- Applicability / Exemptions
- Data Fields
- Loans and Loan Guarantees
- Other Reporting
- Q: Do 1512 reporting requirements only apply to non-Federal recipients who receive funding provided through discretionary appropriations?
Yes. The reporting requirements do not apply to funding received through entitlement or other mandatory programs, except as specifically required by Office of Management and Budget.
- Q: Do Prime Contractors awarded less than $25,000 need to report?
Yes, to date, there is no government-wide floor for prime reporting.
- Q: We are listed on the DOE Federal Reporting Recipients Information spreadsheet as being a recipient of the EECBG grant we applied for however, we have not received a letter of award. Are we still required to report this quarter?
Yes. If the date of your award is on or before the last day of the quarter, you will need to submit a report into FederalReporting.gov. If you have not received your award notification from FedConnect, please check your FedConnect account and follow the steps below to see if your award notice is there. When you click on the small tick box (next to 'base) and click on acknowledge, the agency (DOE) is notified that the award was acknowledged. The award notice should contain an Assistance Agreement which is normally required to be signed in 5 days. Using the 'New' button will allow you to attach and send the signed/scanned Signed Assistance Agreement form.
- Sign into FedConnect with your username and password
- Click on the 'Awards' tab
- Click on the title of the award
- 'Join' the 'Award Team' by clicking the 'Join' button
- Acknowledge the award by clicking on the small tick box in the documentation under 'Base'
- You will be presented the option to send an e-mail to the agency by clicking on the 'New' button (attachments can be made at this point)
If you are listed on the Federal Reporting Recipients Information spreadsheet found on the DOE Recovery Act website's Help with FederalReporting.gov page, you will see that the spreadsheet also contains much of the awardee information required for reporting.
- Q: If a state's program uses cost sharing by the sub-recipients for the projects, do the jobs created as part of the project need to reflect this cost sharing percentage? (i.e. if a project that has 50% cost sharing by the sub-recipient and 10 direct jobs are created, do you report that as 5 FTE jobs creates due to ARRA funds?)
Recipients will report on all projects and activities or federally awarded contracts funded in whole or in part by the Recovery Act, but should report only on hours worked and funded under the Recovery Act. Additional information on the calculation methodology, formula information, and examples can be found in OMB Memoranda M-10-08 (page 11 - 22).
- Q: We have been conditionally selected for funding, but we are not under contract. Is it necessary to begin quarterly reporting now, or only after we get under contract?
If you did not have a signed award (contract) with DOE by the end of a calendar quarter, you are not required to report for that quarter. A DOE financial assistance award is valid only if it is in writing and is signed, either in writing or electronically, by a DOE Contracting Officer. Source: Code of Federal Regulations 10 CFR 600.16(a). To check to see whether you are required to report this quarter, please check the Federal Reporting Recipient Information Spreadsheet found at the DOE's Help with FederalReporting.gov website. Any award listed on the spreadsheet is required to report for the current quarter.
- Q: Are there collaborative sites that discuss 1512 reporting?
- Q: Will Office of Management and Budget issue additional guidance or clarification?
Yes. Office of Management and Budget has indicated it will regularly provide updated guidance. Please visit FederalReporting.gov and the Office of Management and Budget Recovery Act web pages for further information.
- Q: Why am I being asked for the compensation of the top 5 individuals in my organization?
The Federal Funding Accountability and Transparency Act of 2006 (FFATA) requires the public release of such data to inform the taxpayers. Recipients should only answer this question if three conditions hold: (1) The recipient receives more than 80 percent of all of its annual gross revenue from the Federal Government (whether Recovery Act funding or non Recovery Act funding); (2) Total revenues equal or exceed $25 million; and (3) This information is not publicly available 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.
- Q: Do National Labs need to report the top 5 highly compensated officers?
Yes, for contracts awarded to National Labs, the top 5 highly compensated officers should be reported if the three criteria listed above are met. The exception would be for federal employees because that information is publicly available through other sources.
- Q: I am a Sub-Recipient for a Recovery Act grant or loan, but my award is in the form of a contract. Am I subject to the Office of Management and Budget reporting guidance or to Federal Acquisition Regulation?
You are subject to Office of Management and Budget guidance instead of the Federal Acquisition Regulation because the original form of Recovery Act funding was a grant or a loan (100 percent Federal Financing Bank financed).
