DOT Section 1512 Guidance
Frequently Asked Questions (FAQs)
Introduction
Section 1512 of the Recovery Act requires that recipients report on the use of Recovery Act funding by recipients no later than the 10th day after the end of each calendar quarter (beginning the quarter ending September 30, 2009) and for the Federal agency providing those funds to make the reports publicly available no later than the 30th day after the end of that quarter. Recipients will be expected to report:
Who is Required to Report Under Section 1512?
All prime recipients (and sub-recipients that a prime recipient has designated to report directly) of Recovery Act funds are required to report. The DOT Recovery Act programs include:
What is the website for reporting?
To report awards granted under the American Reinvestment and Recovery Act (Recovery Act), visit http://www.federalreporting.gov
When will the website be available?
The website will be available for registration on August 17, 2009. The website will be available for report submission starting October 1, 2009.
Is there any limitation on the number of users?
There is no limitation to the number of users that may register with http://www.federalreporting.gov. Organizations are reminded to delegate responsibilities for reporting to ensure that all data is reported, and that no data is duplicated.
Where can I find screen shots of what the website will look like?
Screenshots of most pages are available in the PowerPoint presentations from webinars. Prime Recipients should access the presentation from Webinar 5: Prime Recipient Reporting and sub- recipients should access the presentation from Webinar 6: Sub-Recipient Reporting. Both presentations can be found at: http://www.whitehouse.gov/recovery/webinartrainingmaterials.
Registration for 1512 Data Reporting
Registration for Section 1512 Data Reporting will begin on August 17, 2009. Anyone who will use the system should register. Registration will be available through September 30, 2009. Participants are encouraged to register as early as possible. In addition, participants should note that a Central Contract Registry (CCR) number, and a D-U-N-S number are required to register. Participants will need to obtain these two items before registration can be completed.
M-09-21 stated that it did not apply to federal contracts, just grants, loans, and other financial assistance; however, the Supplement 1 list includes programs that are only supported by federal contracts. Is that a mistake and should Federal "contract" programs be removed? (Clarification of M-09-21 Guidance June 22, 2009)
No. Supplement 1 is a list of Recovery Act funded programs that are subject to the recipient reporting requirements in Section 1512 of the Act. If the work of the program listed in Supplement 1 of the guidance is performed under a federally awarded contract, then the recipient is a federal contractor subject to the FAR clause 52.204-11 and the agency awarding that contract is responsible for following the related requirements of the FAR for that Recovery Act funded action. Supplement 1 carries no further implications for programs carried out using federally awarded contracts.
Are activities funded by the Recovery Act and executed under PL 93-638 contracting mechanisms with the Indian Health Service; or the Department of the Interior subject to the reporting requirements outlined in M-09-21? (Clarification of M-09-21 Guidance June 22, 2009)
Yes. With the exception of a few statutory exemptions, tribal contracts and contract addenda are subject to the reporting requirements outlined in M-09-21 because they are not exempt from the requirements of Section 1512 of the Act. The ARRA contract and contract addendum includes a list of reporting responsibilities for tribes or tribal organization that accept ARRA funds.
When will registration be open?
Registration will open on August 17, 2009.
When will registration close for the first reporting period?
Registration will close for the first reporting period on September 30, 2009. Recipients are strongly encouraged to register early.
Will registration reopen at the beginning of each reporting period?
No, registration will only occur prior to the first reporting cycle (as stated in the OMB Section 1512 Guidance – p. 17)
Who is required to register?
Anyone who will use the system is required to register, regardless if they are reporting or reviewing. Therefore, Federal agencies and prime recipients are required to register. Sub- recipients are required to register only if the prime recipient delegates the responsibility to them. Vendors are not required to register since the vendor reports are submitted by the prime recipient or the sub-recipient, if so designated.
What is required to register?
To register, a person must have the organization’s the organization’s D-U-N-S number and a valid email address. If the person is a prime recipient, they must also have a Central Contract Registry (CCR) number. In order to receive a CCR number, the prime recipient must already have a D-U-N-S number as well as a tax identification number.
How long does it take to register?
Registration may take up to 8 days if the recipient does not have the necessary identification elements. D-U-N-S numbers are usually received within the same day. Tax identification numbers may take up to 5 days to receive. CCR numbers may take up to 2 days to receive.
How can I obtain a CCR number?
To obtain a CCR number, visit the BPN.gov CCR Search website at http://www.bpn.gov/ccr.
How can I obtain a D-U-N-S number?
To obtain a D-U-N-S number, visit the Dun & Bradstreet website at http://www.dnb.com.
