American Recovery and Reinvestment Act Reporting Policy

Transcription

1 American Recvery and Reinvestment Act Reprting Plicy Updated May

2 I. Backgrund On February 17, 2009, President Barack Obama signed the American Recvery and Reinvestment Act f 2009 (ARRA) int law. The ARRA authrized ver $100 billin in federal funding t be spent n educatin refrm by September 30, As a cnditin t receive these funds, the ARRA is clear that every dllar spent must be subject t unprecedented levels f transparency and accuntability. T achieve this gal, the Office f the State Superintendent f Educatin (OSSE) sets frth the fllwing reprting plicy t ensure cmpliance with ARRA Sectin 1512 reprting requirements. II. Authrity Sectin 1512 f the American Recvery and Reinvestment Act f III. Scpe This plicy applies t the fllwing ARRA grants 1 : ARRA 1003(g) Schl Imprvement Grant (CFDA ) ARRA Enhancing Educatin Thrugh Technlgy (CFDA ) ARRA IDEA, Part B 611 (CFDA ) ARRA IDEA, Part B 619 (CFDA ) ARRA McKinney Vent Hmeless Assistance Act (CFDA ) ARRA State Fiscal Stabilizatin Fund Educatin Stabilizatin (CFDA ) ARRA State Fiscal Stabilizatin Fund Gvernment Services (CFDA ) ARRA Title 1, Part A (CFDA ) IV. Overview f the Reprting Prcess OSSE cllects and reprts bth prime and sub recipient reprting data quarterly t the District f Clumbia (Reprting.dc.gv) as well as the Federal Gvernment (FederalReprting.gv) in accrdance with Sectin 1512 quarterly reprting deadlines. Each entity receiving ARRA funds must, at least quarterly accrding t specific reprting deadlines, cmplete an ARRA Reimbursement and Reprting Wrkbk cntaining the required data elements and submit the wrkbk t OSSE. OSSE, in turn, reprts the required infrmatin n sub recipients behalf t the District f Clumbia s nline data cllectin system (Reprting.dc.gv). Subrecipients may nt reprt directly t either Reprting.dc.gv r FederalReprting.gv. V. Quarterly Reprting In accrdance with the ARRA Sectin 1512 guidance issued by the federal Office f Management and Budget (OMB), data n the use f ARRA funds by recipients (i.e., the state) and sub recipients (i.e., lcal educatinal 1 Grants included in OSSE s ARRA mnitring activities are subject t change withut advance ntice. 2

3 agencies [LEAs] and ther entities receiving funds thrugh the state) are due t the federal gvernment n later than the 10th day after the end f each reprting quarter. T ensure timely, cmplete, and accurate reprting, OSSE requires sub recipients t submit an ARRA Reimbursement and Reprting Wrkbk t OSSE.Reimbursment@dc.gv, at a minimum, quarterly accrding t the fllwing schedule: Reprting Quarter Quarterly Submissin Perids fr Submitting ARRA Reimbursement and Reprting Wrkbks t OSSE III March 17 March 22, 2010 IV June 16 21, 2010 V September 16 21, 2010 VI December 17 22, 2010 VII March 16 21, 2011 VIII June 17 22, 2011 IX September 17 22, 2011 Sub recipients electing t submit mre frequent ARRA Reimbursement and Reprting Wrkbks may d s; hwever, each must submit a signed wrkbk by 5:00 pm n the last day fr each quarterly submissin perid utlined abve. Sub recipients electing nt t submit expenditures fr reimbursement during a given ARRA reprting quarter must still submit a signed wrkbk t OSSE.Reimbursement@dc.gv. OSSE prgram staff will cntact all sub recipients failing t submit an ARRA Reimbursement and Reprting Wrkbk within three business days f the reprting deadline. ARRA Reimbursement and Reprting Wrkbks, with the exceptin f revised wrkbks, received after the last day f the applicable reprting quarter (e.g. a QIII ARRA Reimbursement and Reprting Wrkbk received n r after April 1, 2010) will nt be prcessed fr reprting purpses until the subsequent reprting quarter. VI. Data Cllectin and Reprting Systems and Prcesses OSSE utilizes three data cllectin systems t cllect and reprt ARRA financial and jbs created/retained infrmatin: OSSE s internal Payment Tracking System (PTS) The District f Clumbia s financial system f recrd (SOAR) The District f Clumbia s stimulus reprting database (Reprting.DC.gv). Sub recipients submit an ARRA Reimbursement and Reprting Wrkbks t OSSE. The ARRA Reimbursement and Reprting Wrkbk cntains tabs fr each ARRA grant, enabling the sub recipient t cllect and reprt infrmatin fr all applicable ARRA grants in ne centralized reprt. Sub recipients submit the ARRA Reimbursement and Reprting Wrkbk t OSSE t bth a) fulfill their federal Sectin 1512 reprting requirements and b) seek reimbursement fr expenditures charged against ARRA grant prgrams. Upn receipt f the ARRA Reimbursement and Reprting Wrkbks, OSSE prgram staff enters the expenditure and jb infrmatin in the Payment Tracking System (PTS). Each grant prgram is respnsible fr reviewing and apprving its respective sub recipients ARRA Reimbursement and Reprting Wrkbks in accrdance with PTS perating guidelines (see PTS manual). Additinally, ARRA prgram staff must update the fllwing additinal ARRA specific fields in PTS: 3

