ARRA, Ed Jobs and Other Federal Reporting Requirements PASBO March 17 th , 2011. ARRA Team: Michael Walsh, Deputy Secretary for Administration, Pennsylvania Department of Education Brian LaForme, Office of Administration, Executive Stimulus Coordinator, Pennsylvania Department of Education
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ARRA, Ed Jobs and Other Federal Reporting Requirements
March 17th, 2011
Michael Walsh, Deputy Secretary for Administration, Pennsylvania Department of Education
Brian LaForme, Office of Administration, Executive Stimulus Coordinator, Pennsylvania Department of Education
Program Staff, Pennsylvania Department of Education
Federal Programs Staff (Title I, etc.)
Special Education Staff (IDEA)
Teaching & Learning Support (BEF/PA-PACT)
Early Childhood Development (IDEA)
Food & Nutrition (School Lunch Equip)
Migrant Education (Homeless)
Budget & Fiscal Management (Accounting)
Federal Reporting Myths
Ed Jobs Funding
Myths, or Things You May Not Know
Things You May Not Know (or fully understand):
Some ARRA Reporting will continue through September 30, 2013.
E.g., School Improvement Grants are available through 09/30/2013, State Longitudinal Data Systems through 06/30/2013.
The new Ed Jobs funds will be subject to ARRA Section 1512 Reporting Requirements too.
The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was the precursor to ARRA, affects ALL federal funds, and doesn’t expire. Implementation was delayed due to ARRA, but is now ramping up.
Federal Agencies reported starting in 2008, Primary Recipients (states/PDE) must start reporting effective 10/01/2010; first reports due 11/30/2010.
FFATA has many of the same requirements of ARRA (CCR, Duns, Highly Compensated), and will be in all federal assistance subgrant terms & conditions going forward.
Continued receipt of federal funding requires grantees (PDE) to have in place processes to sustain (not temporary) reporting requirements and validate data (monitor) [CFRSection 170, specifically 170.200(b)].
ARRA contains little that is new in the way of requirements, other than 1512.
Most of the attention on Monitoring, Fiscal Controls, and much of the Single Audit Supplement focus is on reiterating and reinforcing existing requirements that pre-date ARRA and the current administration.
E.g. Cash Management Investment Act of 1990 (CMIA)
Federal funds come with numerous ‘fiscal’ requirements that typically fall under the responsibility of the Business Manager, NOT typically the Federal Program Coordinators.
Contract approval, Accounting/Payroll systems, Procurement procedures apply to the entire organization, NOT just your under your Federal Program Coordinator
EDGAR Links: Full text / Part 80 / Part 74 / Part 668, USDE Cash Mgt Guidance and FAQs
Your Federal Payments are also available on USASpending.gov – a website which won’t go away when ARRA ends, so public scrutiny, and therefore elevated oversight, will continue after Recovery.gov.
Other Sites include:
PaymentAccuracy.gov –improper payments
Federal Audit Clearinghouse – your single audits
PA School Audits, PA Recovery Site, PA Contracts Online, OIG Reports, GAO Reports
Myth: ARRA Reporting will be over in a few months; September 30, 2011 (the date by which States must obligate funds received under the SFSF program)
Some ARRA funds can stretch to September 30, 2013 or beyond
ARRA Section 14008 Annual Reports are due in February 2012
ARRA funds will continue to be ‘high-risk’ for single audit purposes in each Fiscal Year
The new Ed Jobs money is subject to ARRA Section 1512 Reporting Requirements
Federal agency funding for oversight and administration is generally through September 30, 2012, and the ARRA Boards and Panels don’t terminate until September 30, 2013
The Section 1512 Data elements are also known as the FFATA data elements, which is a 2006 law which does NOT expire like ARRA (implementation was delayed for ARRA)
Myth: The Recovery Act / The Current Administration is responsible for this oversight, and it will pass;
It is not just ARRA which is responsible for the increased oversight, but the increased scrutiny due to the massive amount of online information (see above) and budget pressures;
FFATA pre-dates ARRA, passed in 2006, under the previous administration, bi-partisan co-sponsors, but implementation was simply delayed because of technical challenges, then ARRA.
All the focus on Monitoring, focus on Fiscal Controls and much of the expansion of Single Audits is NOT new – rather OMB and USDE are simply restating, and checking, on obligations we’ve always had, but perhaps overlooked (e.g. Cash Management Act of 1990).
Myth: Business Managers can defer this stuff to the Federal Programs Staff
It is true that Federal Programs Coordinators can be wholly responsible for the ‘programmatic’ elements, or implementation of federal funds. However,
The fiscal requirements cross ALL federal funds and pertain to Contract Approval, Procurement Procedures, Invoice Payment, General Ledger Accounting, Record Retention, etc. – Traditionally Business Manager Functions.
Myth: Audit findings either don’t go into this detail, or go nowhere – it really won’t impact me
Single Audits now focus more intently on this – see most recent Single Audit Supplement
Single Audits won’t be your only review. PDE Monitoring specifically addresses areas which were previously overlooked. In addition, other auditors, federal and state, are focusing on fiscal elements and 1512 data (jobs and vendor payments).
PDE is required to follow-up on corrective action and take uniform action for non-compliance
Feds are likewise taking action for non-compliance or deficiencies related to monitoring.
Surprised? Need Help? Check out these PDE resources:
ARRA Monitoring Quick Guide
Policy on Federal Interest
Policy on Data Deficiencies
USDE Cash Management Policies Memo
Spend ARRA funds BEFORE regular Federal funds
How you account (journal entries) for your local versus federal funds can dramatically impact your single-audit findings.