My organization has more than one DUNS number. How do I know which DUNS number to enter when I register?
You need to provide the DUNS number associated with your award when you register. If no DUNS number is listed on your award document or contract, please go back to your application for award and use the DUNS number you provided to the Federal Agency at that time.
If I am a state central coordinator who will be reporting on behalf of multiple state agencies, which DUNS number do I enter when registering?
You may enter a state central DUNS number when registering. However, when reporting, you must submit the report using the DUNS number associated with the award being reported.
How can we ensure that only authorized people from our organization are registering?
An organization is required to designate a Point of Contact (POC) in their CCR Registration. This POC will receive notification when someone from their organization tries to register with the system. The POC will have the opportunity to approve or deny the registration.
Can multiple individuals within our organization register as FederalReporting.gov users?
Yes, multiple individuals within your Federal Agency or Recipient organization can register as FederalReporting.gov users. You should carefully coordinate your activities within your organization.
Will I be able to register during the reporting period (October 1-10)?
Yes. Registration will be open throughout the recipient reporting cycle. Advance registration is highly recommended since external prerequisites could take as long as 8 days.
My agency has registered with CCR prior to this process. What if the POC currently designated in CCR is not involved with Recovery Act reporting?
You will need to work within your organization’s administrative or financial management office to make sure the appropriate individuals are knowledgeable and can fulfill the expectations for their position under ARRA.
Help and Support
OMB has contracted out help desk support to a contractor experienced in large scale service desk management. The service desk staff will utilize decision trees to help solve problems. However, agency-specific questions will need to be directed to agency Points of Contact.
Who should I call if I have questions during the reporting process?
If you have questions during the reporting process, you should first call the Help Desk at 1-800- XXX-XXXX. If the Help Desk associates cannot answer your question, they will direct you to your agency specific technician.
Where can I review information provided in the webinars?
OMB held webinars during the week of July 20, 2009 to provide further clarification on the Section 1512 Guidance issued by the Office of Management and Budget (OMB). To listen to the sessions or to access the PowerPoint presentations that were used, please visit http://www.whitehouse.gov/recovery/webinartrainingmaterials.
Where can I find the OMB guidance and the supplements to the OMB guidance?
The OMB Guidance for Section 1512 is located on the OMB website at http://www.whitehouse.gov/omb/memoranda_default. The Section 1512 Guidance is M-09-21 titled “Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009.” The supplements can be found on the same page, directly under the Guidance.
Where is the OMB- issued list of Frequently Asked Questions located?
The OMB- issued list of Frequently Asked Questions is located at http://www.whitehouse.gov/omb/recovery_faqs.
Reporting:
Data reporting will begin the day after the end of the quarter (Day 1) and the initial submission will be due on Day 10. Recipients are able to submit data in three ways: web- based form, Microsoft Excel spreadsheet, or XML Schema. Prime recipients are responsible for ensuring that all data is submitted, even if they delegated to their sub-recipients. As of Day 10, reports may be published on Recovery.gov in either detail or summary form. Updates to the initial submission may be made Day 21; however each change will be logged as a modification for audit purposes. On Day 22, data will be locked for federal agency review. Federal agencies will inform recipients of any errors, or omissions, and recipients will have until Day 30 to make corrections. Reports will be posted to Recovery.gov no later than Day 30, regardless if corrections have been made.
Where can I find the list of Federal Programs under which grant recipients are required to report for the Recovery Act?
The list of Federal Programs was issued as a supplement to the Section 1512 Guidance. This can be found at: http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21-supp1.pdf. In addition, the DOT programs are listed under the Introduction section of this Guidance.
When is data submission open?
Data submission will be open the day after the end of the quarter (Day 1) until Day 10 at 11:59:59 p.m EDT.
Can I start submitting data before October 1, 2009?
No, since the data that is reported should include all information through the end of the quarter, reports cannot be submitted prior to Day 1. Data that is collected prior to Day 1 is not considered complete.
What is the reporting period for information submitted on October 1, 2009, the start of the first reporting period?
Recipients should report information for the period beginning February 17, 2009, (the day the Act was enacted by Congress) through September 2009. If an agency extended pre-award authority that predates enactment, ARRA activity conducted under pre-award authority should also be included.
What ways can data be reported?
Data can be reported directly into a web-based form, into an Excel spreadsheet template or into a XML schema. The web-based form will be available online starting on October 1, 2009. The Excel Spreadsheet and XML Schema can be downloaded prior to October 1, 2009. The completed spreadsheet of schema can be uploaded to federalreporting.gov on October 1, 2009.
Can I save draft copies of the report on the web-based form?
