November 2, 2012
TO THE ADMINISTRATOR ADDRESSED:
SUBJECT: American Recovery and Reinvestment Act of 2009 (ARRA)Section 1512 Quarterly Reporting Continuous Corrections Period
The purpose of this letter is (1) to inform local educational agencies (LEAs) of the continuous corrections period for ARRA Section 1512 Quarterly Reports for the quarter ending September 30, 2012, and (2) to provide additional guidance regarding ARRA reporting requirements related to the renewal of Central Contractor Registration (CCR).
ARRA Section 1512 Quarterly Reporting Continuous Corrections Period—November 5, 2012, through November 30, 2012
A continuous corrections period for ARRA Section 1512 Quarterly Reports is provided by the Texas Education Agency (TEA) approximately five weeks after the end of each reporting quarter.
On Monday, November 5, 2012, TEA will open the expenditure reporting (ER) system to allow corrections to ARRA Section 1512 Quarterly Reports submitted for the quarter ending September 30, 2012, for the following grant programs:
- Education Jobs Fund (Ed Jobs)
- ARRA Title I, School Improvement Grant (SIG) (Texas Title I Priority Schools) as applicable if the grantee’s Notice of Grant Award (NOGA) identifies ARRA SIG funding
The continuous corrections period will close Friday, November 30, 2012, at 5:00 p.m. This corrections period is provided to accommodate LEAs that want to revise data in previously submitted reports for the quarter ending September 30, 2012. No action is necessary unless your LEA has identified data that needs to be corrected. Revisions may only be made to data submitted for the period ending September 30, 2012, for the two programs listed above. All corrections must be submitted by 5:00 p.m. Central Time, Friday, November 30, 2012.
Except for the two programs listed above, all other ARRA grants have ended and no additional ARRA reporting is necessary. TEA appreciates the cooperation of all of the LEAs that have submitted their final ARRA reports for these grants.
Please see Attachment 1 for information about reporting requirements.
New System for Central Contractor Registration (CCR) Annual Renewal
The ARRA Section 1512 Quarterly Reports include a field for the LEA’s CCR expiration date. LEAs that are ARRA grantees are required to register with CCR and receive a Commercial and Government Entity (CAGE) code.
Effective July 29, 2012, the System for Award Management (SAM) combined the federal procurement systems and the Catalog of Federal Domestic Assistance into one new system. The consolidation of SAM includes the functionality from the CCR system. To be able to renew and revalidate its CCR registration, your LEA will be required to create an account in SAM. Please see Attachment 2 for detailed information.
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.
ARRA Section 1512 reporting information is announced on TEA’s website at Recent News and Announcements and through the ARRA Stimulus listserv.
Thank you for your attention to this important matter.
Nora Ibáñez Hancock, EdD
Office for Grants and Federal Fiscal Compliance
For some LEAs, the ARRA Section 1512 Quarterly Report for the quarter ending September 30, 2012, may have been the final report. If an LEA did not submit the report as a final report, the LEA can do so during the continuous corrections period.
The ARRA Section 1512 Report includes a field in which LEAs can indicate that their reports are final. LEAs can submit a final report during the continuous corrections period by changing this field, but should be sure to understand the rules regarding final reports. A project is considered “final” for ARRA reporting purposes only when all four 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 in the “Total Expended Amount” field on the report are less than the total award amount, the LEA must explain the difference.
Provided that an LEA meets all of the above requirements, this final report will be the last ARRA Section 1512 Quarterly Report the LEA will be required to submit. 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.
Reporting ARRA–Funded Jobs
During the continuous corrections period, LEAs may change the total number of jobs that were created or retained and funded with Ed Jobs or ARRA SIG grants as full-time equivalent (FTE) jobs and that were previously reported in the quarterly report. 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 June 30, 2012, but were not able to report the FTEs in the quarterly reports that were due July 5, 2012, should have included these FTEs in the quarterly reports for the quarter ending September 30, 2012, in accordance with US Department of Education (USDE)Clarifying Guidance. LEAs who failed to report FTEs accurately in the quarterly report should use the continuous corrections period to make the necessary corrections. The following guidance applies:
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.
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, 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. TEA will submit the required federal reports and coordinate with LEAs to obtain the necessary information for funds distributed by TEA. Guidance related to ARRA Section 1512 quarterly reporting is available online.
Please refer to USDE Guidance on the Education Jobs Fund Program for additional information on the federal requirements for use of funds.
For additional information about Ed Jobs Fund requirements and guidance from the USDE, please refer to TEA’s Education Jobs Fund website.
ARRA grantees must register with the Central Contractor Registry (CCR) system and then renew and revalidate their registration at least every 12 months 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 information.
Now that SAM is in place, ARRA grantees must create an account in SAM in order to use the functions that were formerly available in the CCR. Once an LEA has created a SAM account, it should follow the instructions to migrate its CCR information into the new SAM system.
Each LEA is responsible for renewing its CCR registration in SAM before the registration expires. An expired CCR registration may impair an LEA’s ability to draw down ARRA grant funds in ER. Upon receiving a new expiration date from the SAM system, LEAs must 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 expiration dates in ER during a ARRA Section 1512 reporting period or continuous corrections period.
Information on SAM is available online at https://www.sam.gov/. Additional information is available from the online Federal Service Desk Answer Center and from the SAM Frequently Asked Questions page.