Posted Date:October 16, 2009
|Author:||Jeff Baker, Director Policy Liaison and Implementation, Federal Student Aid|
Subject: Revisions and Additional Information on ARRA Reporting for the Federal Work-Study Program
In an Electronic Announcement posted to our IFAP website (ifap.ed.gov) on October 9, 2009, we provided specific reporting guidance for schools that received, as part of their 2009-2010 Federal Work-Study (FWS) allocation, at least $25,000 from the American Recovery and Reinvestment Act (ARRA). We attached to that Electronic Announcement a Federal Work-Study Program - ARRA Reporting Tip Sheet (Tip Sheet) that schools should follow when reporting on their ARRA funds under the Federal Work-Study Program.
The following information, in a Question and Answer (Q&A) format, is provided in response to a number of questions we have received as a result of the October 9, Electronic Announcement. All of the questions are written from the perspective of a school. Note that while most of the Q&As simply provide clarification to the earlier guidance, the first two (Q&As #1 and #2) include revisions to the October 9, guidance. All of the Field Numbers referenced in the Q&As refer to the numbers provided on the October 9, Tip Sheet.
The Tip Sheet guidance for Field #22 (Project Status) says to enter the following text: "Federal Work-Study supports payments to individual students throughout the academic year". However, the reporting system will not let me add free text. What is the solution?
Unfortunately, when we prepared the October 9, guidance we were not aware that this field cannot be completed with free text. The solution is to select the appropriate response from one of the values in the "drop down box". The response to be selected is dependent on the relationship between the amounts that will be reported in Field #10 (Amount of Award) and Field #28 (Total Federal Amount of ARRA Expenditure), as follows:
The Tip Sheet guidance for Field #27 (Activity Code) says to enter 'B40'. However, the reporting system rejects that entry. What is the solution?
'B40' (Higher Education) is the correct Activity Code. However, the actual text that must be entered is 'B40 - NTEE'. To complete this field scroll way down on the drop down box (after the set of number codes and after the first set of alpha codes to the second set of alpha codes, where you can select 'B40 - NTEE'.
Must my school report even if we have not yet drawn down any of our 2009-2010 FWS allocation?
Yes. All schools that received $25,000 or more in ARRA funds as part of their 2009-2010 FWS allocation must report even if, as of September 30, 2009, the school had not yet drawn down any 2009-2010 FWS funds. In such cases, while Field #10 and Field #23 must have the award amount entered (see the instructions for those fields on the Tip Sheet), Field #28 will be '$0.00'. Do not enter 'zero' or 'N/A'.
The October 9, guidance refers to the school that was awarded the 2009-2010 FWS funds as the entity that must report. However, as a state school we have been told that all ARRA reporting will be done centrally by our state (or system office). Which is correct? Must each individual state school report on its own or can the state report for us?
We provided the earlier guidance (as well as the guidance in this Electronic Announcement) under the assumption that it would be the school that would be reporting. However, it is possible for a broader entity such as a state or a system office to report on behalf of a school.
The Tip Sheet guidance for Field #4 (Recipient DUNS Number) indicated that we should use the Grantee DUNS number displayed on the school's 2009-2010 Campus-Based Statement of Account. When I attempt to report using that DUNS number, the PIN that was assigned to my school does not work. What is the problem and what is the solution?
The most likely reason for this problem is that when someone at the school registered for ARRA reporting, they used another DUNS number that was assigned to the school and the PIN provided was linked only to that DUNS number. The solution is for someone at the school to register (schools can have more than one registration) using the Campus-Based DUNS number and the PIN that will be assigned to that DUNS number upon registration.
Why does the Tip Sheet say that Field #23 should be the same as Field #10, when my school has not yet drawn down any 2009-2010 FWS funds?
Note that the heading for this field includes the word "Invoiced", and the help text on the reporting site states, "Enter the amount of Recovery Act funds received through draw-down, reimbursement, or invoice". We consider the Campus-Based Statement of Account that included ARRA funds to be an invoice.
Must I exclude the ARRA portion of my FWS allocation to determine the amount of FWS funds that I can transfer to FSEOG and/or Perkins, carry forward or back, use for Job Location and Development (JLD), etc.?
No. Your 2009-2010 FWS allocation is the total of the ARRA portion and the regular portion, plus any supplemental funds you received. Use this total to determine amounts available for other FWS Program uses such transferring funds to FSEOG/Perkins, carrying forward or back funds to another award year, or for JLD activities.
If I used my first draw of 2009-2010 FWS funds to carry back to the 2008-2009 award year, do those 2009-2010 drawn down funds count for ARRA reporting?
Yes. It does not matter what you actually use drawn down 2009-2010 FWS funds for. You use the total amount drawn down from the 2009-2010 allocation in G5, up to the amount of your ARRA award (Tip Sheet Field #10), in reporting for Field #28.
If I carried forward 2008-2009 FWS funds into the 2009-2010 award year and paid FWS students with those funds, how is my ARRA reporting affected?
Under the FWS program rules, you must first use any 2008-2009 FWS funds that you carried forward before you can start drawing from your 2009-2010 FWS allocation. Once you have drawn and used all of your 2008-2009 carry forward FWS funds, your first draw downs from your FWS 2009-2010 allocation are to be used for your ARRA reporting.
My institution initially uses its own funds to pay FWS students and later draws down Federal funds as reimbursement. If I did not draw down any of my 2009-2010 FWS allocation prior to September 30, do I report the disbursements I made to students with my institutional funds?
No. Only funds that you actually draw down from your 2009-2010 FWS allocation are reported as ARRA spending.
Note, as stated in Q&A #3 above, because you were awarded 2009-2010 FWS funds you must report for the quarter ending September 30, 2009, even if you did not draw down any 2009-2010 FWS funds.
As a reminder, while the stated ARRA reporting deadline for the calendar quarter ending September 30, 2009 was October 10, 2009, the ARRA reporting system will remain open through October 21, 2009 to accommodate institutions that are unable to meet the October 10 reporting date due to late notification of FWS reporting guidance from the Department. As we indicated in the October 9, Electronic Announcement, if an institution reports after October 10, the system will ask for a "late justification". For FWS reporting only, institutions may enter "Late notification of Federal Work-Study reporting requirements from the U.S. Department of Education".
Finally, we have been asked why some schools did not see an increase in their 2009-2010 FWS allocation when compared to 2008-2009 even though $200 million of ARRA funds was added to the FWS Program. The reason is that the ARRA provided that the additional $200 million be added to the regular appropriation and not treated as a separate award. Thus, schools that received more than their calculated "fair share" amount because of the "base guarantee" provision in the law would not see an increase from last year. The base guarantee provision states that the first dollars allocated for an award year go to schools in an amount that is equal to the amount the school received for the 1999-2000 award year.
If you have any questions regarding ARRA reporting requirements, contact the Service Desk for Federal Reporting at 877-508-7386 or by email at: Support@FederalReporting.gov.
Thank you for your patience and understanding.