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ARRA
Section 1512 Quarterly Reports Due October 5, 2011
Central
Contractor Registration—Annual Renewal
ARRA
Section 1511 Infrastructure Investment Reports
September
21, 2011
TO
THE ADMINISTRATOR ADDRESSED:
SUBJECT: 1. American Recovery and Reinvestment Act of
2009 (ARRA) Section 1512 2. Education Jobs Fund (Ed Jobs) Reporting
3. Central Contractor Registration—Annual
Renewal
4. ARRA Section 1511 Infrastructure Investment
Reports
5. Enforcement Actions Related to ARRA
Requirements
6. Resources and Assistance
1. ARRA Section 1512 Quarterly Reports
·
Quarterly Reporting period July 1,
2011–September 30, 2011
·
Quarterly Reports due by 5:00 p.m.
Central Time, October 5, 2011
ARRA Section 1512 Quarterly Reports for the July 1 through September
30, 2011, reporting period are due from local educational agencies (LEAs) to
the Texas Education Agency (TEA) by 5:00
p.m. Central Time, October 5, 2011. In order to help LEAs meet the
reporting deadline, TEA will open the Expenditure Reporting (ER) system for
ARRA Section 1512 Quarterly Reports on Wednesday, September 28, 2011. The ER
system will close at 5:00 p.m. Central
Time, October 5, 2011.
This
reporting requirement applies to all ARRA funds distributed by TEA for the following
grant programs:
·
Education Jobs Fund
·
ARRA Title I, Part A
·
ARRA Title I, Part D, Subpart 2
·
ARRA Title I, School Improvement
Program (SIP)
·
ARRA Title I, School Improvement
Grant (SIG) (Texas Title I Priority Schools)
·
ARRA Title II, Part D, Education Technology
(formula and discretionary)
·
ARRA IDEA-B Formula
·
ARRA IDEA-B Preschool
·
ARRA 2009–2010 State Fiscal
Stabilization Fund (2009–2010 SFSF)
·
ARRA 2010–2011 State Fiscal
Stabilization Fund (2010–2011 SFSF)
·
ARRA McKinney-Vento Homeless
Final Report
TEA has modified its ER
system to accommodate the submission of final reports. Beginning with the
quarter ending September 30, 2011, the ARRA Section 1512 Quarterly Reports will
include a field in which the LEA can indicate that its report is final. A
project is considered “final” for ARRA reporting purposes when all of the
following requirements are met:
·
There are no further ARRA expenditures for
the associated award.
·
All expended ARRA funds associated with the
award have been invoiced and received.
·
No additional jobs will be funded.
·
The project status is complete per TEA requirements
and/or performance measures.
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.
ARRA Section 1512 Quarterly Reporting Requirements
All LEAs with an ARRA Notice of Grant Award (NOGA) with an approval
date before July 1, 2011, must meet the October 5, 2011, 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.
ER System Opening September 28, 2011
As described above, the ER system will open for ARRA
Section 1512 quarterly reporting on September 28, 2011. Please plan accordingly in order to
meet the quarterly reporting deadline.
Please note that when an LEA certifies and submits
an ARRA Section 1512 Quarterly Report between September 28 and 30, 2011, the ER
system will prevent the submission of a reimbursement request for that NOGA
until October 1, 2011, to assure data quality.
When an LEA submits an ARRA Section 1512 Quarterly Report
between September 28, and
30, 2011, and needs to submit an
additional expenditure reimbursement report in September 2011, the LEA must
take the following steps:
1.
Un-certify the report.
2.
Enter the expenditure reimbursement in ER.
3.
Wait for the expenditure reimbursement to reach
“Paid/Processed” status in ER, which may take two to three business days.
4.
Re-certify and submit the quarterly report before
5:00 p.m., October 5, 2011.
Accurately Reporting 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 prior to June 30, 2011, with
grant funds from an ARRA NOGA they received after June 30, 2011 (for example,
the 2010–2012 Education Jobs Fund), were not able to report the FTEs in the
quarterly reports that were due June 30, 2011. These FTEs
should be included in the quarterly reports for the quarter ending September 30,
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? (This question updated September 30, 2010, per
updated OMB guidance.)
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/ ARRA Section
1512 Webinars
TEA will conduct two webinars that will
provide technical assistance on the ARRA Section 1512 quarterly reporting
process. The webinars will be conducted from 2:00 to 4:00 p.m. on Tuesday,
September 27, 2011, and on Thursday, September 29, 2011.
Please register for the webinar on the
TEA website at http://www.tea.state.tx.us/webinar.aspx.
Instructions for participation, including the
link to the webinar site and audio specifications will be sent to you via email
after you register.
If you are not able to participate in the scheduled webinar, you will be able to access the recorded webinar 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 the attached document.
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.
ARRA grantees register with CCR only once, but they must
renew and revalidate their registration at least every 12 months from the date
they first registered to ensure that CCR is up to date and corresponds to changes
that may have been made to the Data Universal Numbering System (DUNS) and
Internal Revenue Service (IRS) information.
