American Recovery and Reinvestment Act (ARRA) Transparency, Accountability, and Reporting Penny Kelly and Bonnie Douglas
General Reporting Requirements Note: Presentation is based on preliminary information regarding reporting known as of 8/3/09 and is subject to change.
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
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?
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.
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.
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
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
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
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
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 Required Data Elements
ARRA Reporting Variables • All districts and cooperatives must have a Nine Digit Dun and Bradstreet (DUNS) number assigned http://fedgov.dnb.com/webform
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.
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.
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.
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
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.
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.
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.
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.
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.”
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.
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 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. $2,500,000
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?
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)?
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://188.8.131.52/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
Contact Information • IDEA Grant Coordinators – Bonnie Douglas and Penny Kelly • 217-782-5589 • email@example.com and firstname.lastname@example.org • Funding and Disbursements Consultants – Kim Lewis or Sharon Conrath at 217-782-5589