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A Microsoft Word version of this letter is available for download
and PRINTING. |
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New ARRA Quarterly Reporting Requirements September 25, 2009
SUBJECT: TO THE ADMINISTRATOR ADDRESSED: Federal law (ARRA Section 1512) requires recipients of ARRA funds to report quarterly on the use of those funds. Those reports will be cumulative and made available for public access at Recovery.gov. The Texas Education Agency (TEA) will submit the required reports and coordinate with recipient LEAs to obtain the necessary information for ARRA funds distributed by TEA through the various grant programs listed below:
Much of the required data will be captured through an LEA’s normal grant expenditure reporting activity in the Expenditure Reporting (ER) system. The required data elements that are not captured are: number of jobs created/retained, description of jobs created/retained, amount of SFSF funds expended on infrastructure investments, description of infrastructure investment and vendors receiving payments of greater than $25,000. TEA is currently modifying the ER system to allow LEA’s to report these fields quarterly. In the case of Shared Services Agreements (SSA) where a fiscal agent of the SSA receives a Notice of Grant Award (NOGA) under one of the programs listed above, the required data elements for member LEA’s that are not captured are: sub-grant award amount, sub-grant award amount disbursed, number of jobs created/retained, description of jobs created/retained, amount of SFSF funds expended on infrastructure investments, description of infrastructure investment and vendors receiving payments of greater than $25,000. TEA is currently modifying the ER system to allow SSA fiscal agents to report these fields for each member LEA quarterly. Reporting Timelines At the state level, TEA must submit quarterly reports to the federal government within 10 days of the end of each quarter. To meet this deadline, TEA is requiring LEAs and SSA fiscal agents to enter the required data identified (including 0 or “none” if applicable) above by 5:00PM CST on the fifth day following the end of each quarter. To enable TEA to meet the federal required deadline, LEAs or SSA fiscal agents who fail to enter the required data within the five day period will be unable to draw down funds pursuant to their NOGA until the data is entered. Continued failure to enter the required data in a timely fashion will result in additional penalties. The following chart summarizes the reporting timelines:
Reporting Procedure Much of the data for Section 1512 quarterly reporting will be captured through normal grant expenditure reporting activity in the ER system. In addition, TEA is in the process of modifying the ER system to allow LEAs and SSA fiscal agents to report required data not captured on a quarterly basis. Once ER modifications are complete, TEA will release guidance and instructions on the process for entering required information. U.S. Department of Education guidance provides:
A job may be counted regardless of whether the employee filling the position is paid for with Recovery Act funds as long as the job would not have been created or retained in the absence of the Recovery Act funding (i.e., Recovery Act funds are either being used to pay the employee or the availability of Recovery Act funds for other purposes is freeing up funds that are being used to pay the employee). TEA recognizes the complexity of using Recovery Act funds under the federal law and guidelines such as those pertaining to the calculation of jobs retained for existing positions that would not have been continued to be filled were in not for Recovery Act funding. Please be advised that we recommend for sufficient documentation for audit purposes, as well as to provide clarity, accurately address federal guidance, and provide the necessary transparency and accountability as required by the Recovery Act, LEAs should have and maintain written documentation (such as local school board minutes or district communications contemporaneous with budget and employment deliberations) demonstrating that each job counted would not have been created or retained in the absence of the Recovery Act funding. Also, only compensated employment in the United States or outlying areas should be counted. (See 74 FR 14824 for definitions.) The number of jobs reported by the state as required by the ARRA should be expressed as “full-time equivalents” (FTE), which is calculated as total hours worked in jobs created or retained, divided by the number of hours in a full-time schedule. For purposes of jobs reporting, there is no distinction between a created and a retained job. Example of number of jobs reporting: Assume that a recipient is preparing its first quarterly report and that the recipient’s Recovery Act funded work required two full-time employees and one part-time employee working half days for the quarter. Also assume that the recipient’s full-time schedule for the quarter is 520 hours (2080 hours in a work-year divided by 4). To convert hours worked to number of FTE for the first quarterly report, aggregate all hours worked and divide by the number of hours in a full-time schedule for the quarter. In this example, full‑time hours worked (520 hrs x 2 employees = 1040 hrs) + part-time hours worked
(260 hrs) ÷ number of hours in a full-time schedule for the quarter (520 hrs) = 2.5 FTEs reported in the first quarterly report. Because jobs are reported cumulatively each quarter, this same number of FTE would be reported for the second quarter if the same number of employees worked the same number of hours. Further guidance on this process will published as available on our website at www.tea.state.tx.us/arrastimulus and in the webinars listed below. Information and Assistance For additional assistance, please contact: NCLB ARRA reporting questions at (512) 463-9374 or nclb@tea.state.tx.us Sincerely,
Jerel Booker  |
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