Yes, recipients can save draft copies of the data report on the web-based form. It is important, however, that recipients submit the form when they are finished editing prior to Day 10. Draft data will not be considered an initial, formal submission.
Can I modify the Excel spreadsheet’s format?
The format of the Excel spreadsheet must not be modified. If it is modified, when submitted, an error message will be produced because the system will not be able to validate the data. The spreadsheet will be locked to prevent any unintentional format changes from being made. Recipients should only enter data into the specified fields.
How will I know if I have entered the data into the XML schema correctly?
A validation tool is provided when the recipient submits the data. If the data is entered into the schema incorrectly, an error message will be produced. It is important that recipients only use the XML schema if they have the technical capability to do so.
When will the XML Schema and Excel Spreadsheet be available?
The XML Schema and Excel Spreadsheet are currently available. They can be downloaded at http://www.recovery.gov/?q=content/recipient-reporting.
Will the system pre-populate information from other systems?
No. The initial release of FederalReporting.gov will focus on core functions. Additional features such as pre-population may be considered for future releases.
How will I know if my report has been properly submitted?
When data is submitted correctly, users will see a submission confirmation screen, stating that the information has been submitted correctly.
What happens if multiple reports are submitted for an award (or sub award)?
The last report submitted is considered the final report. After October 10 previous versions will be maintained for audit purposes. Clear coordination among and within prime and sub recipients is critical.
The "Primary Place of Performance" is a mandatory data element requiring recipients to identify a single geographical location. How should a State’s recipient report reflect those instances where a Federal award has more than one place of performance (i.e., funds are used various project across the entire State)?
The State should list the municipality impacted by the largest portion of the Recovery Act award. In the event that it is not possible to determine a single place that is receiving more award funds than others, the State should list the state capitol as the primary place of performance.
Can a recipient choosing to use the XML export option submit a bulk extract containing multiple reports for multiple awards?
No. FederalReporting.gov does not support the ability to bulk upload a single XML file containing multiple prime recipient awards. FederalReporting.gov will provide the ability to upload multiple individually packaged XML files for a single DUNS number. In the case that a prime recipient is submitting on behalf of their sub recipients, the prime will be able to submit reporting data for multiple sub recipients in conjunction with the single prime award.
After I make my initial submission, can changes be made?
Updates to the report may be made until Day 21. However, after Day 10, any changes that are made will be logged as updates or modifications for audit purposes. On Day 22, the reports will be locked for federal agency review. Changes can only be made after that point if the agency unlocks the report for the recipient to correct an error. The report will automatically be unlocked when the report is marked “Reviewed by agency with material omissions or significant reporting errors” by the agency.
When will information be posted to Recovery.gov?
The information may be posted to Recovery.gov in summary or detailed form on Day 11. However, individual reports will be posted no later than Day 30.
What if I have changes to the data after it has already been posted to Recovery.gov?
After the data has been posted to Recovery.gov, any changes to the data should be incorporated into the subsequent quarter’s data submission. All reports are cumulative from quarter to quarter.
Will any waivers be granted for Recovery Act reporting?
No waivers will be granted for Recovery Act reporting. Extensions will only be granted in the case of extreme circumstances (e.g., natural disaster).
What is the consequence for non-compliance with reporting requirements?
Major or persistent grantee non-compliance with this requirement may result in termination of the award and suspension and debarment from receiving funds. Knowingly providing false information can result in Civil or Criminal claims.
Prime Recipients:
Prime recipients are non- Federal entities that receive Recovery Act funding from the Federal government. Prime recipients are ultimately responsible for ensuring that all information is reported, even if they delegate to their sub-recipient. Prime recipients are also responsible for reporting information relating to jobs created or retained.
When the state is the prime recipient, can multiple agencies within the state be considered prime recipients? Who are the state’s sub-recipients?
Yes, in general, when the state is considered the prime recipient, multiple agencies can report as prime recipients within the state as this is considered disaggregated reporting. For example, different organizational units of State government may receive funding as prime recipients under different Federal programs. Within a State DOT, the Highway Division and the Transit Division may each receive grants separately from FHWA and FTA, respectively, and report separately as prime recipients. Within that same state, the State Department of Health and Human Services and State Department of Labor or Agriculture, for example, may also be prime recipients. However, each state recipient must ensure that all reporting for which it is responsible is completed, and no reporting is duplicated. OMB has not delegated any specific role to the Governor’s office, or other statewide entity, apart from any role it might hold as a direct recipient. Sub-recipients are entities such as cities and counties or non-profit organizations that are receive ARRA funds through a prime recipient rather than directly from the Federal government.
