Posted Date: December 31, 2009
|Author:||Jeff Baker, Director Policy Liaison and Implementation, Federal Student Aid|
Subject: Second Quarter Reporting of Federal Work-Study Funds Received Under the American Recovery and Reinvestment Act of 2009 (ARRA).
In a series of Electronic Announcements we posted to our IFAP website (ifap.ed.gov) (September 24, 2009, October 2, 2009, October 9, 2009, and October 16, 2009) we provided information on the reporting requirements for schools that received $25,000 or more in 2009-2010 Federal Work-Study (FWS) funding from the American Recovery and Reinvestment Act (ARRA). More than 80 percent of the schools that were required to report did so and we thank them for their efforts. We have determined that the reason why many of the remaining schools were not able to report last quarter was related to the requirement that the school register and use its campus-based program DUNS number. We have recently sent emails to the financial aid administrator at each of those schools to remind them of the need to properly register their DUNS number (see Q&A #6 below).
The purpose of this Electronic Announcement is to remind schools of the required upcoming reporting for the calendar quarter ending December 31, 2009. It also provides important information on changes made to the reporting requirements and calculations for this current quarter as compared to requirements for the earlier reporting. Most of the changes are the result of efforts by the Office of Management and Budget to strengthen reporting to more properly reflect the impact of ARRA funding. While more information is provided later in this announcement in a Question and Answer (Q&A) format, the following are the major differences between the two reporting periods -
Reporting Window - Generally, recipient's reports for a calendar quarter must be submitted no later than the 10th day of the month following the end of the quarter. This means that January 10, 2010 is the stated deadline for submission of reports by recipients. However, because of the holiday, reports submitted between the January 11 and January 15, 2010 will not be considered late.
Calendar Quarter Only Reporting - We had assumed that each quarter's reporting would be cumulative to include earlier reporting. However, OMB has now determined that each calendar quarter's reporting is to include only activity that occurred during that quarter. For the purposes of FWS reporting, this means that only the amounts of 2009-2010 FWS funds that were drawndown by the school between October 1, 2009 and December 31, 2009 would be included.
Calculation of Full-Time Equivalent (FTE) Job - Because of the change from cumulative reporting to calendar quarter only reporting, the recommended calculation for the number of FTE jobs created or maintained from ARRA funds, has been changed. Please read carefully the discussion of this change that is provided in Q&A #10 below.
Reporting for the Prior Period - As noted earlier, there are a number of schools that, while required to report, were not able to do so last October. While there currently is no process for such schools to report on the earlier period, we expect to receive guidance from OMB on when and how such reporting can be made. Schools should monitor the IFAP website for a posting of that guidance.
Corrections and Updates to Prior Reporting - We have identified (and some schools have self-identified) instances where reporting for the quarter ending September 30, 2009 included incorrect or missing information. While there currently is no mechanism for a school to correct or update its earlier reported data, we expect to receive guidance on when and how such corrections and updates can be made. In the meantime, schools should keep track of any needed changes so that they are ready to adjust the earlier record once the process has been announced.
Second Quarter Reporting of FWS ARRA Activity
Questions and Answers (Q&As)
As noted, we are providing instructions for the reporting of ARRA FWS activity for the quarter ending December 31, 2009 in the following Question and Answer (Q&A) format.
Q1 What is the time period covered by the next reporting requirement?
A1 The reporting period includes transactions that occurred between October 1, 2009 and December 31, 2009. For the purposes of FWS reporting, this means that only the amounts of 2009-2010 FWS funds that were drawndown by the school between October 1, 2009 and December 31, 2009 would be included.
Q2 What specific 2009-2010 FWS transactions are included for the FWS Program?
A2 The transactions to be included are only the net amount of a school's actual cash draws (including adjustments) of 2009-2010 FWS funds that occurred between October 1, 2009 and December 31, 2009.
Q3 What is the reporting window for the calendar quarter ending December 31, 2009?
A3 Generally, recipient's reports for a calendar quarter must be submitted no later than the 10th day of the month following the end of the quarter. This means that January 10, 2010 is the stated deadline for submission of reports by recipients. However, because of the holiday, reports submitted between the January 11 and January 15, 2010 will not be considered late.
Q4 Is there a place to get comprehensive information about the ARRA Recipient Reporting Process?
A4 Yes, the federalreporting.gov website provides much useful information on the ARRA reporting requirements. Also at the bottom of their homepage is a link to a "User Guide" - https://www.federalreporting.gov/federalreporting/downloads.do#docs.
Q5 Can you provide additional information on the DUNS Number registration process?