- Q: Can Federal Site Office personnel collect the DOE Contractors' quarterly reporting data and enter the information on behalf of the contractors?
No. Federal Agencies are prohibited from entering data on behalf of recipients per Office of Management and Budget guidance.
- Q: Are DOE Contractors required to register and input the quarterly reporting information for the awards made to their subcontractors exceeding $25,000?
Yes, Prime Contractors are required to report on some data elements for subs, including jobs. They are also not allowed to delegate reporting responsibility.
- Q: I am a contractor, am I required to report my Vendor information?
For the purposes of Prime Contractor reporting into FederalReporting.gov, there are not separate reporting categories for sub-recipients or vendors. Instead, all entities which have entered into direct agreements with the Prime Recipient are considered to be "First-tier Subcontractors," and should be reported as such. Please note that per FAR 52.204-11 Paragraph 10, only First-tier subcontracts of $25,000 or more need to be reported individually. First-tier subcontracts of less than $25,000 may be reported in aggregate form by the Prime Contractor, under the prime recipient tab per the requirements outlined in FAR 52.204-11 Paragraph 9. However, it is important that payments be reported EITHER individually in the Sub-Recipient tab OR in the aggregate in the Prime Recipient tab, but not both.
- Q: A lab is the prime contractor for a project and is sending some work to another lab (who is the prime recipient on other Recovery Act projects). Who reports?
The Prime Contractor has the responsibility to report.
- Q: We received the Recovery Act funds under our existing contract. Should we use that contract number when reporting to FederalReporting.gov or is there something different that should be used?
The contract number for the existing contract should be used. Please note that the "Date of the Award" should reflect the date of the modification where Recovery Act funds were included.
- Q: We have hired a contractor to help complete our project. Are they also required to report?
If you are a Prime Recipient of a grant, loan or cooperative agreement, , the contractor you have hired is either defined as a sub-recipient or a vendor. A Contractor is defined as a non-federal organization that has entered into a mutually binding legal agreement (i.e., contract) with DOE that requires the prime contractor to provide services and/or supplies directly to the DOE. A sub-recipient is a non-federal organization spending Federal awards received from another organization to carry out a Federal program - not a program beneficiary. A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required of the conduct of a Recovery program. OMB Memoranda M-09-21 (pdf) discusses in depth the reporting data requirements and the reporting responsibilities of recipients, sub-recipients and vendors. Ultimate responsibility for accuracy and completeness of reporting is the Prime Recipients.
V. DATA FIELDS
- Q: For data elements in the report such as Total Amount of Subawards less than $25,000, or Total Amount of payments to vendors less than $25,000/award, should I include only Recovery Act funds in those figures?
Yes. Only data regarding the use of Recovery Act dollars should be reported in the Federalreporting.gov quarterly report. This applies to all data fields within the report. For example, when calculating the amount of a given payment made to a Vendor to determine whether it exceeded $25,000, only account for the Recovery Act dollars included in that payment.
- Q: I am a loan recipient, what value should be entered into the field 'Award Amount'?
Loan recipients should report the face value of the loan received, whether a traditional loan, or a 100 percent guarantee financed through the Federal Financing Bank.
- Q: What does "executive officer" mean in the Data Element asking for the 5 most highly compensated executive officers in the Prime Recipient and Sub-Recipients?
The term "executive officer", when used with reference to a registrant, means its President, any Vice President of the registrant in charge of a principal business unit, division or function (such as sales, administration or finance), any other officer who performs a policy making function or any other person who performs similar policy making functions for the registrant. Executive officers of subsidiaries may be deemed executive officers of the registrant if they perform such policy making functions for the registrant. For not-for-profit organizations, this does not refer explicitly to the Board of Directors. However, if an "executive office" (e.g. the CEO/President) also serves on the Board of Directors, that person will still be reported.
- Q: What is the difference between the Total Number of Sub Awards less than $25,000 and the Total Amount of Sub Awards less than $25,000?
On the Federal Reporting Template for Grants and Loans, in the field labeled "Total Number of Sub Awards less than $25,000/award", enter the total number of sub recipients whose total awards are less than $25,000. In the field labeled "Total Amount of Sub Awards less than $25,000/award" enter the total dollar amount of all awards to those sub recipients with awards less than $25,000.
- Q: Where do we get our funding agency code from?
The Department of Energy's agency code is 8900. With very few exceptions, the Funding Agency and the Awarding Agency will be the Department of Energy, and both the Funding Agency Code and Awarding Agency Code will be 8900.
