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American Recovery and Reinvestment Act (ARRA)

Reporting Requirements forSection 4410 Preschool Special Education

September 8, 2010

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Today’s Presenters

Deborah H. Cunningham

Coordinator, Education Management Services, NYSED

Harold Matott

Director of the STAC, Special Aids and Medicaid Units, NYSED

Mary Kogelmann

Director of Fiscal Services, NYSED

James Conway

Director of Audit Services, NYSED

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Background

• The American Recovery and Reinvestment Act (ARRA) was signed into law by President Obama on February 17, 2009.

• ARRA provides $787 billion in tax relief and federal funding for:

- transportation and infrastructure, - energy and the environment, - health and human services, - housing and community renewal, - labor and employment services, - education, and - public safety and defense.

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Background

• The main objectives of ARRA are to save and create jobs and promote economic recovery.

• New York State’s share of ARRA, including the shares’ of its local governments, is $32.4 billion (July 2010 estimate). The largest portion of New York’s share is for Medicaid reimbursement.

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Background

• Of the $32.4 billion for New York State, over $3.0 billion is for education. This funding is received through the State Fiscal Stabilization Fund (SFSF) Education Stabilization Fund (ESF) -- $2.5 billion -- and the SFSF Other Government Services (OGS) Fund -- $549 million.

• The State is using $326.8 million of the OGS Fund to pay for a portion of its share of preschool special education costs (59.5 percent).

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ARRA and Medicaid

• Because ARRA funding can not be used to meet the non-Federal share of Medicaid, only claims for non-Medicaid eligible preschoolers with a disability were paid for with ARRA funding.

• Claims for Medicaid-eligible preschoolers with a disability will be paid for with a State General Fund appropriation instead of ARRA.

• If any claims for Medicaid-eligible preschoolers with a disability were paid for with ARRA funding, then counties will not be allowed to obtain Medicaid reimbursement for those claims.

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Accountability• The President has pledged an unprecedented level of

transparency and accountability.

• ARRA funds are federal grants and subject to all federal reporting requirements.

• Section 1512 of ARRA requires fund recipients to report quarterly.

• Counties must separately account for ARRA revenue and expenditures so they can report how much ARRA funding they provide to each special education vendor they contract with.

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Roles• Prime recipient: NYSED is serving as the prime

recipient for ARRA education funds in New York State, including preschool special education funds.

• Sub-recipient - Counties: Entities whose mission requires them to perform certain functions regardless of grant funds received.

• Vendors – Service Providers: Organizations or businesses which sub-recipients contract for services, but which are not required to provide services absent the contract with the county.

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Reporting

• SED has developed an online ARRA reporting system.

• SED will provide the county official who signed the ARRA application with a user ID and password to access the system at http://portal.nysed.gov/. The county official is referred to as the Director of Special Education in SEDREF – State Education Department Reference File.

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The NYSED Application Business Portalhttp://portal.nysed.gov

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Information to be ReportedSED will enter the following sub-recipient information from the completed ARRA applications into its online reporting system:

- County name and address- Contact name, telephone number and email address- BEDS Code- DUNS Number- CCR registration expiration date

SED will also enter the project code and amount each county received for ARRA AVL #1 and #2. There was not enough ARRA funding to pay every county for its ARRA AVL #2 claims. The State’s General Fund will pay the remaining claims.

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Sub-recipient Information

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Other Information to be ReportedCounties will be required to report the following in the on-line ARRA Reporting System:

- Brief program narrative- Vendor information

Payments to vendors Sub-award ID DUNS number OR vendor/organization name and zip + 4

- Jobs saved and/or created by the county and its vendors

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Vendors are defined as: - Preschool special education providers whose rates

are set by SED’s Rate Setting Unit,- Independent related-service contractors, and - Transportation providers.

Note that some counties are also preschool special education providers because they run their own preschool special education programs. However, counties are considered to be sub-recipients rather than vendors.

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• SED will prepopulate the program narrative from the ARRA application into the reporting system. Counties can accept it, expand upon it or delete it and enter their own narrative.

• To assist the counties with reporting ARRA payments to vendors, SED will provide counties, via email or through the file transfer protocol (FTP) process, with the following information:

– List of preschoolers with a disability who are Medicaid eligible,

– List of preschoolers with a disability who are not Medicaid eligible, and

– ARRA payments to special education service providers whose rates are set by SED’s Rate Setting Unit.

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Sub-recipient Vendor Data

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Jobs Summary• The number of jobs saved and/or created by the county

and its vendors must be reported.

• To avoid overstating the number of jobs saved and created in the case where jobs are part-time or temporary, jobs saved and created are stated in terms of “full-time equivalent” (FTE) jobs.

• Because preschool special education is an ongoing program required by federal and state laws, it is assumed that ARRA funding saved, rather than created, jobs.

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• SED will calculate the number of jobs saved with ARRA funding by special education providers whose rates are set by SED’s Rate Setting Unit. Special education providers include county-run preschool special education programs.

• Counties will calculate the number of jobs saved with ARRA funding by independent related-service contractors and transportation providers.

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SED’s Job Calculation Methodology

• To calculate jobs retained, SED will divide the ARRA funds paid to the vendor or county for salaries and fringe benefits for the quarter by the average salary and fringe benefits of the vendor or county’s preschool special education program for the quarter.