4 Applicable ARRA Reprting Quarter FTEs Requested FTEs Apprved Each ARRA Reimbursement and Reprting wrkbk is subject t a multi layer review. Prgram staff cnducts an initial review t verify a) all required fields are cmpleted, b) expenditures submitted fr reimbursement are allwable accrding t prgram requirements and the sub recipient s apprved applicatin, and c) whether the number f FTEs reprted is reasnable. As applicable, prgram staff may cntact sub recipients t request additinal infrmatin and/r t seek clarificatin. Prgram staff reprts the amunt f expenditures and FTEs requested by the sub recipient as well as the amunt apprved accrding t prgram staff s review. Fllwing prgram staff s review, each PTS rder advances t the prgram manager fr anther review and apprval. The prgram manager reviews the sub recipient s submitted infrmatin and enters the amunt f expenditures apprved fr reimbursement as well as the amunt f FTEs apprved fr reprting purpses. The PTS rder is then prcessed fr payment accrding t the steps set frth in the PTS manual. Only Amunt Apprved fr Reimbursement as well as FTEs Apprved data apprved by the Prgram Manager may be reprted fr lcal and federal reprting purpses. Once OSSE reimburses the sub recipient based n the prgram manager Amunt Apprved fr Reimbursement, prgram staff cnsults SOAR, the District f Clumbia s financial system f recrd, t cnfirm payment infrmatin. Each sub recipient is paid frm a purchase rder established fr an amunt equaling the sub recipient s allcatin (ne purchase rder per grant per sub recipient). OSSE establishes a separate purchase rder fr ARRA and nn ARRA grants based n separate Grant Award Ntices (GANs) issued fr ARRA and nn ARRA grants. The purchase rder serves as an internal cntrl t separately track federal funds and t ensure a sub recipient des nt receive payment in excess f its allcatin. Bth prgram staff and the Office f the Agency Fiscal Officer cnfirm available purchase rder funding prir t authrizing payment fr the amunt apprved by the prgram manager. Fllwing payment, the prgram staff then updates payment number, payment date, and payment amunt fields in PTS fr each sub recipient based n the financial data prvided in SOAR. Each reprting quarter, prgram staff updates prime recipient and sub recipient infrmatin in the District s stimulus data cllectin system: Reprting.dc.gv. T infrm quarterly Reprting.dc.gv updates, prgram staff references a number f surce dcuments including, but nt limited t: Grant Award Ntices, SOAR financial reprts, PTS reprts, and draw dwn reprts frm the U.S. Department f Educatin s G5 system. OSSE s Stimulus Crdinatr, as well as the District s ARRA Crdinatr, must review and apprve each ARRA grant file prir t submissin t FederalReprting.gv. OSSE s Stimulus Crdinatr is respnsible fr validating and submitting each ARRA grant file t FederalReprting.gv within the defined federal reprting timeline. Additinally, if the federal agency identifies an issue with a reprt during the review prcess, the OSSE Stimulus Crdinatr is respnsible fr wrking with the apprpriate ARRA grant manager t amend the grant submissin in a timely manner. VII. Prime Recipient Data Elements Prgram staff is respnsible fr cllecting and inputting all prime recipient and sub recipient data int Reprting.DC.gv which is then submitted t FederalReprting.gv n a quarterly basis. As part f the prime recipient respnsibilities, prgram staff must create a unique prfile fr each grant t ensure accurate reprting. Each grant prfile cntains sectins dedicated t general grant infrmatin, funds/awards 4