- Q: If we are a Prime Contractor for DOE Office of Science why would we not use Awarding Agency Code of 8925?
Individual program offices may designate specific office codes for recipients to use. If your contracting official has specified that you should use Awarding Agency code 8925, then do so.
- Q: We've recently received a modification to one of our awards. Which "Award Date" should we use -- the original award date, or the Modification date?
Use the date where Recovery Act funds were first awarded. If you are listed on the Federal Reporting Recipients Information spreadsheet found on the DOE Recovery Act website's Help with FederalReporting.gov web page you are required to report. You will see that the spreadsheet contains the award date as well as much of the awardee information required for reporting.
- Q: For M&O Contracts, do they enter the contract number in the Award Number field?
Yes. In the Award Number field of the excel template for contractors reporting, enter the identifying number assigned by the awarding Federal Agency, which for contractors is the Federal contract number.
- Q: The Order Number field, does this refer to the work authorization number?
For contractors with multiple projects within a single award, enter the DOE project value or RW WFO value. If the contractor has a legitimate order number, then report the order number followed by a space and the project value or WFO value. If you are listed on the Federal Reporting Recipients Information spreadsheet found on the DOE Recovery Act website's Help with FederalReporting.gov web page you will see that the spreadsheet also contains much of the awardee information required for reporting.
Contractors with a single project under the award can enter the order number or leave the field blank.
- Q: Is the award amount the total award or only the DOE share portion?
The "Amount of Award" field should be filled in with the following information:
For Grants: The total amount of Federal dollars on the award.
For Loans: The total amount of the loan obligated by the Federal Agency. This is the face value of the loan.
For Federally Awarded Contracts: The total amount obligated by the Federal Agency. (Source: FederalReporting.gov Recipient Reporting Data Model found on the FederalReporting.gov Downloads page).
- Q: Is there a location where we can go to determine which NTEE code to use for our specific award?
For Grant and Loan awards primarily funding infrastructure projects, enter the North American Industry Classification System (NAICS) code(s) that describe the Recovery Act projects or activities under this award. The NAICS website has a searchable code list.
For all other DOE awards, provide the National Center for Charitable Statistics ''NTEE-NPC'' code(s) that describe the Recovery Act projects or activities under this award. Select the following NTEE code that best fits the DOE funded project:
- C01: environmental awards
- U01: science/technology
- L03.04: weatherization
- C05.02: Energy Resources Programs that conserve existing energy resources, ensure efficient use of available energy and develop new energy sources while protecting the quality of the environment;
- Z99: all others
- Q:: Please confirm the Vendor tab is only used to report vendor awards in excess of $25,000.
Payments to a single vendor totaling $25,000 or more within a given quarter are required to be reported on the vendor tab. Additionally, all payments to that same vendor in subsequent quarters should be cumulatively added to the same line item on the vendor tab. If, in previous quarters, the vendor had received payments totaling less than $25,000 in a quarter, and those payments were reported in the aggregate fields on the prime recipient tab, these payments do not need to be disaggregated, and should remain on the prime recipient tab in aggregate form. The recipient is allowed, but not required, to report vendor payments totaling less than $25,000 in a single quarter as a line item on the vendor tab. The payments can be reported in the aggregate fields on the prime recipient tab or separately on the vendor tab, but not both. When calculating the amount of a given payment made to a vendor to determine whether it exceeded $25,000, only account for the Recovery Act dollars included in that payment.
- Q: Are the counts and amounts of sub-awards to individuals and vendors only for those that are paid directly by Prime Recipient, or do those cells include information from the Sub-Recipients also?
The counts and amounts of sub-awards to individuals and Vendors on the Prime Recipient tab should include sub-awards to Individuals and sub-awards to Vendors (less than $25,000 per payment) made by the Prime Recipient and all Sub-recipients.
- Q: How do you report multiple Places of Performance?
This data element is for the "Primary" place of performance. If there are multiple places of performance, provide information for the primary location. Additional places of performance can be included in the text narrative fields. States should 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's capital as the primary place of performance.
- Q: When you say total federal amount of ARRA funds Received/Invoiced... does this just refer to EECBG money or all ARRA money?
Please only include funds in this field that were received under the award being reported on. If a recipient receives more than one ARRA funded award, each award will be reported on separately.
- Q: What value do I put in the government contracting office code field?
