Federal Education Grant Reporting Requirements.

Cloud Accountability has Arrived!

Bonnie Littleblittle@bruman.comBrustein & Manasevit, PLLCwww.bruman.com

A Division of Thompson Media Group

Overview Reporting Before FFATA

EDGAR Reporting Requirements ARRA Reporting

FFATA Reporting Programmatic Reporting

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Reporting Before FFATA What is “reporting”?

Accountability measure used by granting agencies to ensure that federal funds are spent appropriately

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Reporting Before FFATA –EDGAR Reporting Financial Status Reports

EDGAR 80.41 OMB-approved forms - Standard Form 425

Grant Life Cycle Solicitation, application, award issuance Obligations, draw Federal cash payments Disburse cash/liquidate obligations Document transactions Submit Financial Reports

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Reporting Before FFATA-EDGAR Reporting Standard Form 425

Combines SF 269 and SF 272 Deadlines- federal fiscal year quarters New Certification Language Previous features retained:

Object class categories of expenditure Frequency Handling of accruals Cash management instructions

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Reporting Before FFATA-EDGAR Reporting Subgrantee Reporting

Not required to use OMB forms Grantees may not impose more

burdensome requirements on subgrantees

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Reporting Before FFATA-EDGAR Reporting Performance Reports

EDGAR 80.40 Frequency depends on awarding agency,

not required more often than quarterly EXCEPTION: “High Risk” grantees may be

subject to more frequent and extensive reporting. EDGAR 80.12

Reporting Before FFATA-EDGAR Reporting Performance reports must contain:

Comparison of actual accomplishments to established objectives

Explanation of slippage if objectives not met

Analysis/explanation of cost overruns or high unit costs

Grantees must immediately report “significant developments”

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Reporting Before FFATA-EDGAR Reporting “Significant Developments”

Problems, delays or adverse conditions that substantially impair ability to meet objective of award

Favorable developments that enable meeting time schedules and objectives sooner, at less cost, or produce more beneficial results than originally planned

Note: If grantees/subgrantees suspect materials misuse of funds, may need to report the issue to the awarding agency

Potential fraud, waste or abuse may need to be reported to Office of Inspector General

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Reporting Before FFATA-ARRA Reporting Section 1512 requires states to submit

quarterly reports Total amount received and expended List of all projects or activities funded Estimate of the number of jobs created

and retained www.federalreporting.gov www.recovery.gov

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Reporting Before FFATA-ARRA Reporting SFSF reporting

Distribution of highly qualified teachers Data systems tracking student

achievement Improved standards and assessments Turnaround of failing schools

Some states received extension on certain indicators to Dec. 31, 2013 Old deadline: Jan. 31, 2012.

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FFATA ReportingBackground Reporting needed to

Assess grant performance/effectiveness Provide public opportunity to review

Scope of data collected increase Need for better risk management New technologies

Reported information available through single, searchable website USASpending.gov

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FFATA Reporting-Federal Agency Reporting Federal agencies have long been

required to report data on prime awards and prime awardees Old: Federal Assistance Award Database

System (FAADS), operated by Census Bureau

New: FAADS-Plus Info updated daily Posted on USASpending.gov

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FFATA Reporting-Reporting by Prime Recipients “Prime Recipients” – receive grant or

contract directly from federal gov’t New layer of reporting: prime recipients

to report data on first-tier subawards and executive compensation “Subawards” includes subgrants and

subcontracts Prime recipients of grants and contracts,

both mandatory and discretionary, awarded after Oct. 1, 2010

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FFATA Reporting-Reporting by Prime Recipients Initial awards of $25,000 or more:

Prime recipients report first-tier subawards of $25,000 or more, and executive compensation, if conditions are met

Initial awards below $25,000 FFATA does not apply Subsequent grant modifications push

award over $25k threshold, award is subject to requirements

Subsequent grant modifications reduce award under $25k threshold, continues to be subject to FFATA

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FFATA Reporting-Exempt from Reporting Contracts, purchase agreements, vendor

agreements and consultant agreements for supplies, equipment, and services

Grants under ARRA Federal awards to individuals Federal awards to entities with gross

income of less than $300,000 Classified information

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FFATA Reporting-Prime Recipient Registration

Prime recipients that receive grants must register in two systems: FFATA Subaward Reporting System (FSRS)

– to be displayed on USASpending.gov Accessible to federal employees and prime

recipients Central Contractor Registration System

(CCR) Entities that do business with federal gov’t Links to Dun & Bradstreet (DUNS)

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FFATA Reporting First tier subawards

A grant or contract from a prime recipient to a subgrantee or subcontractor.

