Recipient Reporting Requirements Section 1512 August 19 th at 3:30pm E.S.T.

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Recipient Reporting Requirements Recipient Reporting Requirements Section 1512Section 1512

August 19August 19thth at 3:30pm E.S.T. at 3:30pm E.S.T.

2Recipient Reporting Requirements Section 1512

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4Recipient Reporting Requirements Section 1512

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5Recipient Reporting Requirements Section 1512

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6Recipient Reporting Requirements Section 1512

Featured Speakers 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

7Recipient Reporting Requirements Section 1512

IntroductionIntroduction

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:

8Recipient Reporting Requirements Section 1512

What is required? 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.

9Recipient Reporting Requirements Section 1512

What ETAWhat ETA Programs are Covered? 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

10Recipient Reporting Requirements Section 1512

Who Must Submit Reports? 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

11Recipient Reporting Requirements Section 1512

What Information Does What Information Does The Report Provide?The Report Provide?

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

12Recipient Reporting Requirements Section 1512

Prime Recipient Required Prime Recipient Required Data Elements Per TEGL 1-09Data Elements Per TEGL 1-09

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

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

13Recipient Reporting Requirements Section 1512

Prime Recipient Required Prime Recipient Required Data Elements 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

14Recipient Reporting Requirements Section 1512

Data Elements Con’tData Elements Con’t

– 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

– 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

15Recipient Reporting Requirements Section 1512

Aggregate Reporting Aggregate Reporting

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

16Recipient Reporting Requirements Section 1512

Sub-Recipient Required Data Sub-Recipient Required Data Elements Per TEGL 1-09Elements 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

17Recipient Reporting Requirements Section 1512

Sub-Recipient Required Sub-Recipient Required Data ElementsData 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)

18Recipient Reporting Requirements Section 1512

Vendor Required Data ElementsVendor 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

19Recipient Reporting Requirements Section 1512

When Must Reports Be Submitted?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

20Recipient Reporting Requirements Section 1512

How Will Recipients Report?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

21Recipient Reporting Requirements Section 1512

Caution!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

22Recipient Reporting Requirements Section 1512

Reporting and Review TimelineReporting and Review Timeline

1. REPORT

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

2. REVIEW (Comment Period)

Days 11-21, Prime Recipient Review/Revision

– Ensure complete and accurate information

– Coordinate any corrections with sub-recipients

Days 22-29, 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

3. RELEASE

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

Final Reports available Day 30 at www.Recovery.gov

23Recipient Reporting Requirements Section 1512

In-bound Recipient Reporting In-bound Recipient Reporting (FederalReporting.gov) Timeline and Activities(FederalReporting.gov) Timeline and Activities

Next quarterly reporting

cycle begins- updates reflected

cumulatively

Next quarterly reporting

cycle begins- updates reflected

cumulatively

Agency, Prime and Sub Recipient

Registration

Agency, Prime and Sub Recipient

Registration

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

Prime Recipients

& Subs Enter Draft Reporting

Data

Prime Recipients

& Subs Enter Draft Reporting

Data

Initial Submission

Initial Submission

1

2

10 days after end

of Quarter

Prime Recipients

Review Data Submitted By Sub(s)

Prime Recipients

Review Data Submitted By Sub(s)

3

Prime Recipients & Subs Make Corrections

Prime Recipients & Subs Make Corrections

4

Agency Review of

Data Submitted

Agency Review of

Data Submitted

Recipient Reports

Published on

Recovery.gov

Recipient Reports

Published on

Recovery.gov

Prime Recipients

& Subs Make

Corrections

Prime Recipients

& Subs Make

Corrections

57

6

Agency “View Only” Agency Comment Period

No less than 35 days prior to the

end of the quarter

9

8

90 days after end of

Quarter

Recipient Report Adjustments Possible

Report Status: Draft Initial

Submission Final

Submission Published

24Recipient Reporting Requirements Section 1512

Managing the Reporting ProcessManaging 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

25Recipient Reporting Requirements Section 1512

Who is Responsible for Who is Responsible for Data Quality?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

26Recipient Reporting Requirements Section 1512

Scope of Data Quality 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 misled or confused by the recipient report

27Recipient Reporting Requirements Section 1512

Suggested Internal Controls Suggested Internal Controls ApproachesApproaches

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

28Recipient Reporting Requirements Section 1512

Data Quality ProcessData 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

29Recipient Reporting Requirements Section 1512

Data Quality ProcessData 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

30Recipient Reporting Requirements Section 1512

Jobs CreationJobs 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

31Recipient Reporting Requirements Section 1512

Jobs Creation or RetainedJobs 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

32Recipient Reporting Requirements Section 1512

Estimates of Job ImpactEstimates 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

33Recipient Reporting Requirements Section 1512

References and ResourcesReferences 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

34Recipient Reporting Requirements Section 1512

ETA Technical AssistanceETA 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

Additional webinars– Beginning in September 2009

• Sept. 14th (save the date)

35Recipient Reporting Requirements Section 1512Please enter your questions into the Chat Room! Please enter your questions into the Chat Room!

Question and Answer PeriodQuestion and Answer Period

36Recipient Reporting Requirements Section 1512

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