Questions
- Background on Interior’s Recovery Act Program
- Who must report?
- What data must be reported?
- When is reporting required?
- How do recipients report?
- Do financial assistance awards recipients needs DUNS numbers and to register in the contractor registry, CCR?
- How does a recipient estimate job creation or estimation?
- Are there circumstances where a statistical job estimation/creation methodology may be used?
- What is the process for getting approval of a statistical sampling methodology?
- Where do I go for more information about recipient reporting?
1) Background on Interior’s Recovery Act Program
The Department of the Interior received over $2.9 billion in Recovery Act funding for eight Bureaus and Offices. Interior will be investing in nearly 3,400 projects. Approximately one-third of Interior’s Recovery Act funding will be invested in water infrastructure construction projects. Another 30% will be invested in nearly 240 construction projects at Interior sites. 15% will be invested in over 1,500 deferred maintenance and energy retrofit projects. Another 9% will be invested in over 600 road and bridge maintenance projects.
Approximately 63 percent, or $1.89 billion, of Interior’s Recovery Act funding will be obligated via contracts. Nearly $420 million, or 14 percent, of Interior’s funding will be awarded via tribal agreements. Another $395 million, or 13 percent, will be obligated via cooperative agreements primarily in the areas of habitat and trail restoration. Only $70 million will be awarded via competitive grants to water and irrigation districts and Historically Black Colleges and Universities (HBCUs).
2) Who Must Report
General Guidelines
a) Any prime recipient that received an award from Interior in the form of a contract (or contract modification), competitive grant award, cooperative agreement, or tribal agreement. The prime recipient is responsible for reporting data on payments made to both sub-recipients and vendors.
- The prime-recipient may delegate the responsibility to report sub-recipient information to the sub-recipient.
- The prime recipient may NOT delegate reporting to vendors.
Definition of a sub-recipient: A sub-recipient is a non-Federal entity that expends Federal awards received from another entity to carry out a Federal program but does not include an individual who is a beneficiary of such a program. Specifically, sub-recipients are non-Federal entities that are awarded Recovery funding through a legal instrument from the prime recipient to support the performance of any portion of the substantive project or program for which the prime recipient received the Recovery funding. Additionally, the terms and conditions of the Federal award are carried forward to the sub-recipient. It is possible that a sub-recipient for one award may also be a prime recipient of another Federal award provided directly from the Federal Government.
Definition of a Vendor: A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of a Federal program.7 Prime recipients or sub-recipients may purchase goods or services needed to carry out the project or program from vendors. Vendors are not awarded funds by the same means as sub-recipients and are not subject to the terms and conditions of the Federal financial assistance award.
The characteristics of a vendor that make it distinct from a sub-recipient are summarized below. A vendor:
- Provides the goods and services within normal business operations;
- Provides similar goods or services to many different purchasers;
- Operates in a competitive environment;
- Provides goods or services that are ancillary to the operation of the Federal program; and
- Is not subject to compliance requirements of the Federal Program?
Are there any excluded programs at Interior?
- Recipients of an Indian Affairs guaranteed loan are not required to report.
- Individuals receiving awards, such as awards for habitat restoration by the Fish and Wildlife Service on private lands.
3) What Data Must Be Reported
The data that must be reported, a data dictionary, and Excel templates are available for contracts and financial assistance (grants, cooperative agreements, and tribal agreements) at the FederalReporting.gov website
4) When is Recipient Reporting Required?
Recipient reporting is required quarterly. FederalReport.Gov will be available for recipient reporting beginning on October 1, 2009. The deadline for the first recipient report is October 10, 2009. Recipient reporting begins on October 1, 2009. 2010 reporting will occur at the beginning of January, April, July, and October.
5) Where do I Report?
Recipients must report directly to FederalReporting.Gov.
Early registration in www.FederalReporting.Gov is strongly encouraged. Registration is now open!
6) Do financial assistance awards recipients needs DUNS numbers and to register in the contractor registry, CCR?
Yes! Each Prime and Sub Recipient must have a DUNS Number.
A DUNS Number is a unique 9-digit number issued by Dun & Bradstreet. You can obtain the DUNS number from your award document. (If not found on the award document, use the DUNS number your organization provided on the application for award.)
Visit the Dun and Bradstreet website to obtain a DUNS number.
Visit the CCR website to register.
7) How does a recipient estimate job creation or estimation?