This information is available in the Federal Reporting Recipient Information Spreadsheet (xls).
- Q: Is there someone in DOE who can validate that the correct codes are being used?
Please review the information in the DOE Federal Reporting Recipient Information Spreadsheet (xls). If you believe there are data errors on the Federal Reporting Recipient Information spreadsheet, please contact the DOE Recovery Act Clearinghouse.
- Q: Where can I find the 2-digit Congressional District code?
The USPS list should be used. See: https://www.federalreporting.gov/federalreporting/congressionalDistricts.do.
Any at-large state (i.e., with only one congressional district) should report "00" in the congressional district field. This applies to Alaska, Delaware, Montana, North Dakota, South Dakota, Vermont, and Wyoming.
- Q: Please explain the difference between the following cells: "Total Federal Amount of ARRA Expenditure", and "Total Federal Amount ARRA Funds Received/Invoiced"
Total Federal Amount of ARRA Funds Received/Invoiced includes funds which have been received by the recipient, whereas cell Total Federal Amount of ARRA Expenditure includes funds spent. In some cases these amounts may differ.
Following are the descriptions of these two fields from the FederalReporting.gov Data Model:
"Total Federal Amount of ARRA Expenditure:"
Amount of recovery funds received or will be received that were expended to projects or activities (''Federal Share of Expenditures''). The cumulative total for the amount of Federal fund expenditures, which may include amounts captured in other fields as well, such as amounts in "Total Federal ARRA Infrastructure Expenditure," "Total Amount of Payments to Vendors less than $25,000/Award," and/or "Total Subaward Funds Disbursed." For reports prepared on a cash basis, expenditures are the sum of cash disbursements for direct charges for property and services; the amount of indirect expense charged; and the amount of cash advance payments and payments made to subcontractors and Subawardees. For reports prepared on an accrual basis, expenditures are the sum of disbursements for direct charges for property and services; the amount of indirect expense incurred;; and the total amount owed by the recipient for (1) goods and other property received; (2) services performed by employees, contractors, subcontractors, Subawardees, and other payees; and (3) programs for which no current services or performance are required. Do not include program income expended. The recipient will determine whether to report on a cash or accrual basis based upon their record keeping system.
"Total Federal Amount ARRA Funds Received/Invoiced :"
For Grants and Loans: The amount of Recovery Act funds received through draw-down, reimbursement or invoice. Do NOT include unpaid invoices.
For Federally Awarded Contracts: The amount of Recovery Act funds invoiced by the federal contractor (cumulative)."
- Q: How is "job type" defined?
The recipient should complete this field to best reflect the type of jobs created. However, should questions remain, please contact the program manager identified in your award.
- Q: I have a question about Total Federal ARRA Infrastructure Expenditure. We are replacing the windows in a government building, would that be considered "Infrastructure"?
DOE does not have an established definition of infrastructure. We are using a standard of reasonableness, leaving it up to the recipient to determine whether a reasonable person believes the work is infrastructure.
- Q: Under which conditions may Prime Recipients aggregate reporting?
Aggregations can occur for sub-awards of less than $25,000, Vendor payments of less than $25,000, and sub-awards to individuals of any dollar amount.
- Q: What is the definition of the milestones that should be submitted for quarterly reporting and weekly reporting?
Office of Management and Budget guidance for ARRA funded project reporting does not identify milestones as a required data element. There are two streams of reporting for recipients. The first type is quarterly reporting submitted directly to the Office of Management and Budget through the FederalReporting.gov website. The second type of reporting is through DOE programs and may include fields such as performance/milestones etc. on a monthly or quarterly basis. Some programs may not have their own reporting requirements. Please contact your contracting official if you have questions about program specific reporting.
- Q: I am a Recipient of Recovery Act funds, but am a state or local government. How should I define the "top 5 most highly compensated executive officers in my entity"? Would that include the governor or would it be limited to the members of the state agency which is administering the grant?
Reporting on executive compensation is only required if the recipient received 80% or more of its total revenue from the Federal Government, received $25 million or more in annual revenue from the Federal Government and executive compensation is not otherwise publically available. In most cases, these criteria would not apply to a state or local government.
- Q: When submitting the "amount of award" into FederalReporting.gov, what are the definitions of the phrases, "face value of the award", "obligated amount of the award", and "the total amount of Federal dollars on the award"?
