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Implementing the Requirements of Section 1512 of the American Recovery and Reinvestment Act FTA Webinar for First-Time Reporters April 2011 Reporting Cycle
Transcript

Implementing the Requirements of Section 1512

of the American Recovery and Reinvestment Act

FTA Webinar for First-Time Reporters April 2011 Reporting Cycle

22

This Presentation Will Cover:

• The objectives of the Section 1512 reporting requirements.

• Guidance issued by OMB • Who must submit a 1512 Report.• When information must be submitted.• What information FTA grantees should

submit.• How information should be submitted.• Where to find additional technical

assistance.

3

Technical Assistance Documents

• This presentation should be viewed in conjunction with the FTA 1512 Reporting Technical Assistance documents:– 1512 Reporting Definitions and

Examples– Tips on Section 1512 reporting

(Available on the FTA ARRA Website under ARRA Reporting at http://www.fta.dot.gov/index_9440_10542.html )

44

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.

55

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.

66

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 January, 2011). Grantees should contact FTA with information on the correction and FTA will submit the correction to OMB.

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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.

88

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.

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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

The 1512 Reporting Framework

• Prime Recipients (Direct Recipients) must report. – Prime recipients may choose to delegate certain reporting

requirements to sub-recipients—we will cover in more detail later in this presentation.

• Any recipient that has been awarded an ARRA grant through March 31, 2011 must report.

• Report on a grant-by-grant basis.

• Direct Federal contractors must also report as prime recipients for each contract or task order funded with ARRA.

• Submit reports through FederalReporting.gov

11

The 1512 Reporting Framework

FTA(Federal Agency)

Prime Recipient

Sub-Recipient Vendor

Vendor

12

Reporting Timeframes

• Report (April 1-14)• Prime Recipient Review (April 15)

– You may review your report submitted between April 1-14, 2011. 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 14 days.

• Agency Review (April 16-29)– FTA will review your report during April 16-29, 2011.

• Release (April 30)– All data from the report will be released on April 30, 2011.

• Continuous Correction (May 3-23)– Starts three days after the end of the reporting period).

Your report will be made available to the public

• See www.recovery.gov for how report information is displayed.

• FTA has also posted its grantees’ reports at (http://www.fta.dot.gov/index_9440_10542.html)

13

Before you report you need to…

• Obtain a user ID and password on www.federalreporting.gov

• Make sure your organization is registered on the Central Contractor Registration, www.ccr.gov

• Obtain a Federal Reporting PIN on www.federalreporting.gov

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What you will need to report• Prime Recipient

– Federal Funding Agency Code– Federal Funding Agency Name – Awarding Agency Code– Awarding Agency Name– Program Source (TAS)– Award Number– Recipient D-U-N-S Number– Parent D-U-N-S Number– Recipient Type– CFDA Number– Recipient Name/Address/City/State/Zip Code/County– Recipient Congressional District

– Recipient Account Number – Award Type, Date, Description Project name or project/program

title– Quarterly Activities/Project Description– Project Status

16

What you will need to report

• Prime Recipient (cont.)– Activity Code– Activity Description– Number of Jobs – Description of Jobs Created– Amount of Award– Amount of ARRA Funds Received– Amount of Expenditure– Amount of Infrastructure Expenditure– Infrastructure Purpose and Rationale– Infrastructure Contact Information– Place of Performance Information– Recipient Officer Names and Compensation (Top 5) – Number and Amount of Payments to Vendors less than

$25,000/award– Number and Amount of Sub-awards less than $25,000/award

17

What you will need to report

• Sub-Recipient– Sub-Recipient D-U-N-S

– Sub-award Number

– Sub-Recipient Name/Address/City/State/Zip Code/County

– Sub-Recipient Congressional District

– Sub-Recipient Type

– Amount of Sub-award

– Amount of Sub-award Funds Disbursed

– Sub-award Date

– Sub-Recipient Place of Performance Information

– Sub-Recipient Officer Names and Compensation (Top 5)

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What you will need to report

• Recipient Vendor – Award Number

– D-U-N-S or Name and Zip Code of Headquarters (HQ)

– Product and Service Description

– Payment Amount

• Sub-Recipient Vendor – D-U-N-S or Name and Zip Code of HQ

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What you will need to report

• The next slides discuss the individual data elements required to be reported for Grants Prime Recipients, Sub-Recipients and Vendors.