Recipients should use the “full time equivalent” methodology.
Interior expects its prime recipients to directly report jobs created and/or retained and to collect the jobs information from all of its sub-recipients and vendors. Prime recipients are required to report a single estimate of jobs directly created and retained by project and activity or contract. A job created is a new position created and filled or an existing unfilled position that is filled as a result of the Recovery Act; a job retained is an existing position that would not have continued to be filled were it not for Recovery Act funding. The estimate of the number of jobs should be expressed as “full time equivalents.”
Interior is asking recipients to report on the numbers of jobs created and/or retained using the full-time equivalent (FTE) methodology described by the Office of Management and Budget (OMB) in Section 5.3 of “Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009″ (M-09-21).
8) Are there circumstances where a statistical job estimation/creation methodology may be used?
Interior anticipates that the vast majority of recipients will be able to comply with the FTE methodology. However, there may be circumstances when a recipient can demonstrate an unreasonable burden would result from using a direct and comprehensive job count. In such instances, the recipient will be responsible for developing a statistical method for obtaining the required FTE information, based on a representative sample of sub-recipients, and articulating how this method is preferable to implementing a comprehensive job count.
Examples of instances where a statistical method may be a satisfactory alternative may include the following circumstances:
- A recipient may be responsible for administering a substantial amount (e.g., tens of millions of dollars) of Recovery Act funds that are distributed to a multitude of projects (e.g., hundreds), each having a large number of distinct sub-recipients and vendors. In such instances, the number of sub-recipients and vendors receiving Recovery Act funds may be sufficient in number to support an effort that identifies a representative sample and to use statistical methods that yields valid and robust information on the number of jobs created and jobs retained.
- A recipient may be funding a set of projects where the operating characteristics and nature of the work performed by sub-recipients are equivalent for these projects, so that having detailed job information on a sample might yield reliable statistics to use in developing estimates for the remainder of the population. An example might be a situation where all of a prime recipient’s contracted sub-recipients working on projects funded by the Recovery Act employ the same type of experienced workforce; are required to perform the same tasks; face the same prices and market conditions; and utilize the same amount of labor in their production practices.
- A recipient may have a pre-existing validated statistical method it has recently used to generate information on direct job effects attributable to the receipt of federal government funds for the same type of projects designated to receive Recovery Act funds. In this instance, the recipient may consider seeking permission to transfer this direct job estimation method to quantify the direct job effects associated with projects supported by the Recovery Act funds.
Recipients will be required to obtain approval from Interior on the use of a statistical methodology, as well as the specific methodology the recipient is proposing. In addition, Interior will have to obtain concurrence from OMB prior to preparing a response to the recipient’s request.
9) What is the process for getting approval of a statistical sampling methodology?
OMB, Interior and the other primary agencies responsible for administering the Recovery Act strongly prefer that recipients adopt a comprehensive reporting approach. It is expected that statistical methods will rarely be requested and used by recipients to produce job estimates.
If a Prime Recipient requires the use of an alternative methodology for collection job creation/retention data rather than directly collecting specific data from all sub-recipients and vendors, it must submit a written proposal to Interior containing the following information:
- A justification as to why an alternate methodology is needed. This must address the reasons why the direct collection of information from all sub-recipients and vendors is overly costly or burdensome for the Prime Recipient.
- A technical description of the proposed methodology. This should include sufficient detail and supporting documentation of the sample design and estimation procedures so that the validity of the methodology can be assessed.
- A statement of the qualifications of the persons who will be carrying out the statistical methodology.
- A statement on the length of time the Prime Recipient anticipates making use of the statistical method (e.g., the first effective Section 1512 recipient reporting period; or for an extended period of time, such as the duration of the period during which the project receives Recovery Act funds); and
- Point of contact information including telephone and e-mail information for transmitting Interior and OMB response, and any follow-up questions arising during the review of the request.
Proposals should be submitted electronically to Mary Pletcher at mary_pletcher(at)ios.doi.gov.
Interior and OMB will approve or decline the request within 20 days from receipt of the request. All requests must be submitted no later than September 10, 2009. This will allow Interior and OMB to reach a decision in time for the recipient to either implement the statistical methodology (if request is approved) or pursue a direct and comprehensive approach for gathering job information from sub-recipients and vendors (if request is declined) and meet the October 10, 2009 reporting deadline for Section 1512 recipient reports.
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.
