Recipient Reporting Requirements Section 1512 March 24th, 1:00 - 2:00 pm ET

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Presenters Featured Speakers Judi Fisher, Division Chief, Office of Grants and Contract Management, Division of Policy, Review and Resolution, Employment and Training Administration Lynn Rhodes, Grant Management Specialist, Region 6, Employment and Training Administration

Did your organization listen to the ARRA 1512 Pre-Recorded Webinar? Yes No Not sure

Introduction Purpose: Webinar topics: To discuss the reporting requirements in Section 1512 of the Recovery Act. OMB Guidance M-09-21 M-10-08 TEGL 01-09 Webinar topics: Prime Recipient and Sub-recipient Responsibilities Registration Requirements Reporting Timeline Data Quality Review Job Creation Requirements 8

What is required? Recipient reports required by Section 1512 of ARRA OMB-managed web-based reporting system Detailed information 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) December 18, 2009 (OMB M-10-08 Same reporting requirements apply to Recovery Act grants from all Federal agencies. 9

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 10

What information is included? Total amount of Recovery Act funds received, and of that, the amount spent on projects and activities 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 11

Additional Aggregate Reporting Sub-awards less than $25,000 Sub-awards to individuals ETA has NO sub-awards to individuals Payments to vendors less than $25,000 12

Vendor Required Information Prime Recipient Data: Payments greater than $25,000 Single payment in reporting quarter D-U-N-S or Name and zip code of Headquarters Expenditure amount Expenditure description Sub-Recipient Data: Prime recipient reports unless delegated to sub- recipient 13

When Must Reports Be Submitted? Quarterly within 10 days after the end of each reporting quarter New grants awarded during 1st quarter ending March 31, 2010 Reports are due April 10th 14

How Will Recipients Report? REGISTER Online at www.FederalReporting.gov Must be registered with CCR and have a DUNS number Before end of Quarter REPORT www.FederalReporting.gov is the centralized location for all ARRA Section 1512 recipient reporting 15

Registration– www.FederalReporting.gov OMB-managed central nationwide data collection system for Federal agencies and recipients of Federal awards under Section 1512 of the Recovery Act Registration opened 8/17/09 Must complete one-time registration Recipients must meet certain pre-requisites Early registration strongly recommended! May take two or more days to complete 16

Registration Prime Recipients, delegated Sub-Recipients and Federal agencies will have the ability to: Register for the site and manage their account(s) View and comment on reports Federal Agency Representative or Prime Recipient only Recipients (prime and sub) will have the ability to: Submit reports Update or correct reports when appropriate

Who needs to register? All entities receiving Recovery Act funds Federal Agencies Prime Recipients Delegated Sub-Recipients Note: The reporting system automatically creates a Recipient Point of Contact (POC) 18

Point of Contact FederalReporting.gov automatically registers two individuals as the POC for Recipients The first user for a given DUNS number is the Electronic Business Primary Point of Contact The individual listed in the Central Contractor Registry (CCR) is the Government Business Primary Point of Contact

Responsibilities of Recipient POC Ability to perform all functions of a recipient Assign one or more DUNS Administrators Remove a user identified by the DUNS number Administer FRPIN (Federal Reporting PIN #) Approve/Issue FRPIN in response to user request Deny FRPIN in response to user request Reset/Change FRPIN Can serve as POC for multiple DUNS numbers

Information Needed to Register Pre-Requisites for Registration Valid e-mail address DUNS number (http://fedgov.dnb.com/webform) CCR information (www.ccr.gov) Technology needs for FederalReporting.gov Microsoft Internet Explorer 6.0 or higher Mozilla Firefox 2 or higher (JavaScript enabled) Not accessible on hand-held computers, cell phones, PDAs

Additional Information Needed to Register Federal Agency Information Awarding Agency Code: -DOL - 1600 Funding Agency Code: - DOLETA - 1630 (Code chart is on www.federalreporting.gov) Treasury Account Symbol (TAS) for DOL Green Jobs: 16 0910 0184 If the form seems to want only 4 digits, use the last 4.

