The American Recovery & Reinvestment Act
Who reports How to register
What to report to Feds How to submit to OFM
What to report to OFM
OFM Lead: Julie Murray OFM Lead: Muoi Nguy
Section 1512 is contained in the Recovery Act itself and
requires additional reporting to inform the public on how
funds are expended at the local level.
Who is receiving Recovery Act dollars and what amounts?
What projects and activities are being funded?
What is project completion status and impact on job
Section 1512 is a report that is IN ADDITION to any other
grant or award requirement.
Section 1512 terms/requirements may differ from what is
required under grant programs – both new grants and
existing programs supplemented with Recovery Act funds.
Non-compliance with Section 1512 reports is a violation of
the award or grant and could lead to repayment of those
Report due by the 10th day after the end of the calendar
October 10, 2009
January 10, 2010
April 10, 2010, and so on.
Report is due by 11:59 pm EASTERN TIME, so that is 8:59 pm
PACIFIC TIME. Website is open on weekends.
Reports are CUMULATIVE.
First report covers period of the inception of the Recovery
Act through September 30, 2009.
Agencies report directly to FederalReporting.gov
Agencies will supply OFM with a copy of
Agencies will supply OFM will additional information to
supplement Section 1512 Report
All state agencies will report:
No material omissions or significant reporting errors
Washington receives an A+
State Agencies State Agencies
OFM expects that agencies will FOLLOW YOUR FEDERAL
AWARDING AGENCY’S GUIDANCE.
Federal agencies will review your reports to determine compliance.
OMB is deferring to federal agencies and allowing federal agencies to
deviate from OMB guidance and instruction.
Follow your federal awarding agency’s guidance FIRST!
OMB and OFM guidance are SECONDARY source.
Use FederalReporting.gov help-desk as LAST resort.
OFM needs to know when our advice differs from what your
agency tells you. Email it to Julie.Murray@ofm.wa.gov
FEDERAL AWARDING AGENCY
Many federal agencies are providing their own supplemental
guidance and tip sheets on information required for prime
Check your federal awarding agency directly.
Also check: http://www.recovery.gov/?q=content/agency-
If you get additional guidance, tip sheets, emails, etc. on how
to report, please provide a copy to
Julie.Murray@ofm.wa.gov. We can post the information on
DIVISION A PROGRAMS - YES DIVISION B PROGRAMS - NO
State Fiscal Stabilization Entitlement Programs –
Funds FMAP, DSH, etc.
Competitive grant Extended unemployment
Infrastructure programs Tax Provisions
Bond and loan programs
Most of the Recovery Act is
contained in Division A
WHO REPORTS IS A MOVING TARGET
Some Division B programs are being required to report.
Talk to your federal awarding agency.
Most state agencies are either a:
Any combination of above
PRIME RECIPIENT is a non-Federal entity that receives
Recovery Act funding as Federal awards in the form of
grants, loans, or cooperative agreements directly from the
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.
VENDOR is a dealer, distributor, merchant, or other seller
providing goods and services that are required for the
conduct of a federal program.
INDIVIDUAL is generally defined as a sole proprietorship and
not beneficiaries of a program.
Provides the goods and services within normal Determines who is eligible to receive what
business operations; federal financial assistance;
Provides similar goods or services to many Has its performance measured against
different purchasers; whether the objectives of the Federal program
Operates in a competitive environment; are met;
Provides goods or services that are ancillary to Has responsibility for programmatic decision
the operation of the Federal program; and making;
Is not subject to compliance requirements of Has responsibility for adherence to applicable
the Federal program. federal program compliance requirements (the
terms and conditions of the federal award are
carried forward to the sub-recipient)
Uses the federal funds to carry out a program
of the organization as compared to providing
goods or services for a program of the prime
June 22th OMB Guidance -
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.
Supplemental OMB Guidance to NASBO –
All state agencies are prime recipients. State agencies cannot be sub-
recipients. All funds between state agencies must be aggregated.
Department of Education – State Fiscal Stabilization Funds –
All state agencies receiving funds through their Governor’s Office are
to be reported as sub-recipients.
