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American Recovery and American Recovery and Reinvestment Act (ARRA)Reinvestment Act (ARRA)

Transparency, Accountability, and Transparency, Accountability, and ReportingReporting

Penny Kelly and Bonnie DouglasPenny Kelly and Bonnie Douglas

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General Reporting General Reporting RequirementsRequirements

Note: Presentation is based on Note: Presentation is based on preliminarypreliminary information regarding reporting known as of 8/3/09 and information regarding reporting known as of 8/3/09 and

is subject to change.is subject to change.

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Tracking ARRA FundsTracking ARRA Funds

The State (SEA) is required to report The State (SEA) is required to report ARRA funds separatelyARRA funds separately

SEA must maintain accurate SEA must maintain accurate documentation of all expendituresdocumentation of all expenditures

SEA must ensure data quality and proper SEA must ensure data quality and proper expenditure of ARRA fundsexpenditure of ARRA funds

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Questions Reports Must Answer:Questions Reports Must Answer:

Who is receiving ARRA funds?Who is receiving ARRA funds?

How much are they receiving?How much are they receiving?

What projects or activities are being funded?What projects or activities are being funded?

What is the completion status of the What is the completion status of the projects?projects?

What impact on job creation and retention?What impact on job creation and retention?

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When Are Reports Due?When Are Reports Due?

ARRA requires that the state’s report on ARRA requires that the state’s report on the use of ARRA funding is due no later the use of ARRA funding is due no later than the 10than the 10thth day after the end of each day after the end of each calendar quarter.calendar quarter.

Due to the short timeline, LEAs will need Due to the short timeline, LEAs will need to transmit ARRA data before the day that to transmit ARRA data before the day that the state’s report is due.the state’s report is due.

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Who Reports?Who Reports?

Prime recipients (States) have the primary Prime recipients (States) have the primary responsibility for reporting all data.responsibility for reporting all data.

Sub-recipients (Districts) must report to Sub-recipients (Districts) must report to the state.the state.

Reports are expected to meet the Reports are expected to meet the requirements of recent legislation requirements of recent legislation regarding reporting.regarding reporting.

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Federal Oversight AuthorityFederal Oversight Authority

OMB, Recovery Board, Office of Inspector OMB, Recovery Board, Office of Inspector GeneralGeneralEstablish data quality expectationsEstablish data quality expectationsEstablish data and technical standardsEstablish data and technical standardsCoordinate any centralized reviews of dataCoordinate any centralized reviews of data

Findings by a Federal agency can result in Findings by a Federal agency can result in termination of Federal fundingtermination of Federal funding

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CautionsCautions

No waivers will be granted regarding required No waivers will be granted regarding required reportingreportingReporting elements cannot be combined with Reporting elements cannot be combined with other Federal reporting requirementsother Federal reporting requirementsPrime recipient (state) must avoid double Prime recipient (state) must avoid double countingcountingNon-compliance with reporting requirements is Non-compliance with reporting requirements is considered a violation of the award agreementconsidered a violation of the award agreementReports may be used to assess compliance with Reports may be used to assess compliance with award agreementsaward agreements

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Prime RecipientPrime Recipient

Owns recipient dataOwns recipient data

Initiates appropriate data collection and Initiates appropriate data collection and reporting proceduresreporting procedures

Implements internal control measures to Implements internal control measures to ensure accurate and complete informationensure accurate and complete information

Performs data quality reviews and makes Performs data quality reviews and makes appropriate and timely correctionsappropriate and timely corrections

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Sub-recipientsSub-recipients

Own sub-recipient dataOwn sub-recipient data

Initiates appropriate data collection and Initiates appropriate data collection and reporting proceduresreporting procedures

Implements internal control measures to Implements internal control measures to ensure accurate and complete informationensure accurate and complete information

Reviews information and makes Reviews information and makes appropriate and timely correctionsappropriate and timely corrections

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Required Data ElementsRequired Data Elements

Sub-recipient DUNSSub-recipient DUNS

Sub-recipient typeSub-recipient type

Amount receivedAmount received

Amount awardedAmount awarded

Sub-award dateSub-award date

Sub-award periodSub-award period

Place of performancePlace of performance

Area of benefitArea of benefit

Officer names and Officer names and compensationcompensation

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ARRA Reporting VariablesARRA Reporting Variables

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

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Expenditure ReportsExpenditure Reports

Transfer of funds by a cooperative to a Transfer of funds by a cooperative to a member district’s subgrant member district’s subgrant does notdoes not constitute an expenditure.constitute an expenditure.

Cooperatives must ensure member Cooperatives must ensure member districts have districts have expendedexpended funds that were funds that were subgranted and report the aggregated subgranted and report the aggregated expenditures on their quarterly and final expenditures on their quarterly and final expenditure reportsexpenditure reports. .