According to the Recipient Reporting Data Model (which can be found on the FederalReporting.gov Download page), the definition of "amount of award" varies based on the award type. These definitions are as follows:
For Grants: The total amount of Federal dollars on the award. (This is the total amount of Recovery Act funds expected over the course of the award from the Federal Agency regardless of whether only a portion of the award has been obligated to date.)
For Loans: The total amount of the loan obligated by the Federal Agency. This is the face value of the loan. (This is the total dollars associated with the loan)
For Federally Awarded Contracts: The total amount obligated by the Federal Agency. (The total dollars the Federal Agency has committed to the contract that are likely to result in payments immediately or in the near future.)
Definitions in italics are supplemental clarification and are not included in the Recipient Reporting Data Model.
- Q: I am a National Laboratory. If I apply for a DOE/Energy Efficiency and Renewable Energy grant, which reporting requirement would DOE apply to the lab - Federal Acquisition Regulation or Office of Management and Budget guidance?
Reporting requirements are based entirely on the nature of the award instrument, not the nature of the entity receiving the award. Awards in the form of Grants are covered by Office of Management and Budget guidance. Awards in the form of Contracts are covered by the Federal Acquisition Regulation and components of OMB Guidance associated with jobs reporting.
- Q: Is there a minimum sub-award amount before the Prime Recipient can delegate reporting responsibility?
- Q: Are Sub-Recipients with no delegated reporting responsibilities, required to collect Vendor information for submission to the Prime Recipient?
Yes, however the process by which this information is collected must be agreed upon by Prime and Sub-Recipients to meet the reporting timeframes outlined.
- Q: Do the Federal Acquisition Regulation 52.204-11 Office of Management and Budget guidance memos have differing requirements?
Yes, they do. It is important that you understand which documents provide reporting guidance for your particular financial award. All grants, loans and cooperative agreements fall under guidance provided by Office of Management and Budget Memoranda, while Federal Contractors fall under guidance provided by Federal Acquisitions Regulation 52.204-11. If you are unclear as to what form of award agreement you have or which guidance to follow, please contact the Recovery Act Clearinghouse directly for further assistance.
- Q: I have received a Cooperative Agreement from the DOE. Which reporting template should I use?
Recipients of awards in the form of a Grant, Loan or Cooperative Agreement should use the "Grants and Loans" reporting template located on Federalreporting.gov. Additionally, recipients of a Grant, Loan or Cooperative Agreement are subject to reporting guidelines outlined by the Office of Management and Budget. Recovery Act specific guidelines are available on the Office of Management and Budget Recovery Act web page.
- Q: How do I distinguish between Recovery Act and non-Recovery Act funding?
Please refer to your award documents. They should identify the source of Department of Energy funding.
- Q: Will the reporting requirements for FederalReporting.gov be consistent between Agencies?
Yes. Office of Management and Budget requirements for FederalReporting.gov are uniform across Agencies Please note however, that certain recipients, such as those funded by the Department of Transportation, have job reporting requirements in the American Recovery and Reinvestment Act that go beyond those outlined in Section 1512. Recipients must follow this guidance with respect to the reporting requirements under Section 1512 and must also comply with program- and agency-specific requirements.
- Q: Do we report all of our projects on one form?
Federal Contractors with multiple projects funded by one award should submit a different report for each project. Grant, loan, or cooperative agreement recipients with multiple projects under one award should submit only one report and include all project information in that report.
- Q: Will our project officer at DOE automatically receive these reports as well?
OMB requires all Federal agencies to perform a Quality Assurance check on all data submitted into FederalReporting.gov. As part of this check, the Department of Energy will be reviewing recipient submitted data through FederalReporting.gov. This data and review results will be sent to a variety of individuals within the Department, including federal employees in Program Offices, in DOE Headquarters, and at Field Offices. Your project officer will have the ability to see the information. However please note, reporting into FederalReporting.gov does not exempt recipients from any DOE or other reporting requirements. If you have a question about DOE or other reporting requirements, please contact your Contracting Officer.
- Q: Is an engineering design consultant with a contract in excess of $25,000 a sub-recipient or a vendor?
The tasks to be performed by the design consultant would need to be known in order to accurately define the consulting firm's relationship to the awarding entity. Please review the definitions of Sub-recipients and Vendors found in OMB Memorandum M-09-21 (pdf) in Section 2.2 and in the Appendix. The key difference between a sub-recipient and a vendor is that sub-recipient activities directly execute the mission, whereas vendors provide products or services that indirectly support the mission.