State Agency X, Y & Z
(Prime Recipient = THE STATE)
State Agency X
Receives Award (Prime Recipient)
State Agency Y City County State Agency Z
(Sub-Recipient) (Sub-Recipient) (Sub-Recipient) (Sub-Recipient)
AGENCY THAT RECEIVED FEDERAL AWARD
IS PRIME RECIPIENT
Unless otherwise directed by your federal awarding agency,
another state agency should be reported as a sub-recipient.
If we are to err, it will be on the side of more disclosure and
If you are directed otherwise, let us know. Email
Current guidance CONFLICTS:
The Recovery Act
OMB June 22nd Guidance & Clarification
This presentation follows the published Data Dictionary.
Follow your federal awarding agency guidance.
OFM is providing you guidance to follow in the absence of
more concrete information from your federal awarding
What you need to report:
Copy of your federal award
External communications and GMAP materials
Information collected from sub-recipients and vendors
Data Dictionary - Title and general description with purpose
of each funding action if any. Should capture overall purpose
Can be found on Federal Award Notice
OFM Guidance - Add whether the funds are:
Competitive grant for approved AmeriCorps programs.
Formula funds to capitalize on the state’s Drinking Water State
State Fiscal Stabilization Fund (formula funds) - Education
Fund- for the support of public elementary, secondary, and
postsecondary education and, as, applicable, early childhood
education programs and services.
Formula grant program funds for crime victim assistance.
Data Dictionary – Enter Project Name or Project/Program
Title as it EXACTLY appears on Federal Award Notice
OFM Guidance - None
ARRA AmeriCorps competitive grant
WA State Funds for the DWSFR program - ARRA
State Fiscal Stabilization Fund – Education Grants
Recovery Act – OVC FY 09 VOCA Victim Compensation Formula
Data Dictionary - Description of the overall purpose and
expected outputs and outcomes or results of the award and
first-tier sub-award(s). For an award that funds multiple
projects such as a formula block grant, the purpose and
outcomes or results may be stated in broad terms.
OFM Guidance: Use information already contained in:
Status reports to your federal awarding agency
External communications and website
Field most likely used by Governor to describe the program.
Allow the state of Washington to capitalize its revolving loan
fund for the financing for the construction of drinking water
facilities, green infrastructure, program administration and
drinking water related activities. Primary purposes are to
preserve and create jobs and promote economic recovery
through the investment of infrastructure projects. We
anticipate XX projects benefiting XX household and business
Data Dictionary – Evaluation of completion status of the
project, activity or federally awarded contract. Evaluation
should be based on performance progress reports and other
relevant non-financial information. Chose:
Less than 50% completed;
Completed 50% or more;
With awards that have multiple projects, report what is
closest to the average rate of performance.
OFM Guidance - Performance differs from expenditures. A
contract or program may be 75% complete yet no Recovery
Act funds have been expended through a draw-down,
reimbursement or invoice. An agency would report
“completed: 50% or more”.
Caveat: Some federal awarding agencies are saying to use
expenditures to complete this data element.
Data Dictionary – Use North American Industry Classification
System (NAICS) or National Center for Charitable Statistics
Searchable databases can be found at:
You are allowed up to 10 activity codes to use.
OFM Guidance - Be as specific as possible.
In the case you cannot fit all the detailed codes within the given
constraints, choose the 10 codes that represent the majority of the
Infrastructure programs must use NAICS Codes.
Data Dictionary - Single piece of data. NOT being asked to
measure job created separately from jobs retained.
In reporting number of jobs, EXCLUDE:
Employment impact on materials suppliers and central service
providers (so-called “indirect” jobs)
Employment impact on the local community (“induced” jobs).
Jobs outside the United States
Uncompensated jobs (unpaid internships, volunteers, etc.)
Employment that is not directly charged to Recovery Act supported
Convert jobs “full-time equivalent” (FTE) jobs. In order to
perform the calculation, a recipient will need:
Total number of hours worked that are charged to Recovery Act
Include all forms of compensation.
