The American Recovery & Reinvestment Act

POLICY

Who reports What to report to

Feds What to report to OFM

OFM Lead: Julie MurrayJulie.Murray@ofm.wa.gov

360-902-0647

TECHNOLOGY

How to register How to submit to OFM

OFM Lead: Muoi NguyMuoi.Nguy@ofm.wa.gov360-664-7699

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Section 1512 is contained in the Recovery Act itself and requires additional reporting to inform the public on how funds are expended at the local level. Who is receiving Recovery Act dollars and what

amounts? What projects and activities are being funded? What is project completion status and impact on job

creation/retention?

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Section 1512 is a report that is IN ADDITION to any other grant or award requirement.

Section 1512 terms/requirements may differ from what is required under grant programs – both new grants and existing programs supplemented with Recovery Act funds.

Non-compliance with Section 1512 reports is a violation of the award or grant and could lead to repayment of those amounts.

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Report due by the 10th day after the end of the calendar quarter. October 10, 2009 January 10, 2010 April 10, 2010, and so on.

Report is due by 11:59 pm EASTERN TIME, so that is 8:59 pm PACIFIC TIME. Website is open on weekends.

Reports are CUMULATIVE. First report covers period of the inception of the

Recovery Act through September 30, 2009.

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Agencies report directly to FederalReporting.gov Agencies will supply OFM with a copy of

FederalReporting.gov submission. Agencies will supply OFM will additional

information to supplement Section 1512 Report

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All state agencies will report: TIMELY COMPLETELY ACCURATELY

No material omissions or significant reporting errors

Washington receives an A+

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OFM expects that agencies will FOLLOW YOUR FEDERAL AWARDING AGENCY’S GUIDANCE. Federal agencies will review your reports to determine

compliance. OMB is deferring to federal agencies and allowing federal

agencies to deviate from OMB guidance and instruction. Follow your federal awarding agency’s guidance FIRST!

OMB and OFM guidance are SECONDARY source. Use FederalReporting.gov help-desk as LAST resort. OFM needs to know when our advice differs from

what your agency tells you. Email it to Julie.Murray@ofm.wa.gov

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FOLLOW YOUR FEDERAL AWARDING AGENCY GUIDANCE

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Many federal agencies are providing their own supplemental guidance and tip sheets on information required for prime recipients.

Check your federal awarding agency directly. Also check: http://www.recovery.gov/?

q=content/agency-guidance-reporting. If you get additional guidance, tip sheets, emails,

etc. on how to report, please provide a copy to Julie.Murray@ofm.wa.gov. We can post the information on RecoveryShare.

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DIVISION A PROGRAMS - YES

State Fiscal Stabilization Funds

Competitive grant programs

Infrastructure programs

Most of the Recovery Act is contained in Division A

DIVISION B PROGRAMS - NO

Entitlement Programs – FMAP, DSH, etc.

Extended unemployment benefits

Tax Provisions Bond and loan

programs

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WHO REPORTS IS A MOVING TARGET

Some Division B programs are being required to report.

Check: http://www.whitehouse.gov/omb/assets/

memoranda_fy2009/m09-21-supp1.pdf Talk to your federal awarding agency.

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YOU DO!Most state agencies are either a:

Prime Recipient Sub-recipient Vendor Any combination of above

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PRIME RECIPIENT is a non-Federal entity that receives Recovery Act funding as Federal awards in the form of grants, loans, or cooperative agreements directly from the Federal government

SUB-RECIPIENT is a non-Federal entity that expends Federal awards received from another entity to carry out a Federal program but does not include an individual who is a beneficiary of such a program.

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VENDOR is a dealer, distributor, merchant, or other seller providing goods and services that are required for the conduct of a federal program.

INDIVIDUAL is generally defined as a sole proprietorship and not beneficiaries of a program.

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VENDOR

Provides the goods and services within normal business operations;

Provides similar goods or services to many different purchasers;

Operates in a competitive environment;

Provides goods or services that are ancillary to the operation of the Federal program; and

Is not subject to compliance requirements of the Federal program.

