Supplemental USDOT Guidance on Jobs Reporting
Under Section 1512 of ARRA
Who is responsible for reporting the estimates of jobs created or retained by Recovery funds?
Estimates of jobs created or retained by Recovery funds must be reported by the Prime Recipient. This cannot be delegated to sub-recipients.
How will jobs that are created or retained be reported?
Jobs must be reported in both numerical data and a narrative form. The numerical value will be a total of workers employed by prime recipients, sub-recipients, and vendors to work on that project. The narrative contains a description of the project, justification for the project, and the types of jobs created or retained, using job titles or broader labor categories (e.g., “skilled,” “semi-skilled, etc.”), as long as the terms are widely understood and describe the general nature of the work. The intent of this narrative requirement is to indicate the qualitative impact that the project had on the availability of employment for different kinds of workers.
How are “direct jobs” defined?
“Direct jobs” are defined as jobs directly billed to (or clearly attributable to) a project for which funds have been expended by the ultimate grant recipient, whether the work is done on-site or off-site. This will include jobs provided by prime contractors, sub-contractors, and second-tier contractors, as well as job-hours by state or other public employees whose work is directly billed to the ARRA project. It can also include manufacturing jobs (e.g., manufacturing buses for transit agencies) if the jobs are clearly linked to a particular contract.
Should direct jobs be reported for projects on which no expenditures have yet been made?
No. In cases in which work on the project begins before the agency expends any funds, direct job-hours on the project should not be reported until the quarter in which the agency makes its first expenditure on the project. At that time, all job-hours worked to date on the project should be reported.
How should “direct” jobs be reported if most of the jobs are created in the manufacturing sector, e.g., in manufacturing buses or vans?
When a grant recipient signs a contract with a vendor to perform work under an ARRA grant, whether that vendor is a construction contractor laying pavement or a manufacturer building buses, the work performed under that contract should be considered “direct jobs” if the jobs are billed to or otherwise clearly linked to the contract. In the case of a construction contract, work done by vendor employees on the construction site is normally billed to the contract even if the contract is relatively small, and hence all those jobs can be considered “direct jobs.” In the case of a manufacturer, the manufacturing jobs can normally be tied directly to the contract only if the contract is relatively large compared with the manufacturer’s overall scale of operations. The grant recipient should make a judgment whether the manufacturing order (e.g., for buses) is large enough relative to the manufacturer’s scale of operations to make it likely that the manufacturer will create or retain jobs specifically to meet that order.
Who is responsible for estimating the number of jobs created or retained in the case of manufacturing jobs?
The grant recipient is responsible for reporting the number of direct jobs created or retained. In the case of manufacturing jobs considered to be direct jobs, the grant recipient (or sub-recipient, if any) should ask the vendor how many job-hours were created or retained to meet a particular order. If the vendor cannot estimate how many job-hours were created or retained, the grant recipient may estimate the number of job-hours created or retained, and use that to estimate the number of full-time equivalent jobs that were created or retained as a result of the equipment order.
Will USDOT provide technical assistance to grant recipients to help them estimate the number of jobs created or retained in manufacturing plants to meet orders for buses?
Yes. While USDOT cannot estimate the number of jobs created or retained in manufacturing plants (because, under OMB’s guidance and under the provisions of section 1512, that is the grant recipient’s responsibility), it will provide technical assistance to grant recipients to assist them in estimating the number of direct jobs created or retained in manufacturing buses. USDOT is currently developing the methodologies to be made available as part of this technical assistance and will make them available in September 2009.
What should grant recipients report if they believe that the equipment order was too small relative to the manufacturer’s scale of operations to create or retain any identifiable jobs?
Grant recipients should report zero direct job-hours in this case. In this case, the employment effects of the equipment order will be considered as part of the Council of Economic Advisers’ overall estimate of the employment impact of the Recovery Act.
Does the number of jobs created have to be reported separately from the number of jobs retained?
No. Grant recipients should report a single number that includes both jobs created and jobs retained. In the narrative discussion, recipients should discuss whether the job-hours worked are predominantly new positions (i.e., jobs created) or continuations of existing positions (i.e., jobs retained).
What is the best way to compile data for jobs created or retained?
It is suggested that the person who will be responsible for gathering the jobs data make a spreadsheet similar to the one used in the example provided by OMB. The example can be found in the Guidance on page 35. The spreadsheet shows the number of job-hours worked by each employee during each calendar quarter that the project was underway.