• SED will get the data needed to calculate jobs saved from the claims counties submit to its STAC, Special Aids and Medicaid Unit and the Consolidated Fiscal Reports which preschool special education providers submit to SED’s Rate Setting Unit.

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County Calculation of Jobs SavedCounties can calculate jobs saved by:

1.) Dividing the total number of hours worked during the quarter that were funded by ARRA by the total number of hours in a full-time schedule for the quarter as defined by the vendor, or

2.) Dividing the ARRA funds paid to the vendor for salaries and fringe benefits for the quarter by the average salary and fringe benefits of the vendor for the quarter. This is the same methodology used by SED.

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• Each county must confirm SED’s estimate of jobs saved, which will be prepopulated in the online reporting system, and increase it to reflect jobs saved by independent related-service contractors and transportation providers.

• If you have questions on the number of jobs calculated by SED, contact the STAC unit at http://www.oms.nysed.gov/stac.

• Additional guidance on job estimates is available at http://usny.nysed.gov/arra.

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• The Federal government has revised its guidance and jobs must now be reported in the quarter in which they are worked.

• The Federal government’s and SED’s online reporting systems have not been modified yet to allow for reporting in prior quarters.

• SED and the counties will report jobs saved when the systems have been modified.

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Reporting TimelineARRA funding for preschool special education will be spent within the July - September quarter and therefore counties will only have to report expenditures for that quarter.

- Online System opens on the Portal: 9/9/10

- Deadline for data from sub-recipients: 9/30/10

- NYSED submits report to federal government: 10/14/10

- NYSED makes corrections: 10/15/10-10/21/10

- Federal review and SED corrections: 10/22/10-10/29/10

- Reports published on www.recovery.gov: 10/31/10

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Submission of Data• Sub-recipients, such as school districts and counties,

report on vendor contracts. Sub-recipient vendors do not report directly to NYSED.

• The County Director of Special Education must certify and submit the data.

• NYSED reviews, approves and aggregates the data from sub-recipients and reports it to the federal government on their behalf.

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County Director of Special Education Certifies and Submits Data

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Closing out the Grant• To close out the ARRA grant for preschool

special education, SED will produce a final expenditure report which shows the total amount of ARRA funding each county received.

• SED will reconcile the total on its report with total ARRA preschool special education spending shown on the State’s central accounting system.

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ARRA Monitoring Plan for New York State

• Desk audits of applications and quarterly reports

• On-site monitoring of Education Stabilization Funds, Cafeteria grants and programs funded with Other Government Services Funds

• On-site audits of ARRA ESF, ARRA Title I and ARRA IDEA

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Preschool Programs Monitoring Plan for the 2009-10 School Year

4410 Preschool Special Education Beechbrook 5/4/10; 5/5/10; 5/13/10

4410 Preschool Special Education Eden II 6/10/10; 6/14/10;7/21/10; 7/28/10

4410 Preschool Special Education Jewish Guild for the Blind 5/4/10; 5/5/10; 5/13/10

4410 Preschool Special Education The Lighthouse, Inc. May-June 5/18/10, 5/19/10; 6/3/10

4410 Preschool Special Education Rainbow 7/20/10; 7/27/10; 7/28/10

4410 Preschool Special Education Therapy and Learning Center 5/17/10; 5/18/10; 6/4/10

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Preschool Special Education Monitoring

• All ARRA grant recipients should keep records concerning their use and reporting of ARRA funds to be available for monitoring or audit.

• NYSED’s Special Education Office will inform preschool special education program providers of its intent to monitor and appropriate instructions for preparing for monitoring visits.

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Single Audit Requirements• ARRA Other Government Service (OGS) Fund -

Subject to Single Audit Requirements

• Schedule of Expenditures of Federal Awards- Required for the financial statement period- List individual Federal programs by Federal agency- Name of pass-through agency- Total Federal Awards expended

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Single Audit RequirementsDetermining Federal awards expended

- Based on when activity related to award occurs

- Pertains to events such as Expenditure/expense transactions associated with

grants, cost reimbursement contracts, etc.

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Single Audit Requirements

• For the county fiscal year- Payments made to providers for which

ARRA will reimburse

• Non-Medicaid costs from AVL1 and 2 which were paid during the financial statement period

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Questions

• Frequently asked questions and answers from today’s presentation will be posted on SED’s website and emailed to counties.

• Additional questions on this presentation after today’s training session should be sent to Jessica Morelli from the New York State Association of Counties (NYSAC) at jmorelli@nysac.org. She will compile the questions and forward them to SED to be answered.

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General Information• usny.nysed.gov/arra/• www.ed.gov/recovery/• http://www.oms.nysed.gov/stac

Email your reporting questions to NYSED:arra@mail.nysed.govemscmgts@mail.nysed.gov

Program Questions to: omsstac@mail.nysed.gov

E-mails for Federal guidance:Office of the Inspector General hotline: oig.hotline@ed.govInspector General: rick.rasa@ed.gov

ARRA Resources

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Saving and Creating Jobs and Reforming Education: An Overviewhttp://www.ed.gov/policy/gen/leg/recovery/implementation.html

Federal ARRA Legislationhttp://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_bills&docid=f:h1enr.pdf

OMB Circular A-87 are the cost principles applicable for school districts. http://www.whitehouse.gov/omb/rewrite/circulars/a087/a87_2004.html

Office of Management and Budget: EDGARhttp://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

ARRA Federal Reportingwww.federalreporting.gov

Use of All ARRA Funds Must Comply with Federal Guidance