Bureau Of Indian Education American Reinvestment & Recovery Act (ARRA) Prime Recipient Reporting Review & Updat

1. Bureau Of Indian Education American Reinvestment &Recovery Act (ARRA)Prime Recipient ReportingReview & UpdatesRepeat SessionsJune 16, 2010June 17, 2010

2. Presenters Dr. Valerie Todacheene ARRA Projects Specialist Division of Performance & Accountability Bureau of Indian Education U.S. Department of Interior Office: 505-563-5269 Fax: 505-563-5281 valerie.todacheene@bie.edu Sandra C. Poolaw ARRA Projects Specialist Division of Performance & Accountability Bureau of Indian Education U.S. Department of Interior Office: 505-563-5429 Fax: 505-563-5281 sandra.poolaw@bie.edu

3. Handouts • Bureau Of Indian Education Recovery Act (ARRA)Prime Recipient Reporting Review & Updates Presentation • BIE Tip Sheets for • Title I, Part A – Improving Basic Programs Operated by Local Educational Agencies, Recovery Act (CFDA 84.389) • Title II-D: Enhancing Education through Technology, Recovery Act (CFDA 84.386) • Title X-Education of Homeless Children and Youths, Recovery Act (CFDA 84.387) • Section 1003(g) – School Improvement Grants, Recovery Act (CFDA 84. 388) • Frequently Asked Questions (FAQ) for Recipients • Number of Jobs Exercise Sheet

4. Overview and Objectives • Reporting Summary • Prime Recipient Responsibilities • Review Process • Recipient Review • Agency Review • Lessons Learned • Specific Data Elements Guidance • Recipient Reporting Examples • Timeline and Activities for Continuous QA • Prime Recipient Required Data • Reporting Assistance • Where to Find Information • Questions

5. Reporting Summary: Prime Recipient The Prime Recipient is each school that receives Recovery Act (ARRA) funding as Federal awards in the form of grants from the Federal Government. Prime Recipients should have already established the following: • Your school or tribe/tribal organization has identified the DUNS number for which you will be reporting • FederalReporting.gov has created and assigned a unique FRPIN to your organization Point Of Contact (POC) as listed in the Central Contractor Registration (CCR) database • Your school or tribe/tribal organization has identified the POC who will serve as your ARRA Reporter during the July 1-14, 2010 reporting period; or has delegated that responsibility to another person in your organization • A Secondary Point of Contact for your report has been identified and information has been provided to DPA, ARRA Specialists

6. Reporting Summary (continued):Review of Relationship Between FederalReporting.gov & Recovery.gov Recovery.gov Reporting Data Portal Federalreporting.gov Recipient Reporting Publish • Provides: • Public data access • Coverage Maps • Standard Reports • Reported Data • Supports: • Recipient • Registration • Recipient Reporting • Report Review and Validation Database Database

7. Review of Basic Prime Recipient Framework Federal Agency Prime Recipient Vendor

8. Prime Recipient Responsibilities • Ultimately responsible for reporting ALL data required by Section 1512 of the Recovery Act and OMB Guidance • Resource: http://www2.ed.gov/policy/gen/leg/recovery/section-1512.html • Must report three additional elements associated with any vendors receiving funds from the prime recipient for payments greater than $25K

9. Agency ReviewConsequences of uncorrected data • Recipients will be given an opportunity to correct the deficiencies before bureaus and offices take enforcement actions • Bureau or office may take proactive action to protect the Federal government’s interests when it is determined a recipient is noncompliant with Section 1512 reporting requirements: • Placing special conditions on awards or precluding the grantee from obtaining future awards for a specified period • Taking action designed to prevent future noncompliance, such as closer monitoring • Withholding, suspending or terminating payment of funds for noncompliance with the reporting requirement • 1st missed report: award official sends a cure notice or other strong letter to remind recipient reporting is mandatory • 2nd missed report: award official will initiate termination action or other strong sanction, including suspension or debarment

10. Reporting is a quarterly responsibility that begins for the reporting period in which the award is made.

11. Prime Recipient required data • Total Number of Payments to Vendors less than $25K/ Award • Total Amount of Payments to Vendors less than $25K/ Award • Total Number of Sub Awards less than $25K/Award • Total Amount of Sub Awards less than $25K/Award • Award Description • Project Name or Project/Program Title • Project Status • Total Federal Amount ARRA Funds Received/Invoiced • Number of Jobs* • Description of Jobs Created • Quarterly Activities/Project Description • Activity Code (NAICS or NTEE-NPC) • Recipient Name* • Award Type • Award Number* • Final Report • Recipient DUNS Number • Recipient Account Number • Recipient Congressional District • Funding Agency Code • Awarding Agency Code • Award Date • Amount of Award* • CFDA Number • Program Source (TAS) • Sub Account Number for Program Source (TAS) • Total Number of Sub Awards to Individuals • Total Amount of Sub Awards to Individuals * If incorrect, OMB currently considers a “Significant Error”

12. Specific Data Elements Guidance:Vendors Less than $25K Reporting • Section 1512(c)(4) and OMB Guidance allows for prime recipients to aggregate reporting on: • Payments to vendors less than $25,000 • Fields on Report: • Total Number of Payments to Vendors less than $25K/ Award • Total Amount of Payments to Vendors less than $25K/ Award