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ARRA Reporting VariablesARRA Reporting Variables

All expenditure and other ARRA data must be reported All expenditure and other ARRA data must be reported CUMULATIVELY or year-to-date from the point that CUMULATIVELY or year-to-date from the point that each LEA began expending ARRA funds through the each LEA began expending ARRA funds through the end of each quarterly reporting period.end of each quarterly reporting period.

Each subsequent quarterly report will also be Each subsequent quarterly report will also be cumulative. In other words, the report due January cumulative. In other words, the report due January 2010, will include the data reported through September 2010, will include the data reported through September 2009 and be updated to include data that accumulated 2009 and be updated to include data that accumulated through December 2009. ISBE will aggregate all ARRA through December 2009. ISBE will aggregate all ARRA expenditures across fiscal years for each LEA.expenditures across fiscal years for each LEA.

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ARRA Reporting VariablesARRA Reporting Variables

Jobs Created and RetainedJobs Created and RetainedA job created is a new position created and filled; a job A job created is a new position created and filled; a job retained is an existing position that would not have been retained is an existing position that would not have been continued were it not for ARRA funding. continued were it not for ARRA funding.

FTE – Full Time EquivalencyFTE – Full Time EquivalencyEnter the FTE for each position. This is calculated as total Enter the FTE for each position. This is calculated as total hours worked divided by the number of hours in a full-time hours worked divided by the number of hours in a full-time schedule. The figure should be reflected to two decimal schedule. The figure should be reflected to two decimal places.places.

The number reported should represent a reasonable average The number reported should represent a reasonable average of FTE’s created and retained for the quarter. Such an estimate 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 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 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 single point in time, as long as care is taken that the single point is representative of the quarter for the position.point is representative of the quarter for the position.

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Reporting on Jobs CreationReporting on Jobs Creation

Required to report an estimate of jobs Required to report an estimate of jobs directlydirectly created or retainedcreated or retained

Number of jobs expressed as FTEsNumber of jobs expressed as FTEs

Report includes a job title or labor categoryReport includes a job title or labor category

Report only on “direct” jobsReport only on “direct” jobs

Report on all jobs attributable to an awardReport on all jobs attributable to an award

ISBE is planning to collect this info as a ISBE is planning to collect this info as a component of expenditure reportscomponent of expenditure reports

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ARRA Reporting VariablesARRA Reporting Variables

Awards made to a vendor greater than $25,000:Awards made to a vendor greater than $25,000:A vendor is defined as a dealer, distributor, merchant, or other seller A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of the providing goods or services that are required for the conduct of the program.program.

A vendor: A vendor: (1) Provides the goods and services within normal business operations; (1) Provides the goods and services within normal business operations; (2) Provides similar goods or services to many different purchasers; (2) Provides similar goods or services to many different purchasers; (3) Operates in a competitive environment; (3) Operates in a competitive environment; (4) Provides goods or services that are ancillary to the operation of the (4) Provides goods or services that are ancillary to the operation of the Federal program; andFederal program; and(5) Is not subject to compliance requirements of the Federal program.(5) Is not subject to compliance requirements of the Federal program.

If a sub-recipient (i.e. district or cooperative) awards ARRA funds greater 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 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 program, the sub-recipient must report the identity of the vendor by reporting the DUNS number, if available, or otherwise the name and zip reporting the DUNS number, if available, or otherwise the name and zip code of the vendor’s headquarters. code of the vendor’s headquarters.

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Federal Funding Accountability and Federal Funding Accountability and Transparency Act (FFATA)Transparency Act (FFATA)

Not later than January 1, 2008, the Office of Management and Budget shall, in 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 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 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 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 searchable website, accessible by the public at no cost to access, that includes for each -- each --

(A) the name of the entity receiving the award; (A) the name of the entity receiving the award; (B) the amount of the award; (B) the amount of the award; (C) information on the award including transaction type, funding agency, the (C) information on the award including transaction type, funding agency, the

North American Industry Classification System code or North American Industry Classification System code or Catalog of Federal Domestic AssistanceCatalog of Federal Domestic Assistance number (where applicable), program number (where applicable), program source, and an award title descriptive of the purpose of each funding action; 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 (D) the location of the entity receiving the award and the primary location of performance under the award, including the city, State, congressional performance under the award, including the city, State, congressional district, and country; district, and country;

(E) a unique identifier of the entity receiving the award and of the parent entity (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 of the recipient, should the entity be owned by another entity; and

(F) any other relevant information specified by the Office of Management and (F) any other relevant information specified by the Office of Management and Budget.Budget.

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Reporting MOEReporting MOE

2020

Reporting RequirementReporting 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.

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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.