When is the recipient required to report the top 5 officer names and officials?
Recipients should report the Top 5 Highly Compensated Officers under 2 conditions:
As a prime recipient, is a state permitted to submit all reports using a central D-U-N-S number?
Yes, a state is permitted to submit all reports using a central D-U-N-S number. However, each award must be reported separately.
Sub-Recipients:
Sub-recipients are non- Federal entities that receive Federal awards from a prime recipient to carry out a Federal program. Sub-recipients carry on the underlying mission of the program and may be delegated reporting responsibilities by prime recipients.
Must sub-recipients report subsequent sub-awards that they make?
Sub-recipients are currently not required to report information from their sub-recipients. This is still being monitored and may change at a later date.
Vendors:
Vendors provide the goods or services required to conduct a Federal program. These goods or services can be provided directly to the prime recipient, or to the sub-recipient. Vendors are not required to report any information to Federalreporting.gov. However, prime recipients and sub-recipients are required to gather information from the vendors such as job estimates.
What are the basic differences between sub-recipients and vendors?
Sub-recipients carry on the underlying mission of the program for which the award was granted, have responsibilities under the grant agreement, and supplement the mission attainment. Vendors provide goods or services to prime recipients or sub-recipients but do not tie to the grant agreement. Vendors also are not aiding in carrying out the mission of the program.
Are vendor requirements the same for prime recipient vendors and sub-recipient vendors?
Vendor requirements differ based on if it is a prime recipient vendor or a sub-recipient vendor. Prime recipients must report the D-U-N-S number or the name and zip code of the vendor headquarters, the expenditure amount and the expenditure description for prime recipient vendors. For sub-recipient vendors, only the D-U-N-S number or the name and zip code of the vendor headquarters needs to be reported.
What qualifies as a vendor payment?
Vendor payments refer to payments of $25,000 or more.
If multiple payments to a single vendor aggregate over $25,000, is the recipient required to report each payment separately?
An individual vendor may receive multiple payments that aggregate over $25,000. But, if the individual payments are each less than $25,000 they do not require a separate report. Separate reports are only required for single payments in excess of $25,000.
If the vendor is a general contractor, do sub-contractors need to be reported?
No, beyond the general contractor, no additional requirements need to be reported in terms of expenditures. However, the recipient should ask the general contractor for job estimates, since the general contractor will likely have a job impact.
Data Quality Review
Data quality review is essential to the reporting process to ensure accuracy, completeness and timely reporting as well as avoidance of material omissions or significant reporting errors. Review is expected to occur throughout the reporting process. Recipients should review their data before the initial submission on Day 10 is made, however, recipients will be able to review and modify data until Day 21. Agencies will also have the opportunity to review data Days 11- 21 with their official review occurring Days 22- 29. Data will be posted to Recovery.gov by Day 30. Recipients are encouraged to create internal control procedures prior to the reporting period.
What are the responsibilities associated with data quality review?
Each prime recipient and sub-recipient that reports data is responsible for completing their own data quality review. In addition, agencies will perform a data quality review of all information during Days 22- 29 of the reporting process.
When should data quality review occur?
Prime recipients and sub-recipients should review their data prior to the first submission during Days 1- 10. In addition, all recipients will have the opportunity to review their data following the initial submission during Days 11- 21. Agencies are able to review data in a “View- only” mode during Days 11- 21, and will be able to provide comments to recipients during official agency review during Days 22- 29.
How should recipients avoid the two key data issues: material omissions and significant reporting errors?
Everyone who is reporting is required to have internal control procedures in place to ensure accuracy, completeness and timeliness. Examples of internal control procedures include: establishing a data review protocol that identifies inconsistent results, establish procedures to avoid “double counting” that may result from delegation to sub-recipients, establish control totals and verify that reported information matches the control totals, and establish an estimated distribution of expected data and identify any outliers. It is suggested that the internal control procedures are established before the reporting process begins.
Will agencies verify that corrections are made?
No. Due to the short review timeframes agencies may not be able to confirm that corrections have been made by the final posting date (October 30). Some agencies however may have this capability
How will the system support the identification and communication of any identified reporting issues?
The system will provide search capability to find individual reports. Agencies will be able to download XML extracts based on Agency program grouping. When an issue is identified the reviewer will open a comment page that pre-populates the reviewer name and contact information and the report submitter name and contact information. A text box will appear that allows the reviewer to indicate the nature of the issue identified. This information is sent via email to the reporter and is appended to the report. For agency reviews (occurring day 22-29 after the end of the quarter) this also unlocks the file for editing. Once again the changes are maintained through internal version control.