13. Specific Data Elements Guidance:Vendors $25K or more Reporting • Payments to vendors of $25,000 or more • Prime recipients must report required information on each sub-award of $25,000 or more under the Vendor Tab of the report on federalreporting.gov

14. Specific Data Elements Guidance:Number of Jobs • “Jobs Created/Retained” is reported in the “Number of Jobs” field • Number of Jobs is expressed in terms of “full-time equivalents” (FTE) • Number of Jobs is a simple calculation: Total Number of Hours Worked & Funded by Recovery Act within Reporting Quarter Quarterly Hours in a Full-Time Schedule (520 hours) FTE = • Prime recipients should not attempt to report the employment impact upon materials suppliers and central service providers (i.e., indirect jobs) or on the local community • Best practice: maintain documentation of how you calculated Number of Jobs and include a description of the calculation in the “Description of Jobs Created” field.

15. Specific Data Elements Guidance:Description of Jobs Created • Brief description of the types of actual jobs created or jobs retained • Description may rely on job titles • Recipient’s existing practice for describing jobs as long as the terms used are widely understood and describe the general nature of the work • Best practice: Include the CALCULATION of how “Number of Jobs" in the Description of Jobs Created field

16. Recipient ReviewMy Reports

17. Agency Review • Reports are “locked” and may not be freely modified by recipients • Agencies review reports, focusing on fields OMB identified as significant errors: • Recipient Name • Number of jobs retained or created • Federal award number • Recipient name • Recipients are provided with formal comments through FR.GOV • If a recipient receives a comment, the report is “unlocked” and able to be modified for correction • Agencies identify any non-compliant or missing reporters. This information is provided by another department in DOI, DPA does not have access to this information until provided.

18. Agency ReviewSignificant error/material omission • Agencies are required to identify both ‘significant errors’ and ‘material omissions’ • Significant Errors: • Data fields of major concern per OMB are: award amount, number of jobs created / jobs retained, award number and recipient name • If a recipient does not make the requested correction or submit a reasonable explanation of why the data is not incorrect, then the award report is considered to have significant errors. • Material Omissions: • Failure of a Federal ARRA award recipient to report on a received award • Data in a report that is not responsive to a specific data element (e.g., lack of sufficient narrative description) • Significant Errors and Material Omissions are ultimately reported to the Recovery Act Transparency Board and OMB • Recipients that do not report are published on Recovery.gov

19. Recipient & Agency ReviewMaking corrections • Reports may be updated once they have been initially submitted • Reports may be updated at any time during the Initial Submission period • During the Agency Review period, reports may only be updated if the report is “unlocked” with an agency comment • Any Recipient User that has access to the FRPIN for a given DUNS number may update an associated report • Reports may be updated multiple times within the reporting cycle • Report updates may be made via the 3 reporting methods available (i.e., Excel template, online, XML) • Federal agencies do not make updates to reports • Each time a report is submitted, the previous version of that report is replaced

20. Number of Jobs Exerciserefer to Handout

21. Lessons Learned • If the Prime Recipient or Tribe selects “Opt Out” of the CCR Public Search Information, DPAARRA Specialists cannot provide Prime Recipients with reminders of CCR expiration. Our office was able to remind about 10 reporters to update their CCR and avoid issues later. • Grant Award Number must be entered incorrectly (check extension on Tip Sheet for new grant awards) • Reporters need to refer to BIE Tip Sheets for the Project Description field for each ARRA grant report • The “Description of Jobs” field should include the calculation for the resulting number provided in the “Number of Jobs” field. This Description of Jobs must support the Number Jobs.

22. Additional Help in Report Submission • Contacting FederalReporting.gov • FederalReporting.gov allows Recipients to submit and Federal Agencies to review required Recovery Act reporting data. If you need help with registering as a user, submitting a report, reviewing a report, or other website functions, contact their Service Desk. • Service Desk Information • Phone: 877-508-7386 • TTY: 877-881-5186 • Email: Support@FederalReporting.gov • Chat:LivePerson Support

23. Where to find information • FederalReporting.gov • www.federalreporting.gov • Frequently Asked Questions (FAQs) • Service Desk (also on previous slide) • Downloads Tab (Reference Data and Additional Links) • Includes reporting templates, Recipient Reporting Data Model, Webinars, User Guides, Look-ups for congressional districts, agency codes, CFDA numbers, Program Source numbers, and ZIP code information • Recovery.gov website • http://www.recovery.gov/ • Frequently Asked Questions (FAQs) • DOI Recovery website • http://recovery.doi.gov/ • BIEARRA Specialists • Valerie.Todacheene@bie.edu • Sandra.Poolaw@bie.edu

24. BIE Contacts Dr. Jeffrey Hamley E-mail: Jeffrey.Hamley@bie.edu Ph: 505.563.5260 Gaye Leia King E-mail: GayeLeia.King@bie.edu Ph: 505.563.5263 Valerie Todacheene E-mail: Valerie.Todacheene@bie.edu Ph: 505.563.5269 Sandra C. Poolaw E-mail: Sandra.Poolaw@bie.edu Ph: 505.563.5429

25. Questions