5 infrmatin, prject infrmatin, prime recipient resurces, prime recipient vendrs, and sub recipient infrmatin. Prtcls fr updating infrmatin are infrmed by bth federal and lcal reprting guidance (e.g. U.S. Department f Educatin Tip Sheets and DC Prime Recipient Reprting Prtcl). Data elements t be cllected and reprted at the prime recipient level fr each grant may include, but are nt limited t: 1. General Infrmatin Prime Recipient DUNS Number Award Number Award Descriptin Award Type OCFO Cde Prime Recipient Accunt Number 2. Funds/Awards Infrmatin Ttal Award Amunt Ttal Federal Amunt ARRA Funds Received/Inviced Ttal Federal Amunt f ARRA Expenditures Ttal Amunt f Subawards 3. Place f Perfrmance Address 4. Prject/Award Infrmatin Award Number Federal Agency Cde Funding Agency Cde Funding Agency Name Awarding Agency Cde Awarding Agency Name Prgram Surce (TAS) CFDA Number Award Date 5. Prject Infrmatin Prject Name Prject Descriptin Prject Status Activity Cde Number f Jbs Descriptin f Jbs Created 6. Prime Recipient Resurces Prject Name r Prgram Title Name Jb Title # f FTEs Created/Retained 7. Prime Recipient Vendrs Vendr Prfile Vendr DUNS Vendr Name 5

6 Vendr Address r Headquarter Zip Cde Prduce and Service Descriptin Payment Amunt # f FTEs Created/Retained 8. Sub Recipient Infrmatin Sub Recipient Name Sub Recipient DUNS Subaward Number (assigned by Prgram Manager) Sub Recipient Cngressinal District Subaward Date Amunt f Subaward Ttal Subaward Funds Disbursed # f FTEs Created/Retained Related Place f Perfrmance VIII. Sub Recipient Data Elements Data elements t be cllected frm each sub recipient, fr each grant, include (1) data that must be reprted t the federal gvernment at the sub recipient level (fr example, the name f the sub recipient and the amunt f each subaward) and (2) data that OSSE needs t cllect frm sub recipients t prperly reprt at the recipient (state) level (fr example, the number f jbs retained r created). Sub recipients are respnsible fr prviding OSSE with individual level data fr jbs created and retained. Sub recipients submit jb data thrugh the ARRA Reimbursement and Reprting Wrkbks at a minimum n a quarterly basis accrding t the schedule set frth in Sectin V. Reprting. Sub recipients must prvide the fllwing data elements t OSSE: 1. Sub Recipient Infrmatin (fr submissin t Reprting.dc.gv) DUNS Number Address 2. ARRA Reimbursement and Reprting Wrkbk Infrmatin (Quarterly) Fr each nn persnnel expenditure submitted: Prgram Categry Budget Categry Schl r Campus where Services were Perfrmed Payee Required r Optinal Set aside (as applicable) Descriptin f gds r services prvided Invice Date Ttal Invice Amunt Check Number Check r Payment Date Amunt Requested Fr each persnnel expenditure submitted: ARRA Funding Surce (Grant Title) 6