(Note: Direct Federal contractors report on fewer data elements)

• Please refer to the “1512 Reporting Definitions & Examples” technical assistance document for more detailed information on these data elements.

(Available at: http://www.fta.dot.gov/index_9440_10542.html#1512)

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Prime Recipient

• Funding Agency Code & Awarding Agency Code– FTA code is 6955. Use this code for all FTA reports on all FTA

grant programs, including flexed funds in FTA grant.

• Program Source (TAS)– There are four codes for the FTA ARRA programs:

• 69-1101 for Section 5307, Section 5311, Tribal transit, and TIGGER grant programs.

• 69-1102 for Section 5309 Fixed Guideway Modernization programs.

• 69-1133 for Section 5309 New Starts program. • 69-0106 for grants funded under Supplemental

Discretionary Grants for a National Surface Transportation System (TIGER program).

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Prime Recipient

• Award Number– FTA recipients should use the 8 character TEAM

project number of the grant award (do not include the final amendment extension – e.g. -00 or -01).

– E.g. PA-96-X055

• Recipient DUNS Number– If your agency has multiple DUNS numbers, be

sure to use the number for the unit that received the FTA grant (should be the DUNS in TEAM associated with the grant for which you are reporting.)

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Prime Recipient

• CFDA Number– There are five CFDA numbers pertaining to the FTA

grants funded under ARRA.• 20.507 for Section 5307 program.• 20.509 for Section 5311 and tribal transit

programs.• 20.523 for TIGGER program.• 20.500 for Section 5309 Fixed Guideway

Modernization and New Starts programs.• 20.932 for TIGER program.

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Prime Recipient

• Recipient Congressional District– Enter Congressional district that relates to the zip

code where your headquarters is located. A subsequent reporting field will request the Congressional district associated with place of performance.

• Recipient Account Number– Optional to provide your agency’s internal tracking

number for projects funded under the FTA grant, if your agency uses such a number.

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Prime Recipient

• Final Report– Enter “yes” only if your grant was ready to be closed out on

or before the end of the reporting period.

• Award Type– Almost all FTA ARRA recipients received funds through a

grant agreement and should enter “grant.” Cooperative agreement recipients should also enter “grant.” Only Direct Federal Contractors enter “contract.”

• Award Date– Enter date FTA awarded your grant in TEAM using only

numeric characters. Do not enter date award was executed.– E.g. 20100930 (September 30, 2010)

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Prime Recipient

• Award Description– All FTA grant recipients should enter: “invest in public

transportation” to capture the overall purpose of funds awarded and then briefly describe each activity funded by the grant.

– Write in plain language for the public and do not include acronyms or jargon.

– 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.

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Prime Recipient• Project Name or Project/Program Title

– Provide project description used in TEAM project details screen.– E.g. “Purchase of six replacement buses.”

• Quarterly Activities/Project Description– Describe specific outputs and outcomes that will result from grant.

Include quantitative information about activities conducted and items purchased. Also report significant activities during the quarter.

– E.g. “This grant allowed the transit agency to purchase six low-floor, hybrid-electric buses, modernize and expand two of its three bus depots, conduct preventive maintenance on 40 existing buses, and install automatic stop announcement systems on 50 buses. As a result of these investments, the transit agency will be able to offer public transportation service that is safer, more reliable, more environmentally friendly, and more accessible for people with disabilities. We developed specifications and issued a st request for bids this quarter. “

Narrative That Met Transparency Test

Recovery.gov information  Recipient name SANTA ROSA, CITY OFProject name Hybrid Bus Replacement

Award description Invest in public transportation. These funds will partially finance the purchase of one replacement bus. The bus to be replaced is a 1998 40’ diesel fixed route urban public transit bus. This bus will have met the end of its 12 year useful life by 2010. The 1998 bus will be replaced with a 40-foot, low floor Gasoline Hybrid Electric Bus (GHEB) fixed route, urban public transit bus. This bus will be procured in accordance with FTA’s Procurement Requirements. The bus will meet the Clean Air Act (CAA) standards and the Americans with Disabilities Act (ADA) requirements.