New Guidance on SupplantingNew Guidance on Supplanting

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The 50% RuleThe 50% Rule

““An LEA may treat as local funds up to 50% of An LEA may treat as local funds up to 50% of the amount of funds it is eligible to receive…from the amount of funds it is eligible to receive…from that appropriation that exceeds the amount from that appropriation that exceeds the amount from funds appropriated for the previous fiscal year funds appropriated for the previous fiscal year that the LEA was eligible to receive…to carry out that the LEA was eligible to receive…to carry out activities that could be supported with funds activities that could be supported with funds under the ESEA regardless of whether the LEA under the ESEA regardless of whether the LEA is using funds under the ESEA for those is using funds under the ESEA for those activities.” activities.”

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For ExampleFor ExampleFY 09 IDEA Allocation = $1,000,000FY 09 IDEA Allocation = $1,000,000

FY 10 IDEA Allocation = $1,000,000FY 10 IDEA Allocation = $1,000,000

FY 10 ARRA IDEA Allocation = $1,000,000FY 10 ARRA IDEA Allocation = $1,000,000

Total FY 10Total FY 10 = $2,000,000 = $2,000,000

Difference between FY 09 and FY 10 is $1,000,000.Difference between FY 09 and FY 10 is $1,000,000.

The 50% rule allows the district to use 50% of this The 50% rule allows the district to use 50% of this amount or amount or $500,000$500,000 to supplant local expenses. to supplant local expenses.

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Maintenance of Effort and the 50% Maintenance of Effort and the 50% RuleRule

The District’s MOE is $3,000,000 in FY 09The District’s MOE is $3,000,000 in FY 09

The District’s MOE is $3,000,000 in FY 10The District’s MOE is $3,000,000 in FY 10

Since the 50 % rule allows the District to use Since the 50 % rule allows the District to use $500,000 to supplant local expenses, the $500,000 to supplant local expenses, the district can subtract this amount from MOE district can subtract this amount from MOE and report the new total, $2,500,000, as the and report the new total, $2,500,000, as the FY 10 MOEFY 10 MOE..

$2,500,000

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MOE QuestionsMOE Questions

Total IDEA Flow Through and IDEA Total IDEA Flow Through and IDEA Preschool Allocations to LEAs?Preschool Allocations to LEAs?

What was the LEAs Determination status?What was the LEAs Determination status?

Reduction of state and local funds taken in Reduction of state and local funds taken in dollars?dollars?

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Early Intervening ServicesEarly Intervening Services(EIS) Reporting(EIS) Reporting

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EIS questionsEIS questions

Was the LEA required to use 15% for EIS due to Was the LEA required to use 15% for EIS due to disproportionality?disproportionality?

What was the amount the LEA was required to spend?What was the amount the LEA was required to spend?

Did an LEA voluntarily use up to 15% for EIS?Did an LEA voluntarily use up to 15% for EIS?

What Amount was voluntarily reserved for EIS?What Amount was voluntarily reserved for EIS?

Total number of children receiving CEIS under IDEA in Total number of children receiving CEIS under IDEA in FY 10?FY 10?

Total number of children who received EIS under IDEA Total number of children who received EIS under IDEA anytime in the past two school years (FY09 and FY10)?anytime in the past two school years (FY09 and FY10)?

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Helpful Internet SitesHelpful Internet SitesARRA Recovery Site :ARRA Recovery Site :http://www.recovery.gov/http://www.recovery.gov/

ARRA Department of Education GuidanceARRA Department of Education Guidancehttp://www.ed.gov/policy/gen/leg/recovery/index.htmlhttp://www.ed.gov/policy/gen/leg/recovery/index.html

ARRA-IDEA Part B Department of Education GuidanceARRA-IDEA Part B Department of Education Guidance http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdfhttp://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdf

State or Federal Project and Payment Information:State or Federal Project and Payment Information:http://206.166.105.128/FRISInquiry/http://206.166.105.128/FRISInquiry/

IDEA 2004IDEA 2004 http://idea.ed.gov/explore/homehttp://idea.ed.gov/explore/home

USDE – Office of Special EducationUSDE – Office of Special Educationhttp://www.ed.gov/about/offices/list/osers/osep/index.htmlhttp://www.ed.gov/about/offices/list/osers/osep/index.html

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Contact InformationContact Information

IDEA Grant Coordinators – Bonnie IDEA Grant Coordinators – Bonnie Douglas and Penny KellyDouglas and Penny Kelly– 217-782-5589217-782-5589– bdouglas@isbe.netbdouglas@isbe.net and and gkelly@isbe.netgkelly@isbe.net

Funding and Disbursements Consultants – Funding and Disbursements Consultants – Kim Lewis or Sharon Conrath at 217-782-Kim Lewis or Sharon Conrath at 217-782-55895589