7 Name f Emplyee (Last, First) Prgram Categry (refer t apprved budget) Title/Psitin Schl r campus where emplyee wrks Brief jb descriptin Ttal annual salary Ttal salary during this reprting perid Budget/prgram categry Beginning and end date f hurs wrked fr the reimbursement perid Number f hurs wrked by the emplyee during the reimbursement perid (Numeratr) Ttal number f hurs wrked by a full time emplyee in a similar psitin during the reprting perid (3 mnths) (Denminatr) Percent f time charged t each cst bjective/funding surce Fr applicable vendr emplyees: ARRA Funding Surce (Grant Title) Vendr Name Name f Emplyee (Last, First) Vendr DUNS number r Vendr s headquarters zip cde Amunt f ARRA funds paid t the vendr during the reprting perid Cnfirmatin if emplyee was hired/retained as a result f the sub recipient payment Brief jb descriptin Ttal number f hurs wrked by the persn fr the perid f time reprted Ttal number f hurs wrked by a full time emplyee in a similar psitin during the reprting perid (3 mnths) (Denminatr) IX. Reprting Jbs Created/Retained In accrdance with the Office f Management and Budget s (OMB) Memrandum M 10 08, OSSE defines jbs created r retained as thse paid fr by the Recvery Act r will be reimbursed with Recvery Act funds. Jbs partially paid r apprved fr reimbursement with Recvery Act funds will nly be cunted based n the prprtin funded by the Recvery Act. OSSE des nt make subjective judgments n whether a given jbs wuld have existed were it nt fr the Recvery Act. Only hurs wrked that are either directly tied t an actual Recvery Act expenditure r an expenditure apprved fr Reimbursement with Recvery Act funds by the Grant Manager are cunted fr reprting purpses. OSSE reprts jbs in the quarter in which the persnnel expenditure was either (A) apprved fr reimbursement with Recvery Act funds by the Grant Manager (applicable fr prime recipient vendr, subrecipient, and sub recipient emplyees) r (B) paid with Recvery Act funds (applicable fr prime recipient emplyees). All jbs are reprted in terms f full time equivalents (FTEs). Calculating Sub Recipient, Sub Recipient Vendr, and Vendr Jbs: OSSE emplys a reimbursement prcess t pay sub recipients, sub recipient vendrs, and prime recipient vendrs. As such, OSSE implemented a methdlgy fr calculating the number f jbs funded by the Recvery Act that cmpensates fr instances in which a sub recipient r vendr may submit expenditures fr hurs wrked in previus reprting quarters. T ensure the accurate number f FTEs are reprted in these instances, OSSE (1) cmpares hurs wrked by the emplyee t that f a typical emplyee during the 7

8 reimbursement perid 2, (2) nly cnsiders the prtin f hurs wrked that are apprved fr reimbursement with Recvery Act funds (e.g. hurs supprted with Recvery Act funds), and (3) cmpares number f days wrked and sught fr reimbursement t that f a typical federal ARRA reprting quarter 3. OSSE emply the fllwing calculatin t derive # f FTEs created r retained fr sub recipients and vendrs: Hurs wrked by an emplyee during the reimbursement perid divided by Hurs wrked by a typical, full time emplyee during the reimbursement perid times the Percent f salary and benefits charged t the ARRA funding surce (e.g. ARRA IDEA, Part B 611). This prduct is then multiplied by the number f days included in the reimbursement perid divided by the average number f business days in a federal ARRA Reprting Quarter. The utput is Full Time Equivalents (FTEs) Reprted in decimal frm. Sub recipients are NOT required t calculate the number f FTEs created r retained; rather, the ARRA Reimbursement and Reprting Wrkbk autmatically cmputes Full Time Equivalents Reprted based n the data entered by the sub recipient. Depending n the length f the reimbursement perid, a subrecipient may submit persnnel expenditure infrmatin fr a fractin f r mre than ne FTE. 4 OSSE prgram staff and the grant manager review all persnnel and jb reprting infrmatin and ppulate the field Full Time Equivalents Apprved accrdingly. Disallwed persnnel expenditures are nt included in Full Time Equivalents Apprved as these prtins f FTEs will nt be reimbursed with Recvery Act funds. OSSE reprts the number f Full Time Equivalents Apprved t Reprting.dc.gv and FederalReprting.gv. The number f Full Time Equivalents Apprved by the grant manager may differ frm the number f Full Time Equivalents Reprted by the sub recipient. Calculating Prime Recipient Jbs: Prime Recipient Jbs refers t OSSE emplyees whse salaries are paid in full r in part with Recvery Act funds. Only OSSE persnnel with a dcumented payrll expenditure recrded in SOAR during the applicable reprting perid may be cnsidered as a jb funded with Recvery Act funds fr lcal and federal reprting purpses. Fr each ARRA grant, the prgram manager must create a Prime Recipient Resurce prfile fr each emplyee specifying the individual s name and jb title. The prgram manager then creates a crrespnding Prime Recipient Time Card t dcument the number f hurs wrked and funded with Recvery Act mnies each mnth. Based n the hurs wrked infrmatin entered, Reprting.dc.gv then autmatically calculates the ttal number jbs created per quarter by (a) adding the number f hurs wrked by the emplyee during the three mnths cmprising the quarter and (b) dividing that sum by 520 hurs (the number f hurs wrked by a typical full time emplyee assuming a 40 hur wrk week). Reprting.dc.gv aggregates the number f full time emplyees funded by the particular Recvery Act grant per quarter. The ttal number f prime and sub recipient resurces (in terms f fulltime equivalents) funded by the Recvery Act grant is then represented in the summary field Number f Jbs XXX XXX (e.g. Number f Jbs Jan Mar). 2 Reimbursement Perid refers t the perid f time the emplyee wrked fr which the sub recipient is seeking reimbursement. 3 ARRA reprting quarter refers t the federally defined three mnth reprting quarters (e.g. April 1, 2010 t June 31, 2010). 4 OSSE s reimbursement plicy enables sub recipients t submit valid persnnel expenditures at any pint during the applicable grant cycle; therefre, sub recipients may submit wrkbks cntaining reimbursement infrmatin spanning several ARRA reprting quarters at ne time. OSSE s methdlgy fr calculating and reprting jbs accunts fr these challenges and ensures that at the end f the grant cycle all jbs reimbursed with Recvery Act funds are accurately reprted. 8