Number of hours in a full-time schedule for a quarter. In general, a
full-time schedule should be expressed for the quarter as 520 hours.
Cumulative Recovery Act Funded Hours Worked = FTE
Cumulative Hours in a Full-Time Schedule
You MUST capture jobs from:
You, as prime recipient
Any of your first-tier vendors
Your sub-recipients’ first tier vendor
A first-tier vendor is anyone that you or your sub-recipients
have a contractual relationship with for the procurement of
goods or services.
Analyze FTEs to show to show ONLY the Recovery Act
portion of the project or program.
Example: Five projects 80% funded by state or federal
dollars and 20% of it is funded by Recovery Act dollars. This
person is entirely devoted to managing these projects.
Person is keeping timesheets for work spent on ONLY Recovery Act
projects or activities. If 8 hours of time is spent 100% on Recovery Act
activities, then 8 hours out of a 40 hour workweek, gets you a 0.2 FTE.
If the person isn’t keeping timesheets, another option is to prorate
the workweek. In this case, Recovery Act is 20% of the funds. Report
20% of 1 FTE, which is 0.2 FTE.
County A County B City A Vendor A
Vendor B Vendor C Vendor D Vendor E
County A County B City A Vendor A
Vendor B Vendor C Vendor D Vendor E
First-tier contractors and vendors are the minimum amount
of information to collect.
Federal awarding agencies are more likely to expect second-
tier vendor information on infrastructure projects.
OFM Guidance - We would like second-tier vendor (vendors
of your vendors) job information. However, consider:
Size of purchase. The more minor the purchase, the less need
to collect the information.
Quality of the data. Does including subcontractors materially
reduce the accuracy of your numbers.
Ability to distinguish between indirect and induced jobs.
WHO REPORTS REPORTS WHAT?
Prime Recipient must You, as prime recipient
report all job information. Any of your first-tier
Cannot be delegated to vendors
anyone else. Your sub-recipients
Duty to collect, report and Your sub-recipients’ first-
ensure accuracy. tier vendor
Includes maintaining records
of sub-recipients and vendors
to verify jobs data
County A County B City A Vendor A
Vendor B Vendor C Vendor D Vendor E
Data Dictionary – Narrative description of the employment
impact of the Recovery Act funded work. Description may
rely on job titles, broader labor categories, or the recipients
existing practice so long as terms are widely understood.
OFM Guidance - Describe how you collected job information
and use North American Industry Classification System
(NAICS) for descriptions
Minimum obligation to report at 2-digit level and include both digit
and the written description.
Collected specific data from sub-recipients and vendors to
determine FTE attributable to Recovery Act funding. FTEs are
providing educational services in elementary and secondary
schools (NAICs 6111) and institutions of higher education
Funds being used to support 220 FTEs correctional officers
(NAIC 92214) based on statewide accounting/payroll
Data Dictionary - Amount of recovery funds received that
were expended to projects or activities (‘‘Federal Share of
OFM Guidance – Cut-Off Date
Report expenditure data posted in the official accounting system
(AFRS) as of the last calendar day (the Friday before, if the last
calendar day falls on a Saturday or Sunday) of the last month of the
quarter. Financial data related to expenditures in that calendar
quarter, but posted after the last calendar day of the month, should
not be included in the Section 1512 report.
This cut-off date flows through the entire report. Use whenever
financial data is requested.
OFM Guidance continued…
Include all expenditure data, both cash and accruals, posted as of the
cutoff date. Do not include estimated expenditures for the period,
such as cost allocation, labor distribution or payroll costs, posted after
the cutoff date.
DO NOT use the Section 1512 report adjustment period (Day 11
through Day 29) to update expenditure data to reflect data posted
after the cutoff date.
If there is some reason that you cannot follow this guidance, contact
Julie.Murray@ofm.wa.gov to discuss.
Check with your federal awarding agency. Common themes
Any project that is subject to Chapter 39.04 RCW (Public Work), such
as the construction, alteration, or repair of public buildings or public
works. Excludes minor repairs and decoration; however, many
federal awarding agencies are considering this infrastructure.