Project description These funds will partially finance the purchase of one replacement bus. The bus to be replaced is a 1998 40’ diesel fixed route urban public transit bus. This bus will have met the end of its 12 year useful life by 2010. The 1998 bus will be replaced with a 40-foot, low floor Gasoline Hybrid Electric Bus (GHEB) fixed route, urban public transit bus through the exercising of options on an existing contract. This bus will be procured in accordance with FTA’s Procurement Requirements. The bus will meet the Clean Air Act (CAA) standards and the Americans with Disabilities Act (ADA) requirements. Expected contract award by March 2009.

Project activity description Bus and Other Motor Vehicle Transit SystemsAward type GrantsPlace of performance - street address (optional field) 1101 College Avenue, Suite 200Place of performance - city, state, and postal code Santa Rosa, CA 95404-3940Award amount $312,865.00Project status Less Than 50% CompletedAward number CA-66-X01027

Example That Partially Met the Transparency Test

Recovery.gov information  Recipient name

Project name Georgia Statewide Rural Transit Grant: 182 vehicles, ITS, facilities, software

Award description Invest in public transportation in rural areas of Georgia by purchasing new vehicles, upgrading rural bus facilities, procuring scheduling software and installing intelligent transportations systems technology on vehicles.

Project description This quarter contracts have been executed with sub-recipients; however most sub-recipients will begin work in the next quarter. This grant will allow Georgia to assist rural transit agencies to purchase 182 vehicles, upgrade ITS equipment, upgrade transit facilities and purchase scheduling software.

Project activity description Regulation and Administration of Transportation Programs

Award type GrantsPlace of performance - street address (optional field) 600 West Peachtree Street, NWPlace of performance - city, state, and postal code Atlanta, GA 30308-3607Award amount $20,762,143.00Project status Less Than 50% CompletedAward number GA-86-X001-00 Information GAO gathered to improve the descriptionThe award funds various transit activities in 30 counties throughout Georgia. Activities include the following: installing intelligent transportations systems technology on vehicles in order to dispatch and schedule information from many transportation providers and allow the public to visit the transportation provider's Web site to schedule necessary trips on line; replacement of aged equipment in order to maintain Georgia's rural paratransit fleet in a state of good repair; purchasing scheduling and dispatching software that will allow for computer-based dispatch, integration with GPS and GIS mapping, and automated route planning, among other things; and upgrading rural bus facilities or purchasing buildings that will serve as rural transit agencies that will also house equipment for the dispatching and scheduling of trips.

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Prime Recipient• Project Status

– OMB Definition• Evaluate completion status of project, activity, or Federally-awarded

contract action based on performance progress reports and other relevant non-financial performance information.

• Selection Options: Not started; Less than 50% completed; Completed 50% or more; Fully Completed.

• For awards funding multiple projects, provide best estimate of completion of all projects based on any aggregate data and information.

– FTA Comment• Determine completion status of grant on basis of overall status of

projects. • Grant is “fully completed” only if all projects funded are fully completed

and funds fully disbursed. Grant is “less than 50% completed” or “completed 50% or more,” based on your assessment of completion status. Grant is “not started” if no activity has taken place or administrative activity to carry out grant (executing award or preparing solicitation) has taken place but no project work has started.

– E.g. “Less than 50% completed”

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Prime Recipient

• Activity Code (NAICS)– Enter North American Industry Classification System (NAICS) code

that describe Recovery Act grant recipient.