SUB-RECIPIENT

Determines who is eligible to receive what federal financial assistance;

Has its performance measured against whether the objectives of the Federal program are met;

Has responsibility for programmatic decision making;

Has responsibility for adherence to applicable federal program compliance requirements (the terms and conditions of the federal award are carried forward to the sub-recipient)

Uses the federal funds to carry out a program of the organization as compared to providing goods or services for a program of the prime recipient.

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June 22th OMB Guidance - A sub-recipient is a non-Federal entity that expends

Federal awards received from another entity to carry out a Federal program but does not include an individual who is a beneficiary of such a program.

Supplemental OMB Guidance to NASBO – All state agencies are prime recipients. State agencies

cannot be sub-recipients. All funds between state agencies must be aggregated.

Department of Education – State Fiscal Stabilization Funds – All state agencies receiving funds through their Governor’s

Office are to be reported as sub-recipients.18

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AGENCY THAT RECEIVED FEDERAL AWARD IS PRIME RECIPIENT

Unless otherwise directed by your federal awarding agency, another state agency should be reported as a sub-recipient. If we are to err, it will be on the side of more disclosure and transparency.If you are directed otherwise, let us know. Email Julie.Murray@ofm.wa.gov

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WARNINGCurrent guidance CONFLICTS:

The Recovery Act Federal Regulations OMB June 22nd Guidance & Clarification Webinars Data Dictionary

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This presentation follows the published Data Dictionary.

Follow your federal awarding agency guidance. OFM is providing you guidance to follow in the

absence of more concrete information from your federal awarding agency.

What you need to report: Copy of your federal award External communications and GMAP materials Information collected from sub-recipients and vendors

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Data Dictionary - Title and general description with purpose of each funding action if any. Should capture overall purpose of award.

Can be found on Federal Award Notice OFM Guidance - Add whether the funds are:

Formula funds Competitive grant Cooperative agreement Block grant

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Competitive grant for approved AmeriCorps programs.

Formula funds to capitalize on the state’s Drinking Water State Revolving Fund.

State Fiscal Stabilization Fund (formula funds) - Education Fund- for the support of public elementary, secondary, and postsecondary education and, as, applicable, early childhood education programs and services.

Formula grant program funds for crime victim assistance.

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Data Dictionary – Enter Project Name or Project/Program Title as it EXACTLY appears on Federal Award Notice

OFM Guidance - None

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ARRA AmeriCorps competitive grant WA State Funds for the DWSFR program - ARRA State Fiscal Stabilization Fund – Education Grants Recovery Act – OVC FY 09 VOCA Victim

Compensation Formula Grant Program.

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Data Dictionary - Description of the overall purpose and expected outputs and outcomes or results of the award and first-tier sub-award(s). For an award that funds multiple projects such as a formula block grant, the purpose and outcomes or results may be stated in broad terms.

OFM Guidance: Use information already contained in: Grant application Status reports to your federal awarding agency External communications and website GMAP

Field most likely used by Governor to describe the program.

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Allow the state of Washington to capitalize its revolving loan fund for the financing for the construction of drinking water facilities, green infrastructure, program administration and drinking water related activities. Primary purposes are to preserve and create jobs and promote economic recovery through the investment of infrastructure projects. We anticipate XX projects benefiting XX household and business being funded.

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Data Dictionary – Evaluation of completion status of the project, activity or federally awarded contract. Evaluation should be based on performance progress reports and other relevant non-financial information. Chose: Not started; Less than 50% completed; Completed 50% or more; Fully Completed.

With awards that have multiple projects, report what is closest to the average rate of performance.

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OFM Guidance - Performance differs from expenditures. A contract or program may be 75% complete yet no Recovery Act funds have been expended through a draw-down, reimbursement or invoice. An agency would report “completed: 50% or more”.

Caveat: Some federal awarding agencies are saying to use expenditures to complete this data element.

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Data Dictionary – Use North American Industry Classification System (NAICS) or National Center for Charitable Statistics (NTEE-NPC)

Searchable databases can be found at: NAICS: http://www.census.gov/naics/

NTEE-NPC: http://nccsdataweb.urban.org/PubApps/nteeSearch.php?gQry=all-core&codeType=NPC.

