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Reporting Deadlines and Data Collection System

Letter Head: Tom Torlakson, State Superintendent of Public Instruction, California Department of Education

September 4, 2009

Dear American Recovery and Reinvestment Act Subrecipients:

AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009
SECTION 1512 REPORTING DEADLINES AND DATA COLLECTION SYSTEM

This letter is to follow up on a letter I sent to you on Friday, August 28, 2009, in which I provided information on and recommended next steps to meet the reporting requirements imposed as a condition of receiving American Recovery and Reinvestment Act (ARRA) of 2009 funds. This letter advises subrecipients how and when to submit quarterly reports required by ARRA Section 1512 which applies to all entities receiving ARRA funds. Required reporting includes such matters as the number of jobs created and retained and the status of the project funded.

The first deadline for quarterly reporting is Wednesday September 23, 2009, and it is fast approaching. I advise ARRA subrecipients to review the information in this letter and on the California Department of Education (CDE) Web pages referred to in this letter and to immediately begin collecting the data they need to report and submitting the data as explained in this letter.

ARRA subrecipients include school districts, county offices of education, charter schools, school food authorities, child development administrators, and Special Education Local Plan Areas.

Deadlines for Quarterly Reporting

In accordance with the guidance on ARRA Section 1512 issued by the federal Office of Management and Budget (OMB), data on the use of ARRA funds by recipients (i.e., the state) and subrecipients (i.e., local educational agencies [LEAs] and other entities receiving funds through the state) are due to the federal government no later than the 10th day after the end of each calendar quarter. The first reports are due to the federal government on October 10, 2009, and will cover the period from the effective date of the grant through September 30, 2009.

For the CDE to meet the federal reporting deadline, subrecipients will have to submit data for the first quarterly report to the CDE by Wednesday, September 23, 2009. The early date is required because the CDE is submitting its data to the federal government via a statewide data system being developed by the Governor’s Recovery Act Task Force—which requires submission of data by September 28, 2009.

The CDE recognizes that the deadlines for submission of information are before the end of the reporting period, which will preclude submission of final data for the reporting period. Please see the detailed notes on the individual data items that are available on the Web (see citation below) for information regarding how to handle this issue for particular data items.

Instructions for Reporting

The CDE has constructed a Web-based data collection system to collect information for each grant from subrecipients to comply with ARRA Section 1512 reporting requirements. The data collection system can be found on the CDE ARRA Reporting & Data Collection System Web page at http://www.cde.ca.gov/ar/rr/rptingdatcol.asp. The data system will be open to subrecipients for data submission in the next several days. Information on how to use the data collection system and detailed notes on Section 1512 data fields are provided on the data collection system Web page.

In a separate e-mail, the CDE will issue passwords for the data collection system. These same procedures for password distribution to subrecipients were used to distribute passwords to LEAs for the State Fiscal Stabilization Fund (SFSF) application process. Child development agencies will use their Contract and Tracking System (CATS) user ID and password to obtain access to the data reporting system.

Data Elements

Data elements to be collected from each subrecipient, for each grant, include: (1) data that must be reported to the federal government at the subrecipient level (for example, the name of the subrecipient and the amount of each subaward); and (2) data that the CDE needs to collect from subrecipients to properly report at the recipient (state) level (for example, the number of jobs retained or created).

For ease of reporting, the CDE preloaded as much data as possible, including the subrecipient’s name, address, and grant award amounts. We also provided drop-down or check boxes, to the extent possible, to simplify data entry.

The specific data elements being collected from each subrecipient, for each grant, each quarter, are as follows:

  • The subrecipient’s D-U-N-S Number—a unique nine-digit identification number provided by Dun & Bradstreet (see my previous letter for instructions on applying for a D-U-N-S Number)
  • The subrecipient’s Congressional district, State Senate district, and State Assembly district
  • Names and compensation of each of the subrecipient’s five most highly compensated officers, if applicable (this data will not be required for most subrecipients receiving funds through the CDE)
  • Contact information for the person who can answer questions regarding the data submitted
  • Number of full-time equivalent jobs created or retained as a result of ARRA funding in the reporting period (from the effective date of the grant through the end of the reporting period), separately identified as certificated jobs, classified jobs, or vendor jobs
  • ARRA funds expended or obligated for the reporting period
  • Name and location (zip+4) of any vendor that has received or invoiced more than $25,000 in ARRA funds during the reporting period
  • Information regarding infrastructure expenditures, if any

I encourage you to review the document titled “Data Fields for Quarterly Section 1512 Reporting,” which is available on the CDE ARRA Reporting & Data Collection System Web page at http://www.cde.ca.gov/ar/rr/rptingdatcol.asp. This document contains detailed descriptions of the data elements and will answer many questions about reporting.

We note that questions still remain about the data requirements. Some of the guidance we expect from the U.S. Department of Education (ED) has not yet been released.

It is also possible that the data requirements cited in this letter may change for future reporting periods. In the event of clarifications or changes in requirements, we will change our data collection system to accommodate those changes.

Recommended Actions

It is now time to actually start submitting data through the Web-based data collection system. I advise subrecipients to review the information in this letter and on the CDE ARRA Reporting and Data Collecting Web page at
http://www.cde.ca.gov/ar/rr/rptingdatcol.asp, begin collecting the data needed to report, and submit data as soon as possible. As indicated earlier in this letter, data for the first quarterly report are due Wednesday, September 23, 2009.

In anticipation of the upcoming reporting period, in my earlier letter I advised all subrecipients receiving ARRA funding through the CDE to immediately do the following:

  • Determine whether you have a D-U-N-S Number and apply for one if necessary.
  • Identify and correct any outstanding issues that arose from the SFSF password distribution process. If it is necessary to contact the CDE, please send an e-mail to arra@cde.ca.gov.
  • Sign up for the CDE ARRA listserv by sending a blank e-mail to join-arra-page-updates@mlist.cde.ca.gov.

The federal government is very serious about these reporting requirements and it is essential that data be submitted timely. According to the federal OMB Implementing Guidance, issued June 22, 2009, page 15:

“Federal awards, like most legal contracts, are made with stipulations outlined in the award’s term and conditions. Non-compliance with the reporting requirement as established under section 1512 of the Recovery Act is considered a violation of the award agreement because awards made with Recovery funds have a specific term requiring such compliance. The award term language is found in the Code of Federal Regulations (CFR) in 2 CFR Part 176.50. The Awarding Agency may use any customary remedial actions necessary to ensure compliance, including withholding funds, termination, or suspension and debarment, as appropriate.”

Conclusion

Many questions remain about the reporting requirements, and it is possible that the requirements may change in future quarters. As we receive additional information from the federal government about ARRA Section 1512 requirements—and about program specific reporting—we will share it with you. We will continue to keep you apprised of developments concerning ARRA implementation through the listserv and on the CDE ARRA Web page at http://www.cde.ca.gov/ar/.

In the meanwhile, it is essential that subrecipients immediately begin collecting the data they need to report and submitting the data as explained in this letter.

If you have any questions regarding ARRA reporting, please contact Linda Hakala, Education Fiscal Services Consultant, Fiscal Services Division, by phone at 916-319-0658. You can also send your questions to the Fiscal Policy Office by e-mail at arra@cde.ca.gov.

Sincerely,

JACK O’CONNELL

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