PDE Home -> Hot Topics ARRA Reporting -> ARRA Reporting or ARRA Resources;
Update your contact information in PAEdTrak, Institution Information tab; ALL notifications, important updates, and monitoring notices use this distribution list
Ed Jobs Funding
THE FOLLOWING IS SUBJECT TO CHANGE – NOT FINAL!
In August 2010, the federal government awarded to Pennsylvania monies from the Education Jobs Fund (Ed Jobs).
See letter dated January 28th, 2011 from the Secretary of the Budget.
The Letter and FAQ can be found on the Governor’s Budget Office Website.
See PA House Bill No. 915 (Session of 2011, Printers No. 978) for details.
Thus, the Basic Education Funding (BEF) for Local Education Authorities (LEAs) for the 2010-2011 school year consists of all three: State, Federal SFSF and Federal Ed Jobs monies.
More information and allocations here: Home >> Grants and Subsidies >> Education Budget >> Basic Education Funding >> File at bottom
LEAs have already received a portion of the state share of the education funding and the SFSF funds. LEAs will begin to receive the Ed Jobs portion of their BEF as soon as:
The legislature appropriates the funds,
LEAs will be notified that the rider is available for download/signature from eGrants
LEAs sign and submit to PDE the Ed Jobs rider (no application),
PDE reviews and forwards the signed rider to the Comptroller’s Office for final approval, and
Payments are made by the Comptroller
Ed Jobs funds must be used for only salary and related benefits – not general administrative. Ed Jobs can only be used for costs incurred from the date of the grant award notification, or August 10th, 2010 forward.
Because Ed Jobs monies are federal dollars, they must be tracked separately from the State & SFSF portions of education funding.
Additional accounting information can be found here: Home >> Policies and Procedures >> School Finance
Revenue Code 8709 – Ed Jobs, Funding Source 997 – Ed Jobs
The Ed Jobs portion of the BEF is subject to additional reporting requirements:
Quarterly ARRA ‘1512’ Reports: Ed Jobs, while not ARRA, are subject to the reporting requirements set forth under Section 1512 of ARRA (including CCR & DUNS.)
Reminder: if you adjust accounting records, you may also have to correct your 1512 reports
Final Report: Once all funds are expended, a final report verifying the expenditures is due.
For information regarding Social Security Reimbursement, Supplant Questions, please see the USDE August 2010 Guidance. For general ARRA/Reporting questions, see PDE’s ARRA Reporting Page.
Like all Federal Funds, Ed Jobs has general requirements including numerous ‘fiscal’ requirements
Procurement procedures apply to the entire organization,
Ed Jobs will be reviewed as part of your Single Audit.
Full text / Part 80 / Part 74 / Part 668, USDE Cash Mgt Guidance and FAQs
TIPS for Ed Jobs: You can significantly lower the burden of reporting IF you are proactive.
Tip #1 – Advantages to Using Funds on Benefits (Ed Jobs can be used for benefits or salaries)
OMB and USDE have changed guidance multiple times on FTEs;
FTE calculations are complex and time consuming for both LEAs to calculate and for PDE to review/monitor, and for Single Auditors to review (LEAs pay that expense);
Review of employee records, payroll and time keeping systems/procedures, Time and Effort Certifications, Split-Employee accounting, background checks, etc.
Benefits are typically paid to a few vendors which can be easily accounted for, reported, and verified improving transparency as vendor payments tie back to award – FTEs do not;
TIPS for Ed Jobs: You can significantly lower the burden of reporting IF you are proactive.
Tip #2 – Advantages to Using Ed Jobs Funds Immediately
Ties into the use of funds above – by applying this to large vendor payments, the Ed Jobs funds could be quickly expended. Benefits to expending Ed Jobs monies on expenses incurred from 8/10/2010 to 06/30/2011 are:
No chance of excess federal cash (audit findings, interest remit back to feds);
ARRA 1512 Reporting completed sooner;
If high-risk funds extend into another fiscal year, single-audit costs increase.
Summary: By using funds for benefit expenses already incurred (vendor payments), LEAs can complete required reporting sooner, improve transparency and lower administrative costs.
PDE Home -> Hot Topics ARRA Reporting;
Help with Reporting - ARRA Reporting;
Help with Monitoring - ARRA Resources;
For 1512 reporting questions, email: Rafirstname.lastname@example.org.
USDE Ed Jobs: Main Website; August 2010 Guidance; August 2010 Technical Assistance; November 2010 Guidance; Transparency
PDE ARRA Information
PDE Home, Hot Topics-ARRA, ARRA Reporting
ARRA Overview & Reporting
PAEdTrak Security Setup
Quick Guides, FAQs, More
For Help with ARRA Reporting requirements and questions, e-mail: email@example.com
Once PAEdTrak is open and you log on you will be able to access the following:
Review Announcements from PDE regarding ARRA Funds Reporting
Download Data Collection Templates and Instructions
View the list of Reports Submitted this Quarter
Institution Information - (Enter/Confirm/Update)
Upload Report – Upload completed Data Collection reports for the current Reporting Quarter
Help & Contact PAEdTrak
Notify firstname.lastname@example.org if not getting messages.
Verify e-mail on Institution Page – this will be used going forward.
Continuously – report any data corrections or errors to PDE via email above titled “Corrections”
PAEdTrak open from March 15th to 25th.
PDE ARRA Reporting Site
PDE Program Staff
Additional Info: ARRA link at www.education.state.pa.us
The mission of the Pennsylvania Department of Education is to lead and serve the educational community, to enable each individual to grow into an inspired, productive, fulfilled lifelong learner.