Any project that the Recovery Act or federal award defines or
describes as an “infrastructure” project.
Any project requiring a Governor’s certification.
Total Recovery Act Infrastructure Expenditure
Data Dictionary – Total amount of Recovery Act funds expended on
OFM Guidance – This amount should be equal to or less than total
Recovery Act expenditures. Use same cut-off date.
Data Dictionary – Chose one or more of five purposes to chose from.
OFM Guidance – Include information on how your agency prioritized
To preserve and create jobs and promote economic recovery, as
well as invest in environmental protection infrastructure that
will provide long-term benefits, Washington State distributed
Recovery Act transportation funds by 1) advancing projects
and jobs that would have otherwise been delayed due to
funding shortfalls, 2) advancing projects and jobs that would
address high priority highway preservation needs, 3) selecting
projects that assist communities most impacted by the
Primary Place of Performance
Data Dictionary – No guidance
OMB FAQ - List the municipality impacted by the largest portion of
the Recovery Act award. In the event that it is not possible to
determine a single place that is receiving more award funds than
others, the State should list the state capitol as the primary place of
If you have a single address or location, use it.
If there are multiple projects in the same municipality and those
projects in the aggregate represent 50% or more of the award, use the
address of the municipality’s city hall, county courthouse, or tribal
Address of the capitol:
416 Sid Snyder Avenue S.W.
Olympia, WA 98504-0002
Washington Third Congressional District
State Fiscal Stabilization Fund – General Government
Used to support corrections officers throughout the state – use state
Drinking Water Revolving Fund
Use to fund 23 projects across the state – use state capitol address
National Institute of Health grant
Funds research activities at UW – use UW address
Federal Highway Administration
50% of Safe Schools grants awarded to Seattle – use Seattle location
based on its City Hall address
Compensation of five highest paid officers is required if if
ALL THREE conditions are met:
Eighty percent (80%) of gross annual revenue comes from federal
loans, contracts, subcontracts, grants, and cooperative agreements;
Such revenue exceeds $25 million; and
Information cannot be obtained from SEC or IRS filings.
OFM Guidance –
Not applicable for state agencies.
May be applicable to sub-recipients or vendors.
OMB has decided that VENDOR data for awards LESS THAN
$25,000 WILL NOT BE CUMULATIVE one quarter to the next,
only cumulative within the same quarter.
If you make two payments to the same vendor within a calendar
quarter for $15,000 then it crosses the $25,000 threshold and cannot
However, if you make two payments to the same vendor, one on
September 1 and the next on October 15, (which are in two different
quarters) then the threshold would not be crossed. You can aggregate
OMB allows prime recipients to delegate responsibility for
reporting of certain Section 1512 data elements to sub-
WASHINGTON WILL NOT BE
DELEGATING TO SUB-RECIPIENTS
YOU WILL REPORT THE DATA
DUNS number Project Descriptions
Sub-award : Place of performance
Number Project Status
Date signed Jobs Created/Retained
Total funds TO BE Job Descriptions
disbursed Top 5 compensated officers
Total funds that HAVE Vendor Data (see next slide)
DUNS number or Description
Name and HQ zip Payment Amount
of sub-recipient Applies only to
Quarterly Vendors with
Descriptions Payments over
THE LAST TWO SLIDES
The Section 1512 report allows you to aggregate
certain data that we want disaggregated (the
You should be collecting this data to have an
accurate Section 1512 report.