Second tier subawards A subsequent subgrant or subcontract

between the subawardee and another entity

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FFATA Reporting- What Name of entity receiving award Amount of award Subcontract/subcontract number Funding agency NAICS code (contracts) / CFDA program number (grants) Program source Award title descriptive of the purpose of the funding action Location of the entity (congressional district) Place of performance (congressional district) Unique identifier (DUNS) of the entity and its parent; and Total compensation and names of top five executives (same

thresholds as for primes), if required

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FFATA Reporting - When Federal agencies, including ED, report

prime award information to USASpending.gov on the 5th and 20th of each month

Prime recipients must report first tier subaward information by the end of the following month in which the subaward was made

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FFATA Reporting-Executive Compensation Prime recipients must report the total

compensation and names of 5 most highly compensated executives for both itself and first-tier subrecipients, if: (1) more than 80% of annual gross

revenue is from the federal gov’t, and those annual revenues are greater than $25 million, and

(2) compensation information is not already available through reporting to the SEC

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FFATA v. ARRA Under FFATA, expenditures are not required to

be reported on USASpending.gov, only obligated subawards must be reported.

Under FFATA, reporting is done on a rolling basis depending on when a subgrant is made, rather than reporting on a quarterly basis.

There are certain data elements required under ARRA that are not required under FFATA. For example, number and descriptions of jobs created and reporting requirements related to infrastructure projects.

FFATA reporting is done through www.fsrs.gov, while ARRA reporting should continue to be done through www.federalreporting.gov.

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 Prime awardee(Prime recipient)

of Grants

First tier subawardee or subrecipient of grant

* Prime awardee may have to report on subawards and

executive compensation under FFATA

Contract for goods/services paid

with grant

* No reporting required under FFATA

Contract for goods/services paid

with grant

* No reporting required under FFATA

Subaward of grant(subgrant)

This webinar does not discuss reporting

requirements of prime awardee (prime

recipients) of contracts.

Grant Contract

Federal Agency

Federal Agency (U.S. Dept. of Ed)

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Prime awardee(Prime recipient)

of Grants

First tier subawardee or subrecipient of grant

* Prime awardee may have to report on subawards and

executive compensation under FFATA

Contract for goods/services paid

with grant

* No reporting required under FFATA

Contract for goods/services paid

with grant

* No reporting required under FFATA

Subaward of grant(subgrant)

Second tier subawardee or subrecipient

* No reporting required under FFATA

This webinar does not discuss reporting

requirements of prime awardee (prime

recipients) of contracts.

Subaward/subgrant

Contract for goods/ services paid w subgrant

* No reporting required under FFATA

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FFATA Guidance OMB: April 6, 2010 memo requiring the

reporting of first-tier sub-awards OMB guidance containing specific

instructions on the sub-award reporting on August 27, 2010: http://www.whitehouse.gov/omb/open

FSRS FAQs: https://www.fsrs.gov/#a-faqs

Programmatic Reporting-ESEA Consolidated State Performance Report

(CSPR) Complement state consolidated application First part – core ESEA accountability issues

Due six months after relevant school year (Dec. or Jan.)

Second part – other ESEA programs Due 2 or 4 months later

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Programmatic Reporting-ESEA Title I, Part A Title I, Part C Title I, Part D Title I, Part F Title II, Part A Title II, Part D Title III, Part A Title IV, Part A

Title IV, Part B Title VI, Part A,

state assessments Title VI, Part A,

assessment instructions

Title VI, Part B, subpart 2

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Programmatic Reporting-IDEA IDEA section 618, state reporting

requirements State Performance Plan (SPP)

Evaluates state’s efforts to implement Part B and Part C of the IDEA

Every 6 years Measurable and rigorous targets

Annual Performance Report (APR) Actual target data and explanation Discussion of improvement activities

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Programmatic Reporting-Perkins Consolidated Annual Report (CAR)

Due December Progress in achieving state adjusted

levels of performance in state plan Disaggregate data Submitted through CAR Database and

Education Data Exchange Network (EDEN) Financial States Report (FSR)

Expenditures and narrative Interim and final FSR must be submitted

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Programmatic Reporting-Adult Education Annual Progress Report

Progress in achieving adjusted levels of performance, in state place

Submitted using National Reporting System for Adult Education (NRS) data tables

Financial Status Report (FSR) Expenditures and narrative Interim and final FSR must be submitted

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Programmatic Reporting-EDFacts Office of Planning, Evaluation and Policy

Development, Performance Information Management Service (PIMS) (1) electronic submission system that

receives performance data from states, districts and schools;

(2) analytical tools for analysis of submitted data; and

(3) reporting tools for ED staff and data submitters to ensure better use of data

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Programmatic Reporting-EDFacts K-12 performance data SEAs submit data on approx 180 data

groups at the state, district and school levels Includes:

Adequate yearly progress State performance assessments Highly qualified teachers Public school choice Supplemental educational services options Graduation rates

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Programmatic Reporting-EDFacts Federal program offices use EDFacts

data Yearly state profiles Programmatic reports to Congress Statistical research Identification of issues/ monitoring

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Questions??

Bonnie Littleblittle@bruman.com

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This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney-client relationship with the presenter(s). You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances. 

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(4-12-2012 Federal Education Grant Reporting Requirements)