Information to Submit Reports Prime Recipients Awarding Agency Name Award number (case and character sensitive) Don’t forget the dashes DUNS number (as shown on award) Delegated Sub-Recipients Prime Recipient DUNS number Prime Award number Transaction type (ETA sub-recipients choose “grant”)

No waivers to reporting requirements will be granted Caution! No waivers to reporting requirements will be granted Non-compliance will be treated as a violation of the award agreement Sanctions will apply Information reported will be posted for public view at www.Recovery.gov 24

Reporting and Review Timeline Days 1-10, Reports Submitted Online at www.FederalReporting.gov REVIEW (Comment Period) Days 11-12, Prime Recipient Review/Revision Ensure complete and accurate information Coordinate any corrections with sub-recipients Days 13-29, Federal Agency review and comment 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 Final Reports available Day 30 at www.Recovery.gov Continuous QA Period Days 33-75 Prime Recipient and Agency correction period Day 75 Final data posted

FederalReporting.gov Timeline and Activities

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

Who is Responsible for Data Quality? Prime Recipient Owns recipient and sub-recipient data Sub-recipient 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

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 is misled or confused by the recipient report

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 a data review protocol Establish procedures for cross-validation of data Determine method for detecting/correcting material omissions

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

Final Quarterly Report will be classified by Federal Agency as: Data Quality Process Final Quarterly 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

New OMB Guidance OMB Memorandum M-10-08 Dated December 18, 2009 Clarifies definitions and non-reporting requirements Requires provision of key award data Clarifies job creation computations Technical changes at federalreporting.gov Updated user manual Technical enhancements

Consequences for Non-Reporting M-10-08, Part 1 Failure to fully submit an accurate and complete Section 1512 report Considered non-compliant Sanctions could apply Non-compliant recipients could face: Federal action Termination of Federal funding Termination of the ability to receive future Federal funds

DOL must provide to grantees: Key Award Information DOL must provide to grantees: Identifier information such as award number Funding information such as CFDA number Other information such as Activity Codes Key award information has been provided to ETA grant recipients through their Regional Office FPO.

M-10-08 Part 2 Updates and replaces Section 5 of M-09-21 Clarifies definitions Simplifies calculation of jobs created Changes requirement to report jobs quarterly Addresses issue of “indirect” jobs

Job Creation Estimates Report an estimate of jobs directly created or retained Record an aggregate number for the jobs created or retained for the quarter in the “Number of Jobs” field Provide a narrative description of the employment impact

Jobs partially funded are counted based on the proportion funded Definitions The wages and salaries are either paid for or will be reimbursed with ARRA funding Job created = new position or existing unfilled position funded by ARRA Job retained = existing position now funded by ARRA Jobs partially funded are counted based on the proportion funded

Additional Clarification The estimate of the number of jobs must be expressed as “full-time equivalents” (FTE) An FTE is calculated as total hours worked (paid) in jobs divided by the number of hours in a full-time schedule Documentation supporting the calculation must be maintained.

Calculating Jobs Estimates Based on a simple calculation used to avoid overstating the number of other than full-time permanent jobs converts part-time or temporary jobs into FTE jobs The total number of hours worked is needed also need the number of hours in a full-time schedule for a quarter

Calculating Jobs Creation Estimates The formula for reporting can be represented as Total Recovery Act Hours Worked within Reporting Quarter Total Hours in a Full-time Schedule per Quarter = FTE

Calculating Jobs Creation Example Quarter 4: October 1 – December 31 Full-time schedule of 520 hours 2,080 hours in a work year divided by 4 Two full-time employees Each employee worked 520 hours in quarter Combined total of 1,040 hours worked One part-time employee 260 hours worked Total of 1,300 hours worked

Calculating Jobs Creation Example This calculation is displayed using the OMB formula below: Recovery Act Hours Worked Within Reporting Quarter 4 (Q= 1,300) Hours in a Fulltime Schedule Per Quarter (Q=520) = Q 2.5 FTE

Calculating Jobs Creation Estimates IMPORTANT Reporting is not cumulative across the project lifecycle and must instead be calculated on a quarterly basis. If the denominator is other than the standard full-time schedule of 520 hours for a quarter Must maintain documentation supporting the number of jobs calculation at the grantee, subgrantee and vendor levels.

Additional Requirements Prime recipients are required to generate an estimate of job impact by directly collecting specific data from subrecipients and vendors on the total number of FTEs resulting from sub-awarded funds Prime recipients should collect the information from all subrecipients and vendors in order to generate the most comprehensive and complete job impact data available

Breaking News! OMB Guidance issued March 22, 2010 M-10-14 Provides clarification on system improvements and requirements

References and Resources www.whitehouse.gov/omb/memoranda/ OMB Memo 09-21 Supplemental Recipient Reporting Data Model www.doleta.gov/directives/ TEGL 1-09 TEGL 1-09 change 1& 2 Resources www.whitehouse.gov/recovery/WebinarTrainingM aterials/ Series of OMB Webinars on ARRA 1512 Reporting 47

ETA Technical Assistance Ongoing from ETA Contact your FPO Questions can be submitted to ETA mailbox at: 1512.reports@dol.gov Responses provided individually FAQ’s posted on ETA Recovery Act website www.doleta.gov/recovery 48

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