Guidance on ARRA Reporting Requirements from OMB

The American Recovery and Reinvestment Act (ARRA) mandates significant reporting and record-keeping for states and school districts that accept funds. Recent guidance released by the White House's Office of Management and Budget (OMB) details those requirements, including the newly developed online system that will be used to collect the data. While the Department of Education (ED) will soon release further guidance on education-specific stimulus fund reporting, the OMB guidance provides good insight into the effort that will be involved in maintaining public records of stimulus funds and their impact on the economy, including an estimate of jobs created and retained.

The new reporting "solution," www.FederalReporting.gov, will allow recipients of federal stimulus funds to login and enter or upload the necessary reporting information within ten days of the end of each fiscal quarter starting on October 10^th

, 2009. Recipients are divided into two groups. Prime recipients are the recipients who directly receive the federal funds. In the education context, this would be a local education agency (LEA) or public institution of higher education. The second group is the sub-recipient, or a recipient of federal funds via the prime recipient. This could be a specific school within an LEA or an individual research lab within a public university that receives funds.

While the prime recipient could require the sub-recipient to complete its own reporting for its allocation of funds, the prime recipient is ultimately responsible for accurate completion of each reporting cycle. As a result, the prime recipients must conduct a data quality review during the 10 days following the initial submission of data. ED will be required to review each prime recipient's data quality review process.

Over the next eight days, ED will conduct its own review of the submitted data to ensure that it appropriately reflects the funds distributed to each recipient. Any corrections must be completed by the prime recipient within 29 days of the end of the fiscal quarter. This speedy reporting and review process means that all reported data will be publicly available on www.Recovery.gov within 30 days of the end of the fiscal quarter. But many pieces will need to fall perfectly in place for it to work.

First, each prime recipient must have the capacity to implement a data quality review process and ensure that all reported data is correct. Second, ED must have its own capacity to review each submitted record as well. With over 14,000 LEAs and 1,600 public institutions of education, that's a significant amount of oversight.

Beyond that, the OMB guidance requires some very detailed reporting on the part of prime and sub-recipients. In addition to basic identification information like a federal identification number, account number, and contact information, recipients must report information on specific expenditures with rationales, activities and descriptions, officer names and compensation, and details on vendors for services. A very detailed dictionary of all of the required data can be found here.

Perhaps most demanding, however, is the reporting requirement surrounding job creation and retention - an explicit goal of the ARRA. The OMB guidance requires each recipient to calculate the number of full time equivalent (FTE) positions created or retained cumulatively in each quarter by dividing the cumulative ARRA funded hours worked by the cumulative hours in a full-time work schedule. This allows recipients to account for both full-time and part-time employees in their calculations. However, it may require recipients to create new accounting systems to record ARRA funded hours separately from hours funded through other sources including other federal programs. Recipients must also provide a narrative surrounding the jobs created and retained including job titles, labor categories, and descriptions of the nature of work. This reporting requirement, while reflective of the job-saving rhetoric of the ARRA, seems questionable given both the work involved in calculating it and the purely symbolic information it provides.

Further ED guidance on reporting and record-keeping will shed light on the impact these requirements will have on LEAs and public institutions of higher education. But the OMB guidance suggests that the reporting will require significant effort on the parts of all stakeholders in the distribution of ARRA funds. The importance of transparency in the use of these stimulus funds cannot be underestimated. Hopefully the resulting publicly-available data will be worth the effort.

As the reporting data is released, you can count on Ed Money Watch to help make sense of it.