July 20, 2009
Thurston County (Place
(Sub-Recipient Award $1 million
Number (Total Funding to
State Agency – Olympia $225,00
Salmon/Watershed (Congressional District)
Recovery Grants (Sub-Recipient Name) (Total Funds Disbursed
Woodard Bay Clean-up
– removal of debris Less than 50%
and planting of complete (Project
vegetation along Status)
(Quarterly Top 5 Highly
Activity/Project Compensated Officer –
environmental quality 1.0 FTE (Jobs) in
- NAICS 92411 (Job landscaping - NAICS
Description) 561730 (Job
Vendor A Removal of Debris
(DUNS or HQ zip) (Product or Service)
See Economic Recovery Federal OMB Section 1512 and
Washington State Additional 1512 Data Requirements –
Illustrated reporting scenario
Walk through the data element requirement document for
State Additional 1512 details
OFM is developing a custom solution for data collection from
agencies for both:
A copy of the Federal OMB Section 1512 report
A separate report for the Washington State required additional 1512
project/location details at the prime recipient and sub recipient level
Data collection formats:
Excel – 1st priority (for quarter ending 9/30/09 reporting)
XML – 2nd priority (possible enhancement for future reporting)
Web Form – Low priority from agency survey (not likely to be
Working on security component
Will use Agency Point of Contacts for user validation
Submittal comment is required for each file submission
May suggest file naming convention and standard language
on submittal comment
No complicated business rules built for the 1st quarterly
Access data submission via the Internet
Submit both Federal Template and companion State
Template with supporting details together
Unable to submit one without the other since one is
supporting the other
Unable to submit if one of these conditions exists:
Any missing required fields or invalid fields
Award number not match between the two files
Only able to submit one single set of files at each time
Will accept Excel version in 2003 (xls) – same as OMB’s
Will also accept Excel version in 2007 (xlsx)
Prime Recipient State Agencies must:
Register in www.FederalReporting.gov ASAP
Inform OFM when registration is complete
Provide DUNS Number, Award Number, and Agency Point of Contacts
Provide FRPIN to OFM and authorize OFM registrants for data review
Register as Recipient Users for each DUNS Number
Day 1 – 10th of the month following the quarter end:
Collect and compile information required for Federal 1512 and OFM
1512 additional detail data from internal data sources, sub-recipients
Ensure financial data reported includes only data posted in the
Accounting System (AFRS) as of the last calendar day of the quarter
Review data before submission
Day 10th – Deadline for reporting (By 8:59 pm PST)
Last day to submit Federal OMB Section 1512 report to
Submit a parallel copy of Federal OMB 1512 report and State’s
additional project/location details to OFM at the same time
Day 11 – 21st of the month following the quarter end:
Review the submitted data to identify any necessary adjustments
If needed changes are identified, contact sub-recipients and vendors
to submit necessary adjustments
Notify OFM that adjustment is necessary
Respond to OFM questions about the data submittal
Confirm with OFM whether adjustments are needed
Day 21st – Deadline for adjustments (By 8:59 pm PST)
Last day to submit adjustments for the Federal OMB Section 1512
quarterly report to www.FederalReporting.gov (locked after this day)
Submit an updated parallel copy of Federal OMB 1512 report and
updated State’s additional project/location details to OFM at the same
Day 22 – 29th of the month following the quarter end:
Be alert for potential federal agency notifications for further
adjustments and respond to their questions about any data submittal
Notify OFM if adjustment is necessary
If adjustments are required:
▪ Wait for federal agency notification that the system has been unlocked
▪ Submit necessary adjustments to both www.FederalReporting.gov and OFM
Day 29th – Deadline for last adjustments (By 8:59 pm PST)
Last day to submit final adjustments for the Federal OMB Section
1512 quarterly report to www.FederalReporting.gov
Submit an updated parallel copy of Federal OMB 1512 report and
updated State’s additional project/location details to OFM
Future Data Submission Process/Frequency
Update cost information and job information if available for existing
Update new or old projects if additions or changes from previous
Make updates to both the Federal OMB report and State’s additional
project/location detail report
Submit both reports to OFM on a monthly basis
Start date and monthly cutoff for reporting date to be determined
Solicit pilot agencies to submit 1512 data for testing using
OMB 1512 Excel Template
Submit static information such as funding agency name,
award ID, recipient DUNS, etc., and
Submit dynamic data such as costs or job information for
what is available
Contact Muoi.Nguy@ofm.wa.gov if interested in pilot
Excel template to be finalized for the State
Additional Data Requirements
Available the week of September 21st
Presentation materials and handouts from this training is
available at www.recovery.wa.gov/presentations
For further information on Recovery Act-related trainings,
Governor’s Recovery Act Training Coordinator
Questions & Answers