• NAICS Code Examples:– 485113 - Bus and Other Motor Vehicle Transit Systems – 485991 – Special Needs Transportation [Paratransit-Only Systems]– 485111 - Mixed Mode Transit Systems [Systems with Bus & Rail]– 485112 - Commuter Rail Systems – 485119 - Other Urban Transit Systems [Most Rail-Only Systems (Except Commuter)]– 485210 - Interurban and Rural Bus Transportation [Intercity Bus Recipients]– 485999 – All Other Transit and Ground Passenger Transportation [Vanpools]– 928120 – Regulation and Administration of Transportation Programs [State DOTs]– 925120 – Admin. of Urban Planning and Community and Rural Development [MPOs]– 541611 – ONLY FOR DIRECT CONTRACTS: Administrative Management and General

Management Consulting Services

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Prime Recipient

• Number of Jobs– No Distinction Between Jobs Created and Jobs

Retained (they’re all jobs sustained)

– Report Direct Jobs, Exclude Indirect Jobs

– Only Jobs Paid by Recovery Act Funds

– Only Jobs in US and Outlying Areas

– Include Jobs from Contractors, Manufacturers, Subrecipients, and Subrecipient Vendors

– Report jobs on quarterly basis (in first report only, report all jobs to date under the grant)

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• Numbers of Jobs (cont.)– Report as “full-time equivalents” (FTE), reported

cumulatively each calendar quarter.

– Add All Hours Together for the Top (Numerator)

– Add the Hours in a Full-Time Schedule in a calendar quarter for the Bottom (Denominator)

– Denominator is typically 520, unless work schedule for job type is not 40 hours/week

Prime Recipient

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Prime Recipient• Number of Jobs (cont.)

– Direct job hours include:• Hours worked by staff paid with ARRA funds

– Direct Administration expenses paid with ARRA funds– Hours paid by ARRA funds for preventive maintenance – Hours paid by ARRA funds for operating assistance

• Hours worked on-site (at facilities or primary construction location) by contractors or sub-contractors paid with ARRA funds

• Hours worked offsite, but directly on ARRA projects, by contractors or sub-contractors paid with ARRA funds

• Hours worked by manufacturers of vehicles and equipment – when ordered directly from manufacturer.

• Report vehicle manufacturing jobs in quarter during which vehicles are delivered – obtain hours from manufacturer.

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Prime Recipient• Number of Jobs (cont.)

– Direct Job Hours Exclude:• Hours worked in manufacturing vehicles and equipment

purchased from retail establishments or out of pre-existing inventory (e.g. off a dealer’s lot)

• Hours worked by suppliers to manufacturers (i.e. do not use multipliers of direct hours worked – report only the direct hours)

• Hours worked by suppliers to construction projects• Hours worked by operators of buses purchased for fleet

expansion – when not paid with an ARRA operating assistance grant

• Hours worked in administration and oversight of ARRA grants – when not paid by the ARRA grant or when charged only as indirect costs (overhead)

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Prime Recipient• Description of Jobs Created

– Highlight the number of jobs worked on the grant– Describe the types of jobs worked, e.g.: mechanics,

administrative support personnel, laborers, construction workers, vehicle operators, and engineers.

– E.g. “This grant funded rehabilitation of the transit agency’s bus facility and additional preventive maintenance on its vehicle fleet. As a result of these funds, the agency’s contractor performing the facility rehabilitation was able to continue to employ 10 carpenters and 10 electricians. In addition, the agency was able to hire an additional 10 mechanics to perform vehicle maintenance.”

– Describe the calculation of FTEs – hours worked during quarter and denominator used (usually 520) and note number of jobs reported in previous quarters (if any)

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Prime Recipient

• Amount of Award– Enter amount of the FTA award. If grant was amended,

enter total amount of the award.

• Total Federal Amount ARRA Funds Received/Invoiced– Enter cumulative amount of FTA funds received through

ECHO as of the end of the reporting period. Do not report funds associated with ECHO requests submitted but not yet paid by the end of the reporting period.

Note: Direct contractors report payments received through MarkView/Prism, not ECHO

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Prime Recipient

• Total Federal Amount of ARRA Expenditure– FTA requires funds be tracked on an accrual basis. Report the

cumulative expenditures that you have incurred as of the end of the reporting period.

