June 13, 2011
TO THE ADMINISTRATOR ADDRESSED:
SUBJECTS: 1. American Recovery and Reinvestment Act of 2009 (ARRA) Section 1512 Quarterly
Reports Due June 30, 2011
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
1. ARRA Section 1512 Quarterly Reports—Critical Update
- Expenditure Reporting (ER) System will not be available from Friday, July 1, 2011, through Tuesday, July 5, 2011
- ER will open earlier than usual on June 15, 2011, to assist local educational agencies (LEAs) in meeting the June 30, 2011, reporting deadline
- Quarterly Reporting period June 15, 2011 – June 30, 2011
- Quarterly Reports due by 5:00 p.m. Central Time, June 30, 2011
ARRA Section 1512 Quarterly Reports for the April 1 through June 30, 2011, reporting period are due from LEAs to the Texas Education Agency (TEA) by 5:00 p.m. Central Time, June 30, 2011. The ER system will be unavailable from Friday, July 1, 2011, through Tuesday, July 5, 2011, because of a necessary system upgrade. TEA apologizes for any inconvenience this may cause. In order to help LEAs meet the reporting deadline, on June 15, 2011, TEA will open the ER system earlier than usual to give LEAs sufficient time to report ARRA Section 1512 quarterly data for the quarter ending June 30, 2011. The ER system will close at 5:00 p.m. Central Time, June 30, 2011.
This reporting requirement applies to all ARRA funds distributed by TEA through 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
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 June 30, 2011, quarterly reporting deadline for each NOGA for each program identified above. An ARRA Section 1512 Quarterly Report must be submitted even if any of the following is true: (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 June 15, 2011
As described above, the ER system will open for ARRA Section 1512 quarterly reporting on June 15, 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 June 15 and 30, 2011, the ER system will prevent the submission of a reimbursement request for that NOGA until July 6, 2011, to assure data quality.
When an LEA submits an ARRA Section 1512 Quarterly Report from June 15, 2011 – June 30, 2011, and needs to submit an additional expenditure reimbursement report in June 2011, the LEA must take the following steps:
- Un-certify the report.
- Enter the expenditure reimbursement in ER.
- Wait for the expenditure reimbursement to reach “Paid/Processed” status in ER, which may take two to three business days.
- Re-certify and submit the quarterly report before 5:00 p.m., June 30, 2011. LEAs are reminded that the ER system will be unavailable from Friday, July 1, 2011, through Tuesday, July 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 March 31, 2011, with grant funds from an ARRA NOGA they received after March 31, 2011 (for example, the 2010–2012 Education Jobs Fund), were not able to report the FTEs in the quarterly reports due April 5, 2011. These FTEs should be included in the quarterly reports for the quarter ending June 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/
index2.aspx?id=7860&menu_id=934&menu_id2=941.
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 Webinar
TEA will conduct a webinar that will provide technical assistance on the ARRA Section 1512 quarterly reporting process. The webinar will be conducted from 9:30 to 11:30 a.m. on Tuesday, June 14, 2011, and from 2:00 to 4:00 p.m. on Tuesday, June 21, 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 can be submitted in ER at any time, but they 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.
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.
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
Information and Assistance
For additional assistance with ARRA Section 1512 quarterly reporting requirements or individual ARRA grants, please contact the following:
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. (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).
Sincerely,
Nora Ibáñez Hancock, EdD
Associate Commissioner
Office for Planning, Grants and Evaluation
Attachment - Additional Information on Education Jobs Grant |
