A Microsoft Word version of this letter is available for download and PRINTING.
December 5, 2011
1. American Recovery and Reinvestment Act of 2009 (ARRA) Section 1512
Quarterly Reports Due January 5, 2012
1. ARRA Section 1512 Quarterly Reports Due January 5, 2012
ARRA Section 1512 Quarterly Reports for the October 1 through December 31, 2011, reporting period are due from LEAs to the Texas Education Agency (TEA) by 5:00 p.m. Central Time, January 5, 2012. In order to help LEAs meet the reporting deadline, TEA will open the Expenditure Reporting (ER) system for ARRA Section 1512 Quarterly Reports on Monday, December 12, 2011. The ER system will close at 5:00 p.m. Central Time, January 5, 2012.
This reporting requirement applies to all ARRA funds distributed by TEA for the following grant programs:
For some LEAs, the ARRA Section 1512 Quarterly Report for the quarter ending December 31, 2011, will also be the final report. Beginning with the quarter ending September 30, 2011, TEA modified the ARRA Section 1512 Report to include an additional field in which LEAs can indicate that their reports are final. A project is considered “final” for ARRA reporting purposes when all of the following requirements are met:
Additionally, in instances in which the final subrecipient expenditures listed on the report are less than the total award amount, the LEA must explain why the final amount in the “Total Expended Amount” field does not equal the total award amount.
Provided that an LEA meets all of the above requirements for a particular grant, this final report will be the last ARRA Section 1512 Quarterly Report the LEA will be required to submit for that grant. Please note that if there are mistakes in the final report, the LEA will be required to correct the final report during the subsequent ARRA Section 1512 continuous corrections period.
Because timely, complete, and effective reporting under Section 1512 of ARRA is a term and condition of receiving Recovery Act funding, each quarter, TEA reviews and validates the submitted ARRA Section 1512 Quarterly Report information. TEA staff reviewed the quarterly report information submitted by LEAs during the September 30, 2011, regular and continuous corrections periods and identified 189 LEAs that had incorrectly indicated that one or more of their ARRA Section 1512 Quarterly Reports were “final” reports. As described in the preceding section, a project is considered final for ARRA reporting purposes when all of the following requirements are met:
The 189 LEAs that incorrectly submitted one or more of their ARRA Section 1512 Quarterly Reports as final received grant funds after September 30, 2011. Therefore, those LEAs did not meet all of the requirements to submit a final report. Any funds received by LEAs after September 30, 2011, were not reflected in the Total Expended Amount for the September 30, 2011 Quarterly Report but will be included in the December 31, 2011 Quarterly Report.
As a result, those LEAs that reported the ARRA Section 1512 report as final for the September 30, 2011, reporting period will be required to complete an ARRA Section 1512 Quarterly Report for the quarter ending December 31, 2011. Refer to Attachment B for a list of the 189 LEAs, their affected ARRA grants, the date the funds were received, and the amount. LEAs are reminded that they must also report any applicable vendor information and/or FTE information for any additional reimbursements received after September 30, 2011. TEA staff will be contacting LEAs via email and phone to assist them in meeting the ARRA reporting requirement.
ARRA Section 1512 Quarterly Reporting Requirements
All LEAs with an ARRA Notice of Grant Award (NOGA) must meet the January 5, 2012, quarterly reporting deadline for each NOGA for each program identified above. An ARRA Section 1512 Quarterly Report must be submitted regardless of the following: (1) all of the grant funds have been drawn down, (2) a final expenditure report has been submitted, (3) no grant funds have been expended, (4) there has been no grant activity during the quarter.
Expenditure Reimbursement Requests
As described above, the ER system will open for ARRA Section 1512 quarterly reporting on December 12, 2011. Please plan accordingly in order to meet the quarterly reporting deadline. Please note that quarterly reports submitted close to the end of the reporting period may affect expenditure reimbursement requests. For example, if an LEA certifies and submits an ARRA Section 1512 Quarterly Report two to three business days before the end of the reporting period, the ER system will prevent the submission of any reimbursement requests for that NOGA until the reporting period has ended (January 1, 2012). This is done so that no outstanding reimbursement requests will affect the data quality of the ARRA Section 1512 Quarterly Report.
Additionally, if an LEA submits an ARRA Section 1512 Quarterly Report , and then needs to submit an additional expenditure reimbursement report for December 2011, the LEA must do the following:
LEAs should also note that expenditure reimbursements are only captured in the ARRA Section 1512 Quarterly Report when they have been completely processed in ER and paid to the grantee. Reimbursement requests submitted within the last few days of the quarter may not be reflected in the report.
Reporting ARRA–Funded Jobs
As in previous quarters, LEAs must calculate and report the total number of jobs that were created or retained and funded with ARRA grants as full-time equivalent (FTE) jobs. Federal Office of Management and Budget (OMB) guidance defines a funded job “as one in which the wages or salaries are either paid for or will be reimbursed” with ARRA funding.
LEAs that reimbursed payroll costs for hours worked before September 30, 2011, but were not able to report the FTEs in the quarterly reports that were due October 5, 2011, should include these FTEs in the quarterly reports for the quarter ending December 31, 2011, in accordance with US Department of Education (USDE) Clarifying Guidance released on August 26, 2010, and revised on September 30, 2010.
Question 5 of the USDE Clarifying Guidance and its corresponding answer states:
How should FTEs be reported when funds are expended in one quarter to cover costs incurred in previous quarters?