9 X. Risk Management and Internal Cntrls Over Data Quality T ensure accurate, cmplete, and cmpliant quarterly ARRA quarterly reprting, OSSE implements the fllwing effrts: 1. Autmate Key Features f the ARRA Reimbursement and Reprting Wrkbk OSSE requires each subrecipient t enter the base data that is then autmatically calculated t derive the fields Amunt f Expenditures Requested and Number f Jbs Reprted. OSSE prgram staff then cnducts a thrugh lineitem review fr allwability and enters a crrespnding field Amunt f Expenditures Apprved and Number f Jbs Apprved which are the data pints that are then submitted t lcal and federal reprting systems. The built in functinality f the ARRA Reimbursement and Reprting wrkbk autmatically aggregate these key fields at the grant level t ensure accurate reprting. 2. Utilize Cnsistent, Accurate Data Surces OSSE prgram staff reprt expenditure infrmatin frm the District f Clumbia s SOAR system, revenue infrmatin (i.e. Amunt Drawn Dwn ) frm the GAPS/G5 system, and jb infrmatin frm the Apprved FTEs field in OSSE s Payment Tracking System (PTS). OSSE s reprting prtcls specify the relevant data fields in each used t ppulate grant specific infrmatin in Reprting.dc.gv. 3. Centralize Data Cllectin The District f Clumbia s Reprting.dc.gv platfrm enables District agencies t huse data in ne main system. Each quarter agencies update infrmatin, as required; hwever, the main data fields remain ppulated. The streamlined prcess eases the reprting burden, reduces data entry errrs, and allws agencies t easily exprt data fr internal review and verificatin. 4. Emply a Multi Layer Data Review Prir t submissin t FederalReprting.gv, each ARRA grant file underges a thrugh review by OSSE prgram staff and the grant manager, OSSE Stimulus Crdinatr, and District Stimulus Crdinatr. The reviews invlve crss referencing PTS and SOAR reprts with infrmatin upladed t Reprting.dc.gv, ensuring grant prfile infrmatin aligns with federal guidance, verifying that data elements are lgically related, and cnfirming all required data entry fields are cmplete, etc. The Reprting.dc.gv platfrm requires the apprpriate individuals t apprve each file befre it can advance t the next level and ultimately generate the XML file required fr uplad t FederalReprting.gv. 5. Identify Late/Nn Submitters OSSE cntacts each sub recipient wh des nt submit the required reprting dcumentatin by the deadline. Sub recipients that demnstrate systematic r chrnic deficiencies in meeting their reprting respnsibilities may receive additinal mnitring as well as be required t prvide additinal supprting dcumentatin with their ARRA Reimbursement and Request Wrkbk submissins. 9