A5 The first step for reporting a school's ARRA 2009-2010 FWS activity is, if the school has not already done so, to register with www.federalreporting.gov. To register, a school must have a Federal Reporting Personal Identification Number (FRPIN) for its DUNS Number and must register its DUNS Number with Central Contractor Registration (CCR) and Dun & Bradstreet (D&B).
If you did not report last quarter, go to federalreporting.gov for information about how to register:
- Before a school can submit ARRA reports to federalreporting.gov, it must complete the one-time registration process. This may take 2 business days or more to complete.
- The school must know the DUNS number that will be associated with the reporting of the FWS funds (see Data Item #4 in the ARRA Reporting Template).
- That DUNS number must also be registered in the Central Contractor Registration (CCR) database. (Go to https://www.bpn.gov/ccr/default.aspx to register.)
- Go to federalreporting.gov to create a User ID and Password.
- When your registration is complete, you will receive an email confirmation and be ready to begin reporting
For more information, please consult the FAQ section of federalreporting.gov. For questions and help with the ARRA reporting process, the FederalReporting.gov Service Desk is available at 877-508-7386, Monday through Friday 8:00 am to 6:00 pm (ET).
Q6 Is there a way to copy information provided in the last quarter's report to the new report, so that a school does not need to re-enter things like its address and its congressional district?
A6 The federalreporting.gov website has developed a COPY FORWARD function (see Chapter 15 of the User Guide referred to in Q&A #4). Schools have the option to copy their report from the previous quarter using the "Copy Forward" button. Note that you will need to review the pre-populated data and update or modify as needed for the current reporting period. At a minimum, the following fields will need to be updated following the ARRA Reporting Template instructions provided in Q&A #11.
- Field # 2 - Award Number
- Field # 3 - Final Report
- Field #10 - Amount of Award: This amount should not have changed since the last quarter's reporting, but schools should double check by following the instructions.
- Field #22 - Project Status
- Field #24 - Number of Jobs
- Field #28 - Total Federal Amount of ARRA Expenditure [for the reporting quarter].
- Fields #48- #50: Recipient Highly Compensated Officers: Update as needed
Q7 How can a school determine how much of its 2009-2010 FWS allocation was from the ARRA?
A7 The amount that should be used for reporting purposes was included on each school's Campus-Based Statement of Account for the 2009-2010 award year. A school can also view the "Portion Attributed to ARRA 2009-2010" column of the .
Q8 Is the specific, data item by data item, reporting information that was provided in the October 16 Electronic Announcement applicable for reporting for the quarter ending December 31, 2009?
A8 Except for the modified FTE job creation formula that is described below in Q&A #10 and a few other minor changes/clarifications that are explained in Q&A #11, all of the information provided for the first quarter's reporting remain in effect. The specific item by item information was provided in a Federal Work-Study Program - ARRA Reporting Tip Sheet attached to the October 9 Electronic Announcement.
Q9 What are the assumptions and conventions that are used when reporting?
A9 For administrative ease and reporting consistency, assumptions and reporting conventions have been established for the reporting of ARRA FWS activity for the calendar quarter ending December 31, 2009, as follows:
a. The first funds drawn from the school's 2009-2010 FWS allocation are assumed to be ARRA funds, up to the amount of the ARRA portion of the school's 2009-2010 FWS award (see Q&A #7).
b. Total ARRA expenditures to be reported are equal to the total actual net drawdowns of 2009-2010 FWS funds received from the Department (using the Department's G5 system) during the reporting quarter only, not to exceed the amount of the school's FWS funding from ARRA for the award year less the amount of 2009-2010 FWS funds drawn during the quarter ending September 30, 2009. For example, if a school's ARRA 2009-2010 FWS funding was $50,000 (out of a total 2009-2010 FWS allocation of $300,000) and during the quarter ending September 30, 2009 it had drawndown $35,000, only the first $15,000 of the school's second quarter draws are considered to be ARRA funds for the quarter ending December 31, 2009. Note that it is drawdowns that equal expenditures and not payments made to FWS employed students.
c. For the calculation of the number of jobs created or maintained (as described in Q&A #10) schools may use either their own average hourly FWS wage rate or they can use the current minimum Federal hourly wage rate of $7.25.
d. For the calculation of the number of jobs created or maintained (as described in Q&A #10) schools may use either their own determination of the number of hours in the calendar quarter that comprise fulltime employment or they can use 520 hours (an approximation of the number of work hours in a calendar quarter).
e. Because of refinements made to ARRA reporting, the adjustment for school matching of FWS funds that was used in the earlier reporting is no longer applicable.
f. The number of FWS jobs reported is on a fulltime equivalent basis regardless of the number of part-time jobs actually funded.
Q10 What is the modified calculation that schools should use to determine the number of jobs created or retained as a result of ARRA funding received for the quarter ending December 31, 2009?