In calculating the number of Full-time Equivalents (FTE), how is the full-time work schedule determined?
Grant recipients should determine the first calendar quarter for which job-hours are reported for the project and calculate the number of hours that would be in a single employee’s full-time schedule for that quarter (regardless of when the project started during that quarter). For example, for 40 hours per week in a 13-week quarter, the number of hours in a full-time schedule would be 520. Thus, even if the project started during the last month of the quarter, the grant recipient should take the job-hours worked during that last month and divide them by a full-time schedule for the entire quarter (i.e., 520 hours) to estimate the number of full-time-equivalent jobs that were worked during that quarter. Hence, if the project hired 30 people, each working a full-time schedule, but only for the last month of the calendar quarter, then the grant recipient should report that 30 people worked 173 hours each during the last month of the quarter, for a total of 5,190 job-hours. The grant recipient should then divide those 5,190 job-hours by a full-time quarterly schedule of 520 hours to get 9.98 full-time equivalent jobs for the quarter. Recipients should then calculate the cumulative number of hours in a full-time schedule for each subsequent calendar quarter during which the project is underway. So for the second quarter that the project was underway, the full-time schedule would be 1,040 hours, for the third quarter it would be 1,560 hours, and so on. For the calendar quarter during which the project is completed, recipients should again calculate the number of hours in a full-time schedule for the entire quarter, even if the project is completed before the end of the quarter, and include that as part of the cumulative full-time schedule since the quarter in which the project began. A project should be considered to be complete when all work at the job site is concluded; this may occur some time before the contract is formally closed out.
What if collecting jobs data from sub-recipients and vendors is too costly?
In instances when collecting jobs data is determined to be overly costly, burdensome, or disruptive, a statistical sample may be gathered. The sampling approach for gathering the statistical sample must be approved by USDOT and OMB.
Under what circumstances might a statistical estimate, rather than direct and comprehensive job counts, be appropriate and acceptable?
USDOT is not currently aware of any circumstances that will require the use of statistical sampling for USDOT Recovery Act programs. A circumstance in which statistical sampling might conceivably be appropriate would be if a grant recipient provided funds to a large number (e.g., several hundred) of subrecipients, each of which was using the funds on similar types of expenditures. If the grant recipient also had sufficient statistical expertise to design a valid sampling procedure, and if collecting the job information directly from the subrecipients would be a demonstrably unreasonable burden for the recipient, then in this circumstance a valid estimate of job creation might be based on a statistical sample of these subrecipients.
What procedure should USDOT grant recipients follow if they wish to gain approval for using statistical sampling?
Statistical sampling procedures must be customized to the requirements of the particular circumstances. Because USDOT is not currently aware of any circumstances that will require the use of statistical sampling for USDOT Recovery Act programs, it has not designed a statistical sampling procedure. If such circumstances are brought to the Department’s attention, it will consider any statistical sampling procedure proposed by the grant recipient. Recipients seeking to use statistical methods are advised to make use of information contained in OMB’s Guidance on Agency Survey and Statistical Information Collections and Standards and Guidelines for Statistical Surveys. These documents describe professional principles and practices that Federal agencies are required to adhere to and the level of quality and effort expected in all statistical activities, and as such, can serve as a useful guide to recipients of Recovery Act funds. Recipients are required to obtain approval from USDOT on the use of statistical sampling prior to utilizing such methods. As part of the approval process, USDOT will need to obtain OMB concurrence on the recipient’s proposed methodology.
Recipients can contact USDOT through its Recovery and Reinvestment Helpdesk at TigerTeam@dot.gov to seek approval for the use of statistical sampling. The Helpdesk will forward the request to the co-chairs of USDOT’s TIGER Team and to USDOT’s Chief Economist. The Chief Economist will draw upon appropriate staff within USDOT, including economists and statisticians, as well as additional experts under contract to USDOT, and discuss the proposed sampling procedure with OMB.
In order to meet the deadline of reporting data by October 10, 2009, recipients must submit a request to use statistical sampling no later than September 10, 2009. Recipients will receive an acknowledgment of their request within two business days. USDOT will review the proposed statistical sampling with OMB and respond to the recipient no later than September 30, 2009, either by approving the proposed statistical sampling or by declining to approve the proposal and instructing the recipient to collect and report the job information directly.
What information should grant recipients include in a request to use statistical sampling?
A request to USDOT to use statistical sampling to report job information must include