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 renewals,
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, ensure that the ARRA Section 1511 Report for
each NOGA has been completed, certified, and submitted. Additionally, grantees
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 Related to ARRA Requirements
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:
·
Temporarily
withhold cash payments pending correction of the deficiency, or more severe
enforcement action
·
Disallow
all or part of the cost of an activity or action not in compliance
·
Wholly
or partly suspend or terminate the current award
·
Withhold
further awards for the program
·
Take
other remedies that may be legally available
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 quarterly reporting and ARRA Section 1511 infrastructure
certification: (512) 936-3647 or arrastimulus@tea.state.tx.us
·
SFSF:
(512) 463-9374 or nclb@tea.state.tx.us
·
NCLB
ARRA (including Title II, Part D, ARRA formula funding): (512) 463-9374 or nclb@tea.state.tx.us
·
Title
II, Part D, ARRA competitive funding (Target Tech in Texas): (512) 463-9400 or T3@tea.state.tx.us
·
IDEA
ARRA: (512) 463-9414 or sped@tea.state.tx.us
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
1512 reporting information is announced on TEA’s website at Recent News and Announcements (http://www.tea.state.tx.us/index2.aspx?id=4570&menu_id=934&menu_id2=941)
and through the ARRA Stimulus listserv. LEAs can join the ARRA
Stimulus listserv at http://miller.tea.state.tx.us/cgi-bin/wa?SUBED2=name&A=1&L=ARRA-stimulus&b.x=36&b.y=13).
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.
Sincerely,
Nora
Ibáñez Hancock, EdD
Associate Commissioner
Office for Grants and Fiscal
Compliance
Attachment
Attachment
Additional Information
on Education Jobs Grant
USDE Guidance on the Education Jobs
Fund Program is summarized below:
Federal
Required Use of Funds: Pursuant to the authorizing statute, P.L. 111-226, LEAs must use the Ed Jobs
Fund grant for compensation and benefits and other expenses, such as support
services, necessary to retain existing school-level employees, to recall or
rehire former school-level employees, and to hire new school-level employees,
in order to provide early childhood, elementary, or secondary educational and
related services. Allowable expenditures include, among other things, salaries,
performance bonuses, health insurance, retirement benefits, incentives for
early retirement, pension fund contributions, tuition reimbursement, student
loan repayment assistance, transportation subsidies, and reimbursement for
child-care expenses. All expenditures must support school-level employees. No funds may be expended for central office
employees or for district-wide employees.
Federal
Permissible Use of Funds: LEAs may use the Ed Jobs Fund grant to pay the salaries of teachers and other
employees who provide school-level educational and related services. In
addition to teachers, school-level employees supported with program funds may
include, but are not limited to, principals, assistant principals, academic
coaches, in-service teacher trainers, classroom aides, counselors, librarians,
secretaries, social workers, psychologists, interpreters, physical therapists,
speech therapists, occupational therapists, information technology personnel,
nurses, athletic coaches, security officers, custodians, maintenance workers,
bus drivers, and cafeteria workers.
For an
individual with both LEA–level and school-level responsibilities, an LEA may
use the Ed Jobs Fund grant to pay only that portion of the employee’s salary
and benefits associated with the time spent on allowable (i.e., school-level)
activities. The LEA must maintain documentation (i.e., time and effort records)
substantiating that amount of time. Employees paid from Ed Jobs funds who work
100 percent of their time on school-level activities are not required to
maintain time and effort records.
An LEA may
use the Ed Jobs Fund grant to restore reductions in salaries and benefits and
to implement salary increases for the 2010–2011 or 2011–2012 school years. In
addition, an LEA may use the funds for any additional salary and benefits costs
associated with the elimination of furlough days that had been scheduled for
the 2010–2011 or 2011–2012 school years.
Federal
Statutory Prohibitions on Use of Funds: (1) LEAs may not use the Ed Jobs Fund grant for general
administrative expenses related to the operation of the superintendent's office
or the LEA's board of education, including the salaries and benefits of LEA–level
administrative employees; and (2) funds may not be used for payment of
expenditures for fiscal services, LEA program planners and researchers, and
human resource services. Funds may also not be used for construction,
renovation, remodeling, or repairs.
In addition, the following federal
restrictions on uses of funds apply:
·
An
LEA may not use the Ed Jobs Fund grant to compensate employees for any period
prior to August 10, 2010, the date of enactment of the act.
·
An
LEA may not use the funds to pay for contractual school-level services by
individuals who are not employees of an LEA (e.g., janitors employed by an
outside firm). However, an LEA that contracts with another LEA to provide
educational and related services may use the Ed Jobs Fund grant to pay that
portion of the contract associated with the salaries and benefits of the
employees of the LEA providing the services.
·
An
LEA may not use the Ed Jobs Fund grant to meet pension obligations incurred in prior
school years. However, an LEA may use its funds for pension obligations
accruing on the basis of services that an employee performs during the
2010–2011 or 2011–2012 school years.
Ed Jobs and American Recovery and Reinvestment Act (ARRA)
Federal Requirements
Ed Jobs, like
ARRA, is accompanied by unprecedented levels of federal oversight and
accountability. Please be reminded of the significant federal compliance
obligations, additional federal reporting requirements, and potentially
increased audit exposure related to these funds. As such, LEAs should retain
accurate records related Ed Jobs funds.
Federal Requirement for ARRA Section 1512 Quarterly
Reporting:
Section 101
of the Ed Jobs Fund statute,
P.L. 111-226, requires that the fund be administered under the terms and
conditions of 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. Those Ed Jobs funds
reports will be cumulative and made available to the public online at http://www.recovery.gov/. TEA will submit the required federal
reports and coordinate with recipient LEAs to obtain the necessary information
for funds distributed by TEA. Guidance
related to ARRA Section 1512 quarterly reporting is available at http://www.tea.state.tx.us/ Please refer
to USDE Guidance
on the Education Jobs Fund Program at http://www.tea.state.tx.us/ For additional
information about Ed Jobs Fund requirements and guidance
from the USDE, please refer to TEA’s Education Jobs Fund website at http://www.tea.state.tx.us/
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