• Total Federal ARRA Infrastructure Expenditure– Report information submitted in the previous line, excluding

any funds expended on program administration (for grants funded by Section 5311) and/or operating assistance.

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Prime Recipient• Infrastructure Purpose and Rationale

– OMB Definition• Purpose and rationale of funds received for infrastructure investment with funds made available

under Recovery Act. Identify purpose and explain how the infrastructure investment will contribute to one or more purposes of the Recovery Act:

(1) To preserve and create jobs and promote economic recovery.

(2) To assist those most impacted by the recession.

(3) To provide investments needed to increase economic efficiency by spurring technological advances in science and health.

(4) To invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits.

(5) To stabilize State and local government budgets, in order to minimize and avoid reductions in essential services and counterproductive state and local tax increases.

– FTA Comment• All reports submitted by FTA grantees should include purpose #4. Reports may also include one

or more of the other five purposes of the Recovery Act.

– E.g. “The transit agency’s used its grant to purchase six low-floor, hybrid-electric buses, modernize and expand two of its three bus depots, conduct preventive maintenance on 40 existing buses, and install automatic stop announcement systems on 50 buses. The projects funded under this grant will invest in transportation, environmental protection and other infrastructure that will provide long-term economic benefits. These investments will also contribute to preserving and maintaining jobs and promoting economic recovery in the vehicle manufacturing and construction industry.”

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Prime Recipient

• Primary Place of Performance– If grant funds a project in a specific location (facility

construction), enter street address or street corner where project is located and Congressional District of that zip code.

– If grant funds projects located in multiple locations throughout a region (bus or bus shelter purchases), enter the address and Congressional District associated with your office’s headquarters in lieu of the locations of the projects.

– Federalreporting.gov only allows one zip code and Congressional District for place of performance.

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Prime Recipient• Prime Recipient indication of reporting applicability

– OMB Definition• Names and total compensation of each of the five most highly compensated

officers of the recipient for the calendar year in which grant is awarded if—(i) In the recipient’s preceding fiscal year, the recipient received 80 percent or more of its

annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements; and

(ii) $25,000,000 or more in annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements; and

(iii) The public does not have access to information about the compensation of the senior executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.

– FTA Comment• Enter “no” in this field unless all of conditions in the definitions field apply to

your agency. Take into consideration your gross revenue may include farebox revenue, state and local assistance, and other sources of funding in addition to Federal financial assistance. Your balance sheet from the prior fiscal year should indicate the amount and percentage of funds from Federal grants versus non-Federal sources of funds.

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Prime Recipient• Total Number of payments to vendors less than

$25,000/award– Report number of off-the-shelf purchases and individual

payments to contractors totaling less than $25,000. Ex: if a transit agency made three purchases of energy efficient light bulbs at $20,000 per purchase, report three purchases.

• Total Amount of payments to vendors less than $25,000– Report dollar amount associated with off-the-shelf purchases

and dollar amount of payments made to vendors totaling less than $25,000. Ex: if a transit agency made three purchases of energy efficient light bulbs at $20,000 per purchase, report $60,000.

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Prime Recipient

• Total Number of Sub-Awards less than $25,000/award– Report the total number of sub-awards less than

$25,000 per award.

• Total Amount of Sub-Awards less than $25,000/award– Report the aggregate amount of sub-awards less

than $25,000 per award.

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The 1512 Reporting Framework

• Prime recipients will report sub-recipient information (unless they delegate the responsibility to sub-recipients) and vendor information.

• Within each report, there is a separate tab for prime recipient information, sub-recipient information, and vendor information.

• Note: Direct Federal Contractors report sub-contractors on a sub-recipient tab. Contract report form does not include a vendor tab.

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Sub-Recipient• Sub-recipient DUNS Number

– Direct recipients must collect sub-recipient DUNS numbers. Fill out a sub-recipient form for each sub-recipient receiving over $25,000. Do not report sub-recipient information for funds spent by prime recipient on statewide projects such as a statewide vehicle procurement.

• Sub-award Number– Enter sub-award number the direct recipient assigns to

track its grant to the sub-recipient. If direct recipient typically does not assign a sub-award number, it should do so for the purposes of complying with this report.

