American Recovery and Reinvestment Act ARRA

1
American Recovery and Reinvestment Act (ARRA)

• Transparency, Accountability, and Reporting
• Penny Kelly and Bonnie Douglas

2
General Reporting Requirements

• Note Presentation is based on preliminary
  information regarding reporting known as of
  8/3/09 and is subject to change.

3
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

4
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?

5
When Are Reports Due?

• ARRA requires that the states 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
  states report is due.

6
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.

7
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

8
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

9
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

10
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

11
Required Data Elements

• 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

12
ARRA Reporting Variables

• All districts and cooperatives must have a Nine
  Digit Dun and Bradstreet (DUNS) number assigned
  http//fedgov.dnb.com/webform

13
Expenditure Reports

• Transfer of funds by a cooperative to a member
  districts 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.

14
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.

15
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 FTEs created and retained
  for the quarter. Such an estimate would ideally
  be done by taking FTEs 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.

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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

17
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 vendors
  headquarters.

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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.

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Reporting MOE
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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.
21
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.
22
The 50 Rule

• An LEA may treat as local funds up to 50 of the
  amount of funds it is eligible to receivefrom
  that appropriation that exceeds the amount from
  funds appropriated for the previous fiscal year
  that the LEA was eligible to receiveto 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.
  

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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.

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Maintenance of Effort and the 50 Rule

• The Districts MOE is 3,000,000 in FY 09
• The Districts 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
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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?

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Early Intervening Services(EIS) Reporting
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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)?

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Helpful Internet Sites ARRA Recovery Site
http//www.recovery.gov/ ARRA Department of
Education Guidance http//www.ed.gov/policy/gen/le
g/recovery/index.html ARRA-IDEA Part B
Department of Education Guidance
http//www.ed.gov/policy/gen/leg/recovery/guidanc
e/idea-b.pdf State or Federal Project and
Payment Information http//206.166.105.128/FRISIn
quiry/ IDEA 2004 http//idea.ed.gov/explore/home
USDE Office of Special Education http//www.ed
.gov/about/offices/list/osers/osep/index.html
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Contact Information

• IDEA Grant Coordinators Bonnie Douglas and
  Penny Kelly
• 217-782-5589
• bdouglas_at_isbe.net and gkelly_at_isbe.net
• Funding and Disbursements Consultants Kim Lewis
  or Sharon Conrath at 217-782-5589