You are allowed up to 10 activity codes to use.

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OFM Guidance - Be as specific as possible. In the case you cannot fit all the detailed codes within

the given constraints, choose the 10 codes that represent the majority of the activities.

Infrastructure programs must use NAICS Codes.

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Data Dictionary - Single piece of data. NOT being asked to measure job created separately from jobs retained.

In reporting number of jobs, EXCLUDE: Employment impact on materials suppliers and central

service providers (so-called “indirect” jobs) Employment impact on the local community (“induced”

jobs). Jobs outside the United States Uncompensated jobs (unpaid internships, volunteers,

etc.) Employment that is not directly charged to Recovery Act

supported projects/activities. 34

Convert jobs “full-time equivalent” (FTE) jobs. In order to perform the calculation, a recipient will need: Total number of hours worked that are charged to Recovery

Act funding. Include all forms of compensation. Number of hours in a full-time schedule for a quarter. In

general, a full-time schedule should be expressed for the quarter as 520 hours.

Cumulative Recovery Act Funded Hours Worked = FTE

Cumulative Hours in a Full-Time Schedule35

You MUST capture jobs from: You, as prime recipient Any of your first-tier vendors Your sub-recipients Your sub-recipients’ first tier vendor

A first-tier vendor is anyone that you or your sub-recipients have a contractual relationship with for the procurement of goods or services.

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Analyze FTEs to show to show ONLY the Recovery Act portion of the project or program.

Example: Five projects 80% funded by state or federal dollars and 20% of it is funded by Recovery Act dollars. This person is entirely devoted to managing these projects.   Person is keeping timesheets for work spent on ONLY

Recovery Act projects or activities. If 8 hours of time is spent 100% on Recovery Act activities, then 8 hours out of a 40 hour workweek, gets you a 0.2 FTE.

 If the person isn’t keeping timesheets, another option is to prorate the workweek. In this case, Recovery Act is 20% of the funds. Report 20% of 1 FTE, which is 0.2 FTE.

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First-tier contractors and vendors are the minimum amount of information to collect.

Federal awarding agencies are more likely to expect second-tier vendor information on infrastructure projects.

OFM Guidance - We would like second-tier vendor (vendors of your vendors) job information. However, consider: Size of purchase. The more minor the purchase, the less

need to collect the information. Quality of the data. Does including subcontractors

materially reduce the accuracy of your numbers. Ability to distinguish between indirect and induced jobs.

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WHO REPORTS

Prime Recipient must report all job information.

Cannot be delegated to anyone else.

Duty to collect, report and ensure accuracy. Includes maintaining

records of sub-recipients and vendors to verify jobs data

REPORTS WHAT?

You, as prime recipient

Any of your first-tier vendors

Your sub-recipients Your sub-recipients’

first-tier vendor

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Data Dictionary – Narrative description of the employment impact of the Recovery Act funded work. Description may rely on job titles, broader labor categories, or the recipients existing practice so long as terms are widely understood.

OFM Guidance - Describe how you collected job information and use North American Industry Classification System (NAICS) for descriptions

Minimum obligation to report at 2-digit level and include both digit and the written description.

NAICS: http://www.census.gov/naics/

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Collected specific data from sub-recipients and vendors to determine FTE attributable to Recovery Act funding. FTEs are providing educational services in elementary and secondary schools (NAICs 6111) and institutions of higher education (NAIC 6113)

Funds being used to support 220 FTEs correctional officers (NAIC 92214) based on statewide accounting/payroll information.

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Data Dictionary - Amount of recovery funds received that were expended to projects or activities (‘‘Federal Share of Expenditures’’).

OFM Guidance – Cut-Off Date Report expenditure data posted in the official accounting

system (AFRS) as of the last calendar day (the Friday before, if the last calendar day falls on a Saturday or Sunday) of the last month of the quarter. Financial data related to expenditures in that calendar quarter, but posted after the last calendar day of the month, should not be included in the Section 1512 report.

This cut-off date flows through the entire report. Use whenever financial data is requested.