- Q: DOE uses Prime Contractor but the Fed Recovery uses prime recipient. Are they synonymous?
FederalReporting.gov uses Prime Recipient in a generic sense on their webpage to refer to all direct recipients of funds including grants, loans, and contractors. However, the reporting requirements are different depending on whether your award is in the form of a grant, loan or cooperative agreement, or in the form of a contract. In the FederalReporting.gov reporting process, recipients are asked to identify themselves as a grant/loan recipient or a contractor. For reporting purposes, a prime recipient is defined as a non-federal organization receiving Recovery Act funding (grants, loans, or cooperative agreements) directly from the Federal Government. A prime contractor is defined as a non-federal organization that has entered into a mutually binding legal agreement (i.e. contract) with DOE (with ARRA funds) that requires the prime contractor to provide services and/or supplies.
- Q: The Excel spreadsheet that I downloaded is Version 1.3 and does not contain some of the fields shown in your presentation. Is there an updated version of the Excel spreadsheet?
Please confirm that you are using the most recent spreadsheet versions through the FederalReporting.gov downloads web page.
- Q: What happens if a recipient does not report by the 10th of the month following the end of a quarter?
The Recovery Act and OMB guidance is clear that recipients need to report by the 10th. Updates to the schedule do occur on occasion. Please check the FederalReporting.gov website for up to date reporting schedule information. Please also expect to hear from a Department of Energy Official if you fail to comply with mandatory reporting requirements. Additional information on the potential consequences of non-reporting can be found in OMB Memoranda M-10-05 (pdf) "Updated Guidance on the American Recovery and Reinvestment Act - Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates," as well as OMB Memoranda M-10-17 (pdf), "Holding Recipients Accountable for Reporting Compliance under the American Recovery and Reinvestment Act."
- Q: How do I decide how many hours per year counts as one Full Time Equivalent?
OMB Memoranda M-10-08 (pdf) contains the definitions and formulas for calculations of jobs created and retained. The requirement for reporting estimates of the "Number of Jobs" is based on a simple calculation used to avoid overstating the number of other than full-time permanent jobs. This calculation converts part-time or temporary jobs into fractional "full-time equivalent" (FTE) jobs. Full-time equivalent (FTE) employment is a standard concept used by the Office of Personnel Management. This definition is taken from OMB Circular A-11, Preparation, Submission and Execution of the Budget 2009. The definition states the following: "Full-time equivalent (FTE) employment means the total number of regular straight-time hours (i.e., not including overtime or holiday hours) worked by employees divided by the number of compensable hours applicable to each fiscal year. Annual leave, sick leave, compensatory time off and other approved leave categories are considered 'hours worked' for purposes of defining full-time equivalent employment that is reported in the employment summary." The number of hours in a full time schedule for one year will vary by industry. To calculate this total first determine the number of hours in a full time schedule for a week, and multiply this amount by 52 weeks to determine a yearly total. For example, if your industry's standard work week is 40 hours, multiply this amount by 52. This example would result in 2080 hours for the year. Please note that to calculate your quarterly jobs, you will need to divide the yearly total by 4 to determine the quarterly hours in a full time schedule. Again, with this example, this would result in 520 hours for a quarter.
- Q: How do we track cumulative FTE hours from prior quarters?
Cumulative tracking of FTEs jobs is no longer a component of OMB Reporting. On December 15, 2009, OMB modified the guidance and is now requiring jobs to be calculated for the reporting quarter only. Jobs are calculated based upon total hours worked in funded jobs within the reporting quarter divided by total hours in one full time schedule for the kind of job being estimated for that quarter. An example of a jobs calculation can be found in the Instructions for Contractors (pdf) and Instructions for Grant and Loan Recipients (pdf) and in OMB Memoranda 10-08 (pdf)."
- Q: In my award application, I provided an estimate of the number of jobs I would create or retain. Will I be held accountable to those numbers if my reporting jobs numbers vary substantially from my pre-award estimates? Could I lose my funding if my jobs numbers do not meet expectations?
Awardees will not be held to pre-award estimates by Office of Management and Budget. However, the awarding Agency determines if the recipient is not meeting its terms of the award. Once the award has been made and the project has begun, recipients are required to report quarterly on jobs created and retained, and should correct past reporting estimates that vary substantially from actual results. Guidance for such corrections is provided in OMB Memoranda M-10-08 (pdf), Section 5.10.