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Sub-Recipient

• Sub-Recipient Congressional District– Enter the Congressional District corresponding to the

zip code of the address of the sub-recipient’s headquarters.

• Amount of Sub-award– Report the amount of funds that will be disbursed by

the direct recipient to the sub-recipient over the life of the grant.

– Do not include the value of vehicles that the prime recipient purchases and then distributes to sub-recipients.

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Sub-Recipient

• Total Sub-award Funds Disbursed– Report the amount of funds the direct recipient has

disbursed to the sub-recipient as of the end of the reporting period.

• Sub-award Date– Date the direct recipient entered into a grant

agreement with the sub-recipient. If no separate sub-recipient agreement is in place, enter the date the grant was awarded in TEAM.

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Sub-Recipient

• Sub-Recipient primary place of performance– Same guidelines as for prime recipients (one

location per sub-recipient even if there are projects in different locations)

• Sub-Recipient indication of reporting applicability– Same guidelines as for prime recipients

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Vendor• Award Number – Prime Recipient Vendor

– Use identifying number assigned by the prime recipient. Complete this information for vendors with awards of more than $25,000.

• Award Number – Sub-Recipient Vendor– Use award number or other identifying number

assigned by sub-recipient. Complete this field if submitting sub-recipient vendor information.

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Vendor• Vendor DUNS Number

– Use vendor DUNS number if available. If not, must enter vendor zip code and vendor name.

– E.g. 12346789 or 20890-1234 “Acme Manufacturing.”

• Product and Service Description– Provide a short description of product and/or service

provided by vendor.– E.g. “Vehicle manufacturing,” “vehicle maintenance,”

“facility electrical work,” “facility design” or “clerical support.”

• Payment Amount– Provide total amount invoiced (paid) to vendor to date that

will be reimbursed with ARRA funds.

What not to report

• Number of awards to individuals

• Amount of awards to individuals

*Note: Awards to individuals are not an eligibleactivity under FTA’s grant programs. This line isfor other Federal programs that provideassistance to individuals like scholarships, orunemployment compensation.

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Edit Checks

• Federalreporting.gov has built in edit checks to improve data quality.– Hard edit checks block the report

from being submitted.– Soft edit checks prompt the reporter

to review certain information before submitting the report.

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How information should be submitted

• Reports are submitted through a centralized system at www.FederalReporting.gov

• There are 3 methods for reporting:– Online data entry in the Web browser– Excel spreadsheet– Custom software system extract in

XML

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How information should be submitted

• Report as a grant recipient, not as a contractor (use the grant template or check Grant in award type in web entry) Note: Direct Federal Contractors report award type contract and use contract template.

• Be aware of formatting

– Regardless of the method used, incorrectly formatted data will be rejected.

• Back-up your report

– System sometimes experiences problems.

– If you do data entry through the Web browser, print screen shots and save draft report and if you use the Excel template, save a copy

– Save confirmation emails you receive after reading carefully – initial confirmation may not indicate report was successfully submitted.

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 repayment of ARRA funds from the affected grant.

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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.

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Additional Technical Assistance

• FTA 1512 Reporting Technical Assistance Documents– OMB Data Dictionary with FTA Comments and Examples– Reporting Tips for October reporting

(http://www.fta.dot.gov/index_9440_10542.html#1512)

• FTA 1512 Questions and Answers(http://www.fta.dot.gov/index_9440_9327.html#Reporting)

Additional Technical Assistance

• FederalReporting.gov Frequently Asked Questionshttps://www.federalreporting.gov/federalreporting/faq.do

• Recovery.gov Recipient Reporting Information http://www.recovery.gov/FAQ/Pages/RecipientReporting.aspx

• OMB Frequently Asked Questions http://www.whitehouse.gov/omb/recovery_faqs/

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Additional Technical Assistance

• During the reporting period, FTA operates a dedicated hotline and email box to answer your specific questions– 1-800-884-9190 – [email protected]

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5959

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: Daniel 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

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Questions

or

Concerns?


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