The OMB guidance released December 18, 2009, defines a funded job as one in which the wages or salaries are either paid for or will be reimbursed with Recovery Act funding. A job that is paid initially with non–Recovery Act dollars may be reported as created or retained so long as such dollars eventually will be reimbursed with Recovery Act funds for the jobs being reported.
To the extent possible, recipients should follow this guidance and report a job in the quarter in which it is worked. However, there may be circumstances in which a job cannot be reported in the quarter in which it is worked. A situation like this might occur if a recipient identifies the positions to be paid with ARRA funds after the end of a quarter or if the recipient uses the ARRA funds for pre-award costs that were not captured in prior quarter reporting. If this situation arises, the job should be reported in the quarter in which Recovery Act funds are expended to pay for the job. Recipients should be consistent in their application of reporting jobs either in the quarter in which the job is worked or in the quarter in which ARRA funds are expended to pay for the job.
OMB and USDE guidance cited above, along with other Resources for LEAs on ARRA Section 1512 reporting, are available on TEA’s website at http://www.tea.state.tx.us/index2.aspx?id=7860&menu_id=934&menu_id2=941.
TEA will conduct two webinars that will provide technical assistance on the ARRA Section 1512 quarterly reporting process. The webinars will be conducted from 9:00 to 11:00 a.m. on Wednesday, December 7, 2011, and from 9:00 to 11:00 a.m. on Tuesday, December 13, 2011.
Please register for the webinar on the TEA website at http://www.tea.state.tx.us/webinar.aspx.
2. Education Jobs Fund (Ed Jobs) Reporting
Most LEAs received their 2010–2012 Ed Jobs NOGA from TEA in May 2011. Section 101 of the Ed Jobs statute, Public Law (P.L.) 111-226, requires that the fund be administered under the terms and conditions of Title XIV and Title XV of ARRA. Therefore, LEAs must report quarterly on the use of Ed Jobs funds as is required for all ARRA grants pursuant to the requirements in Section 1512 of ARRA. For additional information on federal requirements for the use of Ed Jobs funds, please refer to Attachment A.
3. Central Contractor Registration (CCR) Annual Renewal
The ARRA Section 1512 Quarterly Reports include a field for the CCR expiration date. LEAs that are ARRA grantees are required to register with CCR and receive a Commercial and Government Entity (CAGE) code.
If an LEA does not renew its CCR registration, the registration will expire. Failure to renew an expired CCR registration may impair an LEA’s ability to draw down ARRA grant funds in ER. Therefore, TEA strongly suggests that LEAs renew their CCR registration prior to the expiration date. Upon receiving the new expiration date from the CCR system, please remember to update that information in the ARRA Section 1512 Quarterly Reports through TEA’s ER system, as these two systems are not connected and the update will not happen automatically. LEAs may only update their CCR information in ER when ER is open following a reporting quarter or during the continuous corrections period following a reporting quarter. Information on CCR, including registration renewal, is available online at https://www.bpn.gov/ccr/.
TEA will continue to monitor CCR expiration dates through the ARRA Section 1512 Quarterly Reports. If an LEA has renewed its CCR registration through the CCR system and has updated the new number in ER prior to receiving a notice from TEA requesting CCR renewal, the LEA should disregard the notice.
4. ARRA Section 1511 Infrastructure Investment Reports
Grantees are permitted to use funds for infrastructure investments under three grant programs: ARRA IDEA-B Formula, ARRA IDEA-B Preschool, and ARRA SFSF. All LEAs with a NOGA for any of these ARRA grant programs, including both 2009–2010 and 2010–2011 SFSF, must complete an ARRA Section 1511 Report in ER, even if the LEA has chosen not to use funds for infrastructure investments.
ARRA Section 1511 Reports may be submitted in ER at any time, but should be submitted when the LEA is issued a NOGA and must be submitted prior to drawing down funds for infrastructure investment projects. When completing the ARRA Section 1512 Quarterly Reports for these three grant programs, LEAs must ensure that the ARRA Section 1511 Report for each NOGA has also been completed, certified, and submitted. Additionally, LEAs should confirm that the information in the ARRA Section 1511 Report is aligned with the information provided on infrastructure expenditures in the related ARRA Section 1512 Quarterly Report for each NOGA.
5. Enforcement Actions
TEA will continue to monitor ARRA grantees’ compliance with ARRA Section 1511 certification requirements, ARRA Section 1512 quarterly reporting requirements, and annual renewal of CCR registration.
Pursuant to the provisions of the Code of Federal Regulations (CFR) Title 34, §80.43 and §74.62, if a grantee materially fails to comply with any term of an award, whether stated in a federal statute or regulation, an assurance in a grant application, or elsewhere, TEA may take one or more of the following enforcement actions as appropriate in the circumstances:
6. Resources and Assistance
For additional assistance with ARRA Section 1512 quarterly reporting requirements or individual ARRA grants, please contact the following:
ARRA Section 1512 Resource
TEA guidance on ARRA Quarterly Reporting is available on TEA’s website at http://www.tea.state.tx.us/index4.aspx?id=7860&menu_id=934&menu_id2=941.
ARRA Section 1511 Resource
TEA guidance on ARRA Section 1511 Infrastructure Investments is available on TEA’s website at http://www.tea.state.tx.us/index2.aspx?id=2147484239&menu_id=934&menu_id2=941.
Thank you for your attention to this important matter.
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