- Q: In expectation of Recovery Act funding, I started my hiring of Recovery Act related employees in advance of receiving DOE funding. I have been paying them out of my general fund during their training process. Should I report these as jobs created?
A funded job is defined as one in which the wages or salaries are either paid for or will be reimbursed with Recovery Act funding. Thus, a job that is paid initially with non-Recovery Act dollars may be reported as created or retained as long as such dollars eventually will be reimbursed with Recovery Act funds for the jobs being reported. For example, a recipient may decide to begin hiring new employees as soon they are notified of the amount of their Recovery Act award, but before Recovery Act dollars are received or expended. If, in this situation, the non-Recovery Act dollars that are paying the wages of the new employees were used as an advance on the Recovery Act dollars awarded, the recipient can appropriately report these jobs as created or retained. However, if the recipient does not intend to use its Recovery Act award to reimburse for the previous expenditure of non-Recovery Act funds on wages and salaries, then the hours for such jobs should not reported in the calculation of jobs created or retained. If the reimbursement occurs after the job is terminated, the recipient only reports the jobs as created or retained during quarters in which the employment actually occurred. Please note that as job reporting is not cumulative, you should still only report those hours which were worked during the quarter currently being reported on. SOURCE: OMB Memoranda M-10-08 (pdf) Section 5.9.
- Q: What if I pay my employees on an incentive system based on commission (or piece rate) rather than an hourly rate. How should I report their Full Time Equivalent?
In your reporting, convert their work to a standard work week to the best of your ability and estimate their hourly contribution. All estimations in your reporting should be done using a consistent methodology across all such employees.
- Q: I am a recipient with several non-Recovery Act funding sources and I do not separate my payroll based on Recovery Act or non-Recovery Act. Can I do a simple head count to estimate how many people I hired as a result of Recovery Act funding compared to how many I was planning to hire before receiving the Recovery Act grant?
Jobs numbers must be based on actual jobs created or retained using Recovery funding using the formula provided by OMB guidance. The option for use of a statistical estimation methodology is no longer available.
- Q: I have an employee who is paid 50 percent out of Recovery Act funds and 50 percent out of a general fund. How should I count them?
For the purpose of submitting jobs created/retained into FederalReporting.gov you should only count those hours worked and paid for with Recovery Act dollars, using the formula below:
1. Calculate the Quarterly hours in a full time schedule for your business.
2. Collect the total number of hours worked and paid for with Recovery Act dollars only.
3. Divide the total number of hours worked and paid for with Recovery Act dollars by the quarterly hours in a full time schedule for your business.
You can find more guidance and detailed examples in OMB Memoranda M-10-08 (pdf) Section 5.5 "How do recipients include estimates for jobs partially funded by the Recovery Act?."
- Q: My contract officer is requiring that I report jobs data that is different than what OMB is requiring. Do I need to report such information?
Yes. When appropriate, DOE may establish reporting requirements for their own reporting systems that are different than what recipients report to FederalReporting.gov. These requirements are in addition to the reporting requirements for FederalReporting.gov, which must be met regardless of additional DOE requirements.
- Q: The guidance states that I should report the direct jobs created by my Vendor. Please give me an example of a situation in which this is a "direct" job and how should I collect that information?
A direct job created by the Vendor could include a person hired to support software purchased by a recipient. Contact any likely Vendors to determine whether jobs have been created/retained that are directly funded by Recovery Act projects. An additional example of a direct job created by a vendor would include hours paid for the installation of HVAC systems using Recovery Act funding. The employment impact on the materials supplier or manufacturer of the system would NOT be reported.
- Q: The FAR does not state "Direct Jobs" only. Where is this direction found?
This issues is addressed in the OMB Recovery FAQs for Federal Contractors on Reporting. Question 13 under the section titled "Reporting/Data Element FAQs," states:
"Should I report indirect jobs? (07/02/2010)
No. Do not attempt to estimate and report the number of indirect or induced jobs."
- Q: My City does not have an approved Indirect Cost Schedule. Many of our staff members will be spending time on the Administration of this grant. Our grant calls out $70k for an EECBG coordinator. Is there a way to get credit for the staff time that will be used outside of the EECBG coordinator position (which is a contract)?
Yes, if you can determine the hours worked by the Coordinator that were funded by Recovery Act funds.