A10 To determine the number of fulltime equivalent jobs created or maintained as a result of the receipt of ARRA funds (Field # 24 of the ARRA Reporting Template), per the established OMB reporting guidance, the school would perform the following calculation as shown in the example below that assumes an average hourly wage rate of $7.25 and a 520 hour average. Note that if the values chosen by the institution differ from this example, the institution would perform the following steps using the appropriate alternate wage rate and/or hours.
a. Multiply the average hourly wage rate by the number of hours that constitute fulltime for the quarter. For example multiplying the $7.25 Federal minimum wage rate by 520 hours equals $3,770.
b. Divide the ARRA drawdown amount for the quarter ending December 31, 2009 (see Q&A #9b above) by the result of the previous step and round the result up to the next highest whole number.
Q11 What are the other minor changes/clarifications that were referred to in Q&A #8?
A11 As noted earlier, we had provided a Federal Work-Study Program - ARRA Reporting Tip Sheet that provides item by item instructions for completing the ARRA Reporting Template. The following are revisions and/or clarifications to a few items for the reporting of ARRA activity for the calendar quarter ending December 31, 2009.
|ARRA REPORTING TEMPLATE
Changes to October 9, 2009 Instructions
|TEMPLATE DATA ITEM NUMBER||REPORTING ELEMENT||PRIOR INSTRUCTION||REVISED INSTRUCTION||NOTES|
|2||Award Number||Enter POO33A09XXXX (the last four digits are your institution’s unique GAPS Award Number for FWS)||Enter P033A09XXXX (the last four digits are your institution’s unique GAPS Award Number for FWS)||The first characters are P and one zero (0), not POO, that is, P033A09XXXX.|
|3||Final Report||Select ‘Yes’ only if this is the final report for the year. It will be the final report if the amount entered in field #10 (Amount of Award) is equal to the amount entered in field #28 (Total ARRA Expenditure); otherwise check ‘No’.||This item can be set to ‘Yes’ if the total of the amounts reported in field #28 from all quarters that were reported equals the amount for field #10 in this report.|
|4||Recipient DUNS Number||Enter Grantee DUNS Number||Same - See notes||If your school reported last quarter, use the same DUNS number. If your school did not report last quarter, use the DUNS Number shown on your 09-10 Campus-Based Statement of Account. You can also contact the G5/GAPS Hotline at 888/336-8930 to obtain your Campus-Based DUNS number. Be certain that this DUNS number is properly registered. (See Q&A # 5.)|
|10||Amount of Award||Use amount for institution from Column F (Portion Attributed to ARRA 2009-2010) by linking to the Excel spreadsheet.FWS ARRA Reporting Act of 2009 in Excel Format, 289KB||Same - See notes||The value for this field is the total award for the year, not a prorated amount for the reporting quarter.|
|22||Project Status||Enter: ‘Federal Work-Study supports payments to individual students throughout the academic year.||Select the appropriate response from one of the values in the "drop down box". The response to be selected is directly related to the total amount reported in Field #28 for all quarters. If that total amount is zero, choose ‘Not Started’. If the total from all Field #28 reporting is equal to the amount of Field #10, choose ‘Fully Completed’. If the total from all Field #28 reporting is any other value, choose the appropriate percentage value from the drop down box.||The revised instruction provided here was previously included in the Electronic Announcement dated October 16, 2009.|
|23||Total Federal Amount ARRA Funds Received/Invoiced||Enter the same amount that was used for field #10 above.||Same - See notes||As stated, the value of this field is the same as the ‘Amount of Award’ from field #10. It does not matter whether the funds have been drawndown or not.|
|24||Number of Jobs||Use results of calculation described in the Department’s October 9, 2009 Electronic Announcement||Use results of calculation described in Q&A #10, above||The revised calculation adjusts for the one quarter only reporting as opposed to quarterly cumulative reporting.|
|27||Activity Code (NAICS or NTEE - NPC)||Enter: B40||'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’.||The revised instruction provided here was previously included in the Electronic Announcement dated October 16, 2009.|
|28||Total Federal Amount of ARRA Expenditure||Enter the total net amount of 2009-2010 FWS funds the institution drew down from the Department’s G5 system, not to exceed the institution’s ‘Amount of Award’ from field #10 of this document.||Report the total actual net drawdowns of 2009-2010 FWS funds during the reporting quarter only, not to exceed the amount of the school’s FWS funding from ARRA for the full award year less the amount of 2009-2010 FWS funds drawndown during the prior quarter(s).||The change in the instruction is to adjust for the quarter activity only reporting.|
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 as we try to minimize the impact of ARRA reporting on schools.