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OFM Guidance continued… Include all expenditure data, both cash and accruals,

posted as of the cutoff date. Do not include estimated expenditures for the period, such as cost allocation, labor distribution or payroll costs, posted after the cutoff date.

DO NOT use the Section 1512 report adjustment period (Day 11 through Day 29) to update expenditure data to reflect data posted after the cutoff date.

If there is some reason that you cannot follow this guidance, contact Julie.Murray@ofm.wa.gov to discuss.

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Check with your federal awarding agency. Common themes are: Any project that is subject to Chapter 39.04 RCW (Public

Work), such as the construction, alteration, or repair of public buildings or public works. Excludes minor repairs and decoration; however, many federal awarding agencies are considering this infrastructure.

Any project that the Recovery Act or federal award defines or describes as an “infrastructure” project.

Any project requiring a Governor’s certification.

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Total Recovery Act Infrastructure Expenditure Data Dictionary – Total amount of Recovery Act funds

expended on infrastructure OFM Guidance – This amount should be equal to or less

than total Recovery Act expenditures. Use same cut-off date.

Infrastructure Rationale Data Dictionary – Chose one or more of five purposes to

chose from. OFM Guidance – Include information on how your agency

prioritized projects.

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To preserve and create jobs and promote economic recovery, as well as invest in environmental protection infrastructure that will provide long-term benefits, Washington State distributed Recovery Act transportation funds by 1) advancing projects and jobs that would have otherwise been delayed due to funding shortfalls, 2) advancing projects and jobs that would address high priority highway preservation needs, 3) selecting projects that assist communities most impacted by the recession.

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Primary Place of Performance Data Dictionary – No guidance OMB FAQ - List the municipality impacted by the largest

portion of the Recovery Act award. In the event that it is not possible to determine a single place that is receiving more award funds than others, the State should list the state capitol as the primary place of performance

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OFM Guidance: If you have a single address or location, use it. If there are multiple projects in the same municipality

and those projects in the aggregate represent 50% or more of the award, use the address of the municipality’s city hall, county courthouse, or tribal office.

Address of the capitol:Legislative Building

416 Sid Snyder Avenue S.W.

Olympia, WA 98504-0002

USA

Washington Third Congressional District

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State Fiscal Stabilization Fund – General Government Used to support corrections officers throughout the state

– use state capitol address Drinking Water Revolving Fund

Use to fund 23 projects across the state – use state capitol address

National Institute of Health grant Funds research activities at UW – use UW address

Federal Highway Administration 50% of Safe Schools grants awarded to Seattle – use

Seattle location based on its City Hall address

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Compensation of five highest paid officers is required if if ALL THREE conditions are met: Eighty percent (80%) of gross annual revenue comes

from federal loans, contracts, subcontracts, grants, and cooperative agreements;

Such revenue exceeds $25 million; and Information cannot be obtained from SEC or IRS filings.

OFM Guidance – Not applicable for state agencies. May be applicable to sub-recipients or vendors.

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OMB has decided that VENDOR data for awards LESS THAN $25,000 WILL NOT BE CUMULATIVE one quarter to the next, only cumulative within the same quarter.

If you make two payments to the same vendor within a calendar quarter for $15,000 then it crosses the $25,000 threshold and cannot be aggregated.

However, if you make two payments to the same vendor, one on September 1 and the next on October 15, (which are in two different quarters) then the threshold would not be crossed. You can aggregate this vendor.

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OMB allows prime recipients to delegate responsibility for reporting of certain Section 1512 data elements to sub-recipients.

WASHINGTON WILL NOT BE DELEGATING TO SUB-

RECIPIENTS

YOU WILL REPORT THE DATA

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Applies only to Vendors with Payments over $25,000

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THE LAST TWO SLIDES

The Section 1512 report allows you to aggregate certain data that we want disaggregated (the details).

You should be collecting this data to have an accurate Section 1512 report.

