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Section 1512 Training for the October 2010 Reporting Cycle Refresher Training for Returning Reporters September 27, 2010. Thank You!.
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Section 1512 Training for the October 2010 Reporting CycleRefresher Training for Returning Reporters September 27, 2010
Thank You! • “The reports that you have submitted are of great interest to the Office of the Secretary of Transportation, the White House, Congressional Committees, and other stakeholders with the power to shape the future of public transportation.” • June 8 “Dear Colleague” Letter from Administrator Rogoff to FTA Recipients.
This Presentation Will Cover: New guidance issued by OMB on September 24. The timeline of the October 2010 reporting cycle. Tips for reporting based on lessons learned from the July 2010 reporting cycle. Where to find additional technical assistance. 3
New Reporting Guidance from OMB Recipients can submit their report to their awarding agency outside of www.federalreporting.gov (i.e., by email or fax) if they are unable to report electronically. Recipients can mark their report as “final” if the project status is complete, no additional jobs will be reported, all or nearly all funds from the award have been expended, and all or nearly all funds from the award have been received. 4
New Reporting Guidance from OMB • If not all of the funds in the award will be expended, the recipient must provide a comment in the “Quarterly Activities/Project Description” field explaining why the final amount of expenditures does not = the award amount and confirming no more funds will be expended. 5
New Reporting Guidance from OMB Recipients can make an adjustment to a report submitted in a prior reporting period (i.e., a report submitted in April, 2010). Grantees should contact FTA with information on the correction and FTA will submit the correction to OMB. 6
New Reporting Guidance from OMB Provide sufficient clarity and detail in narrative descriptions. Taken in conjunction, entries in the “award description,” and “Quarterly Activities/Project Description for Prime and Subrecipients” fields must provide clear and complete information on the award’s purpose, scope and nature of activities, outcomes, and status of activities. The information in the “Quarterly Activities/Project Description” field should include information on the accomplishments of the projects funded by the grant. 7
New Reporting Guidance from OMB When reporting payments to vendors exceeding $25,000 aggregate multiple payments made to the same vendor. Note that if multiple payments under $25,000 awarded to the same vendor exceed $25,000, then this information should be reported in the vendor section of the report. 8
New Reporting Guidance from OMB When reporting payments to subrecipients exceeding $25,000 aggregate multiple payments made to the same subrecipient. Note that if multiple payments under $25,000 awarded to the same subrecipients exceed $25,000, then this information should be reported in the subrecipient section of the report. 9
New Reporting Guidance from OMB For more information on this guidance, go to M-10-34, “Updated Guidance on the American Recovery and Reinvestment Act.” 10
Technical Assistance Documents • FTA has posted the following technical assistance for its grantees: • 1512 Reporting Definitions and Examples • Tips on Section 1512 Reporting • Federalreporting.gov edit checks • Instructions on Copying Forward Your report. (Available on the FTA ARRA Website under ARRA Reporting at http://www.fta.dot.gov/index_9440_10542.html.) 11
Reporting Timeframes • Report (October 1-10) • Prime RecipientReview (October 11-23) • You may review your report during on October 11-23, 2010. Direct recipients should review any data reported by subrecipients during this time. You may NOT submit a report during this timeframe. You can only review what was submitted during the first 10 days. • Agency Review (October 23-29) • FTA will review your report during October 23-29, 2010. • Release (October 30) • All data from the report will be released on October 30, 2010. • Continuous Correction (starts three days after the end of the reporting period).
What Happens If I Do Not Report? • Recipients are required to submit timely, complete, and effective reporting under Section 1512 of ARRA. • President Barack Obama and OMB have directed all federal agencies to hold non-compliant recipients accountable “to the fullest extent permitted by law”. • All Federal Transit Administration (FTA) American Recovery and Reinvestment Act (ARRA) grants have a provision that allows FTA to withhold funds for failure to comply with ARRA requirements. FTA contracts also include ARRA reporting clauses. • Under FTA’s Penalty Policy, recipients who fail to submit a Section 1512 report are considered to be non-compliant, and are subject to federal action, up to and including the initiation of suspension and debarment proceedings and/or repayment of ARRA funds for the affected grant.
What Happens If I Do Not Report? • First Instance of Non-Compliance through Failure to Submit a Section 1512 Report • The recipient’s General Manager (or similarly named chief executive) will receive a letter from the applicable regional administrator to: • Document the instance of non-compliance; • Remind the recipient of its ARRA Section 1512 reporting requirements; • Advise the recipient that a second instance of non-compliance will result in suspension from the ECHO payment system for the grant not reported on. • Second Instance of Non-Compliance • A second instance of non-compliance will result in suspension from the ECHO payment system for the grant not reported on. • This suspension will continue until such time that a Section 1512 report is properly submitted for the affected grant (in a future reporting cycle). • Third Instance of Non-Compliance • A third instance of non-compliance may result in severe penalties up to and including repayment of ARRA funds and the initiation of suspension and debarment procedures.
Tip #1—Make Sure your CCR Registration is Current • All grantees need to update their CCR information once a year. • CCR sends a reminder email to your point of contact • Go to http://www.ccr.gov and search by your DUNS number to find out if your registration will expire soon.
Tip #2—Report by October10, 2010 • Report as soon as you can in October. • Be mindful that October 1 falls on a Friday and October 10 falls on a Sunday, providing only six business days to submit a report.
Tip #3-Copy Forward the Information in Your July Report • Use the copy forward function if you are a returning reporter. This will associate your new report with your previous reports. Even if you use the template method of reporting, use copy forward first if any key identifiers (e.g. award number or grant/contract) changed. • Follow the procedures in the copy forward quick reference guide to copy forward your previous report.
