 – 29 days

after end of Quarter

30 days

after end of Quarter

90 days

after end of Quarter

Agency, Prime and Sub Recipient Registration 1 Prime Recipients & Subs Enter Draft Reporting Data 2 Prime Recipients Review Data Submitted By Sub(s) 4 Agency Review of Data Submitted 6 Initial Submission

10 days after end of Quarter

3 Prime Recipients & Subs Make Corrections 5 Prime Recipients & Subs Make Corrections 7 Agency “View Only” Agency Comment Period Recipient Report Adjustments Possible Recipient Reports Published on Recovery.

gov 8 Next quarterly reporting cycle begins updates reflected cumulatively 9

Report Status:

Draft

Recipient Reporting Requirements Section 1512

Initial Submission Final Submission Published

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Managing the Reporting Process

  Prime recipients are required to: – Collect and maintain all relevant information – Be responsive to section 1512 of the Recovery Act – – Design and implement a reporting process Ensure data accuracy and consistency Prime recipients that delegate to sub-recipients must ensure that they: – Clearly communicate coordinated reporting – – – Prevent reporting on same activity by prime and sub recipients Maintain updated inventory of sub-recipient delegations Cross-check data records to ensure no double counting

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

Who is Responsible for Data Quality?

Prime Recipients – Owns recipient and sub-recipient data   Sub-recipients – Owns sub-recipient data Federal Agency – Provides advice/programmatic assistance – Performs limited data quality review  Oversight Authorities (Recovery Board, OMB) – Establish data quality expectations – Establish data and technical standards – Coordinate any centralized reviews

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Scope of Data Quality Reviews:

    Accuracy, Completeness and Timely Reporting Avoidance of two key data issues Material Omissions – required data is not reported – – reported information is not responsive to data requests public is not fully informed on Recovery Act projects or activities Significant Reporting Errors – required data is not reported accurately – public misled or confused by the recipient report

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Suggested Internal Controls Approaches

 Establish internal controls to ensure accuracy, completeness and timely reporting – Establish control totals – Establish an estimated distribution chart to help identify outliers – Establish data review protocol – Establish procedures for cross-validation of data – Determine method for detecting/correcting material omissions

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Data Quality Process

 Federal Agencies are required to: – evaluate recipient and sub-recipient data – identify and resolve material omission or significant error issues – identify and resolve issues when: • Recipients demonstrate systemic or chronic reporting problems • Sub-recipients demonstrate systemic or chronic reporting problems • Recipients demonstrate systemic or chronic deficiencies in reviewing and identifying sub-recipient data quality issues

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Data Quality Process

 Final Report will be classified by Federal Agency as: – Not Reviewed by Agency – – Reviewed by Agency with no material omissions or significant reporting errors Reviewed by Agency with material omissions or significant reporting errors identified

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Jobs Creation

   All jobs directly created or retained from ARRA in projects or activities – Collect specific data from sub-recipients and vendors to determine jobs created and retained – Report as two separate fields • • a numeric field of combined total of jobs directly added or retained Narrative Use of Statistical Model – OMB allows only with approval – ETA has not approved - requires full data collection and reporting Jobs are reported cumulatively

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Jobs Creation or Retained

   What is counted?

– New position created and filled – Existing unfilled position filled – Existing position retained Cannot be counted as both created and retained What is NOT counted? – SCSEP

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Estimates of Job Impact

  To report jobs, prime recipients are required to: – Translate full/part time employees into “full-time equivalents”, or FTEs.

– Calculate FTEs by adding the total hours worked in the quarter, and dividing by the total hours in a full-time schedule.

Additional guidance on reporting jobs created and retained is provided at: – OMB Memo 09-21 – ETA TEGL 09-01

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References and Resources

  References – www.whitehouse.gov/omb/memoranda/ • OMB Memo 09-21 • Supplemental Recipient Reporting Data Model – www.doleta.gov/directives/ • TEGL 1-09 Resources – www.whitehouse.gov/recovery/WebinarTrainingMaterials/ • Series of OMB Webinars on ARRA 1512 Reporting

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ETA Technical Assistance

   Ongoing from ETA – Contact your FPO Questions can be submitted to ETA mailbox at: – [email protected]

– Responses provided individually – FAQ’s posted on ETA Recovery Act website • www.doleta.gov/recovery Additional webinars – Beginning in September 2009 • Sept. 14 th (save the date)

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