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See Economic Recovery Federal OMB Section 1512 and Washington State Additional 1512 Data Requirements – Illustrated reporting scenario

Walk through the data element requirement document for State Additional 1512 details

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OFM is developing a custom solution for data collection from agencies for both: A copy of the Federal OMB Section 1512 report A separate report for the Washington State required

additional 1512 project/location details at the prime recipient and sub recipient level

Data collection formats: Excel – 1st priority (for quarter ending 9/30/09 reporting) XML – 2nd priority (possible enhancement for future

reporting) Web Form – Low priority from agency survey (not likely

to be developed)

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Working on security component Will use Agency Point of Contacts for user

validation Submittal comment is required for each file

submission May suggest file naming convention and

standard language on submittal comment No complicated business rules built for the 1st

quarterly submission

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Access data submission via the Internet Submit both Federal Template and companion State

Template with supporting details together Unable to submit one without the other since one is

supporting the other Unable to submit if one of these conditions exists:

Any missing required fields or invalid fields Award number not match between the two files

Only able to submit one single set of files at each time

Will accept Excel version in 2003 (xls) – same as OMB’s

Will also accept Excel version in 2007 (xlsx)

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Prime Recipient State Agencies must: Register in www.FederalReporting.gov ASAP Inform OFM when registration is complete Provide DUNS Number, Award Number, and Agency Point

of Contacts to OFM Provide FRPIN to OFM and authorize OFM registrants for

data review purpose OFM will:

Register as Recipient Users for each DUNS Number

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Day 1 – 10th of the month following the quarter end: Collect and compile information required for Federal 1512

and OFM 1512 additional detail data from internal data sources, sub-recipients and vendors

Ensure financial data reported includes only data posted in the Accounting System (AFRS) as of the last calendar day of the quarter

Review data before submission Day 10th – Deadline for reporting (By 8:59 pm PST)

Last day to submit Federal OMB Section 1512 report to www.FederalReporting.gov

Submit a parallel copy of Federal OMB 1512 report and State’s additional project/location details to OFM at the same time

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Day 11 – 21st of the month following the quarter end: Review the submitted data to identify any necessary

adjustments If needed changes are identified, contact sub-recipients and

vendors to submit necessary adjustments Notify OFM that adjustment is necessary Respond to OFM questions about the data submittal Confirm with OFM whether adjustments are needed

Day 21st – Deadline for adjustments (By 8:59 pm PST) Last day to submit adjustments for the Federal OMB Section

1512 quarterly report to www.FederalReporting.gov (locked after this day)

Submit an updated parallel copy of Federal OMB 1512 report and updated State’s additional project/location details to OFM at the same time

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Day 22 – 29th of the month following the quarter end: Be alert for potential federal agency notifications for further

adjustments and respond to their questions about any data submittal

Notify OFM if adjustment is necessary If adjustments are required:

▪ Wait for federal agency notification that the system has been unlocked

▪ Submit necessary adjustments to both www.FederalReporting.gov and OFM

Day 29th – Deadline for last adjustments (By 8:59 pm PST) Last day to submit final adjustments for the Federal OMB

Section 1512 quarterly report to www.FederalReporting.gov Submit an updated parallel copy of Federal OMB 1512 report

and updated State’s additional project/location details to OFM

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Future Data Submission Process/Frequency Update cost information and job information if available

for existing projects Update new or old projects if additions or changes from

previous submitted report Make updates to both the Federal OMB report and

State’s additional project/location detail report Submit both reports to OFM on a monthly basis Start date and monthly cutoff for reporting date to be

determined

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Solicit pilot agencies to submit 1512 data for testing using OMB 1512 Excel Template

Submit static information such as funding agency name, award ID, recipient DUNS, etc., and

Submit dynamic data such as costs or job information for what is available

Contact Muoi.Nguy@ofm.wa.gov if interested in pilot testing

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Excel template to be finalized for the State Additional Data Requirements

Available the week of September 21st

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Presentation materials and handouts from this training is available at www.recovery.wa.gov/presentations

For further information on Recovery Act-related trainings, please contact:

Barbara Burgener Governor’s Recovery Act Training CoordinatorPhone: 360.902.4107 Barbara.Burgener@gov.wa.gov

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Questions & Answers

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