Reporting Tip #4 – Registration/FRPIN • Make sure: • Your CCR registration is current. • Your agency Point of Contact (POC) in CCR is current. • The POC knows your role in 1512 reporting. • You have the FRPIN you will need to submit your report. 19
Reporting Tip #5– FTA ID • Use the correct Funding Agency and Award Agency Code. • Your code is 6955 for both fields • Use this code for all FTA grants, including Flex funds. • The wrong code may mean that we cannot find your report, and you may not get credit for reporting. 20
Reporting Tip #6 – Award ID • Use the correct award identification number, i.e., CA-96-X001 • If you have reported the amendment number in your April report, keep the amendment number, and copy forward your April Report in July. • If you have not reported your amendment number in April, do not change your award ID to add the amendment. 21
Reporting Tip #7 – Final Reports • Submit a final report in October if, by September 30: • The projects funded under the grant have been completed; • All jobs have been reported; • All funds from the grant have been expended; and • All funds that will be drawn down from the grant have been drawn down. • If these conditions have not yet been met, your October report should not be marked as final and you should report again in January. 22
Reporting Tip #8 - Codes • Look up the CFDA, TAS, and NAICS codes that correspond to your agency and the grant you are reporting on before you submit your report. • Look up the Congressional District of your headquarters and your project location (if different) before you report. This is a point of emphasis. • These codes can be found in FTA’s Definitions and Examples document online: http://www.fta.dot.gov/index_9440_10542.html 23
Reporting Tip #9 – Prime vs Subs • Only Direct Recipients should report the prime recipient information. • Sub-recipients and 3rd Party vendors should not report prime recipient data. • Sub-Recipient and vendor jobs data is reported by prime recipient. 24
Tip #10--Reporting Vendor Information • Don’t forget to report vendor information if you have disbursed over $25,000 to a vendor as of the end of the reporting period.
Reporting Tip #11 – Grant/Contract • Make sure that you are submitting your information as a grant and not a contract (except for direct Federal contractors). • If you use the Excel template, make sure you are using the grants template (unless you are a Federal contractor). • If you incorrectly reported as a contract in April, submit a new report as a grantee in October and then link your July and October Reports. Do not copy forward if you previously reported incorrect award type – the data fields are different. 26
Reporting Tip #12 – Dollar Amounts • Report financial data correctly • Award amount = FTA amount in grant (this must match the amount in TEAM). • Amount of ARRA funds received = ECHO draw-downs (these must match!). • Amount of ARRA funds expended = accrued expenses you have incurred. • Amount of infrastructure expenditures = amount of ARRA funds expended except expenses for operating and program administration. 27
Reporting Tip #13 – JOBS • Report jobs created or retained from July 1 through September 30. • Report jobs associated with vehicle manufacturing • Report in the quarter when vehicles have been received. • Contact manufacturer for a factor to use in calculating jobs. 28
Reporting Tip #14-Narratives • Make sure that your narrative descriptions provide clear and complete information on the award’s purpose, scope, location, cost, nature of activities, outcomes, and status of work.
Reporting Tip #14 – Narratives (cont). • Use plain English in the narrative sections. Avoid acronyms and jargon. • Imagine you are writing for your mother – and your mother will have to explain what you wrote to someone else. • The jobs narrative must: • Describe the type of each job reported. • Provide information on how the job number was calculated. • Indicate whether jobs were reported in a previous quarter. • Think about the public, reporters, and auditors reading published reports. 30
Reporting Tip #15-FederalReporting.gov Edit Checks • If your report receives a hard edit check, fix the error in question. If you are not sure what to do, call your FTA regional representative. • If your report receives a soft edit check, double check the information reported. If you believe it is accurate, submit the report.
Reporting Tip #16 – Quality Review • If FTA comments on your report during the agency review period, validate or correct the data. • Contact your regional 1512 reporting point of contact for assistance. • Use the help line and/or email technical assistance FTA provides. 34
Additional Technical Assistance • FTA Updated 1512 Reporting Technical Assistance Documents • October 1512 Reporting Tips • 1512 Reporting Definitions and Examples (Revised) • FederalReporting.gov information (https://www.federalreporting.gov) • Recovery.gov Recipient Reporting Information (http://www.recovery.gov/?q=content/recipient-reporting) 35
How to Get Help • Call: 1-800-884-9190 (beginning October 1, 2010). • Email: FTA1512@dot.gov. 36
Contact Information • For further information contact: • FederalReporting.gov Service Desk (https://www.federalreporting.gov/federalreporting/help.do) • FTA Regional Points of Contact • Region 1: Sean Sullivan 617-494-2484 • Region 2: Anthony Carr (212) 668-2170 • Region 3: Elaine Burick (215) 656-7100 and Devendra Soni (215) 656-7257 • Region 4: Margarita Sandberg (404) 865-5612 • Region 5: Mary Campbell (312) 353-1646 and Rotimi Ogunsuyi (312) 353-4070 • Region 6: Phyllis DeGarmo and Terry Showalter (817) 978-0550 • Region 7:Nguyen (816)329-3938 and William Kalt (816) 329-3927 • Region 8: Ryan Hammon (720) 963-3336 • Region 9: Pak Chu (415) 744-0141 and Karineh Gregorian (213) 202-3958. • Region 10: Elaine Wine (206) 220-7536 and Ken Feldman (206) 220-7521 • FTA Headquarters Point of Contact • Aaron Meyers (202) 366-2373 37
Questions or Concerns? 38