On a quarterly basis, Recipients of American Recovery and Reinvestment Act (ARRA) Stimulus Funds are required to provide information about the Stimulus Funds they’ve received and spent and the number of jobs that have been created or retained as a result. Primary responsibility for reporting rests with “Prime Recipients” -- entities that receive Stimulus Funds directly from the Federal Government. However, this 1512 reporting obligation may be delegated to Sub-Recipients, including those who receive funds through state agencies. The first reporting deadline is October 10, 2009.
Our Primer on ARRA Reporting Requirements [www.bricker.com/publications/articles/1525.pdf] provides background, definitions and other basic information about the reporting required under Section 1512 of the American Recovery and Reinvestment Act. This Bulletin discusses the information that must be included in these 1512 reports.
Reporting Methods. 1512 reports must be submitted via www.FederalReporting.gov, using one of three methods:
- Online data entry in a Web browser;
- Excel spreadsheet;
- Custom software system extract in XML.
More information about these methods and a Common Data Dictionary to aid in completing 1512 reports is available at www.recovery.gov.
Information to be Reported. Regardless of which method is used to report, the following key items must be provided:
- Total amount of Stimulus Funds received;
- List of projects and activities funded, including:
- Amount spent
- Completion status
- Estimates on jobs created or retained
- Total compensation of the Recipients’ five most highly compensated officers;
- Information about subawards and other payments, including:
- Total number of subcontracts and subawards less than $25,000
- or each subcontract and subaward of more than $25,000, the name, address, DUNS or CCR number, date and amount of contract or award, project or grant period, and total compensation of the five most highly compensated officers.
- Information about Vendors, including name, address, DUNS number, description of the product or service provided, and the amount paid.
How many Jobs were Created or Retained?
Although the 1512 reporting may be tedious, most of the required elements are straightforward. But Recipients should take care when determining the number of jobs “created” or “retained” as a result of Stimulus Funds. Recipients must report on the number of jobs created or retained and provide a narrative description of those jobs.
Prime Recipients are responsible for providing total jobs information related to the project or activity – including the jobs impact on Sub-Recipients and Vendors.
Calculating the Jobs Number. In general, a job “created” is a new position created and filled or an existing unfilled position that is filled as a result of Stimulus Funds. One job cannot be counted as both “created” and “retained.” Only compensated employment in the U.S. or outlying areas should be counted. Definitions are provided in 74 CRF 14824.
The estimate of the number of jobs created or retained is to be expressed as “full-time equivalents,” or FTEs. To calculate the jobs number to be reported, Recipients will need the total number of hours worked that are funded by Stimulus Funds and the number of hours in a full-time schedule for a quarter at your organization.
The jobs number is calculated as total hours worked in jobs created or retained, divided by the number of hours in a full-time schedule, as defined by the Recipient. Or,
To view the formula click here.
Remember that jobs reporting is cumulative for the life of the project, rather than “resetting” for each quarter, and only direct employment should be considered. Recipients should not report on indirect or induced employment, such as the jobs impact on their suppliers.
Narrative Jobs Information. Recipients also must provide narrative information about the jobs created or retained as a result of the Stimulus Funds. They should briefly describe the types of jobs involved and may use job titles, labor categories, or any descriptions generally used to describe these jobs.
Collecting Jobs Information from Sub-Recipients and Vendors. Prime Recipients must include in their 1512 reports information about the number and types of jobs created or retained on projects managed by Sub-Recipients. To do this, Prime Recipients must directly collect this data from Sub-Recipients and Vendors. As noted above, Prime Recipients also may delegate 1512 reporting obligations to Sub- Recipients. In that situation, Sub-Recipients will directly provide jobs and other information via www.recovery.gov.
Where collecting this information is determined to be overly costly or burdensome, Recipients may use an approved statistical method to estimate job impact on Sub-Recipients and Vendors.
Note: Several Federal Agencies have issued additional guidance about reporting job creation and retention information. This guidance can be found on individual Agency websites.
Deadlines and Penalties
The Federal Government has said that it will not give waivers or extensions for 1512 reporting. Failure to comply with 1512 reporting requirements will be considered a violation of the award agreement, and remedial actions may include withholding funds, termination or suspension of the agreement, or debarment.
Recipients and Sub-Recipients with delegated reporting responsibilities should make every effort to meet the quarterly deadlines. Agencies are to review all 1512 reports submitted by Recipients and contact them with questions or concerns. Recipients can then revise their reports during a limited time period. It seems likely that Recipients and Sub-Recipients will have many questions as this process moves ahead, particularly in this first reporting period, and further guidance may be issued.