- Q: We are a Prime Contractor with DOE. When we calculate FTEs we do NOT include subcontractor hours since we are not reporting on subcontractor jobs, correct?
No. On July 2, 2010, the FAR was updated. Contractors should now report first tier subcontractor jobs in addition to jobs created by the prime contractor. Jobs reporting is NOT retroactive therefore Federal Contractors should NOT attempt to capture jobs created or retained from prior quarters.
- Q: We are a Prime Recipient and were notified that our award date was prior to the end of this quarter. We have not spent any grant funds I assume, then, that jobs have therefore not yet been "created." Can you confirm that this is correct?
For purposes of job calculations, any hours that will be charged to the award (even if they have not yet been charged to the award) for the quarter need to be reflected as jobs created/retained per the guidance outlined in OMB M-10-08 (pdf). Page 21, Section 5.9 of the guidance states:
As described in Section 5.2 above, a funded job is defined as one in which the wages or salaries are either paid for or will be reimbursed with Recovery Act funding. Thus, a job that is paid initially with non-Recovery Act dollars may be reported as created or retained as long as such dollars eventually will be reimbursed with Recovery Act funds for the jobs being reported. For example, a recipient may decide to begin hiring new employees as soon they are notified of the amount of their Recovery Act award, but before Recovery Act dollars are received or expended. If, in this situation, the non-Recovery Act dollars that are paying the wages of the new employees were used as an advance on the Recovery Act dollars awarded, the recipient can appropriately report these jobs as created or retained. However, if the recipient does not intend to use its Recovery Act award to reimburse for the previous expenditure of non-Recovery Act funds on wages and salaries, then the hours for such jobs should not reported in the calculation of jobs created or retained. If the reimbursement occurs after the job is terminated, the recipient only reports the jobs as created or retained during quarters in which the employment actually occurred.
- Q: We have many salaried workers who spend part of their time working on a Recovery Act funded project. We do not collect timesheets from these salaried employees. If I know the portion of time that each of them is being paid by our ARRA funded project, how many hours should I count these employees as for job calculation purposes?
Each salaried employee should count as the portion of their time funded by the ARRA award in the quarter. First, you must determine what a full time schedule is for your employees. Assume, for example, that a standard work week for your entity consists of 40 hours. Multiply the 40 hour work week by 52 weeks to get total hours for a full time year. Then, divide this amount by four quarters to determine how many hours are in a standard full time quarter for your entity. Multiply the portion of the salaried employees' time which was paid for by ARRA funds by the number of hours in your standard full time quarter. For the above example, a full time work week is 40 hours, a full time year is 2080 hours, and a full time quarter is 520 hours. One full time salaried employee being funded by an ARRA award for 50% of their time will count as 260 hours (50% of the 520 hours for the quarter) for the purposes of job calculation for that quarter.
- Q: How should loans and loan guarantees be treated for reporting purposes?
Recipients of loans are subject to all of the same reporting requirements as recipients of grants, tribal agreements, cooperative agreements, and other forms of assistance, and are required to report into FederalReporting.gov in the standard fashion. Recipients of loan guarantees that are 100 percent Federal Financing Bank (FFB) financed are required to report into FederalReporting.gov per Office of Management and Budget guidance. Recipients that are not 100 percent FFB are not required to report into FederalReporting.gov. Office of Management and Budget reporting requirements and standards, however, do not exempt a loan guarantee recipient from fulfilling separate DOE reporting requirements that may exist.
- Q: What should recipients of 100 percent Federal Financing Bank (FFB) loans report to the field "Award Amount" in FederalReporting.gov?
Loan recipients should report the face value of the loan received -- not the subsidy cost.
- Q: I received funding from Bonneville Power Administration or Western Area Power Administration. How will recipients of borrowing authority report financials/jobs?
Recipients of DOE funding through borrowing authority are not subject to reporting to FederalReporting.gov.
- Q: Are recipients required to meet any other DOE reporting requirements if I am reporting the same information into FederalReporting.gov?
Yes. Reporting information into FederalReporting.gov does not exempt recipients from fulfilling DOE reporting requirements.
- Q: Can I report my information to DOE, and ask DOE to submit the data to FederalReporting.gov?
No. Per OMB Guidance, agencies are not allowed to perform this function.
- Q: How can I ensure that the information my organization collects covers Office of Management and Budget's FederalReporting.gov requirements, plus any other reporting required by the Department of Energy, State government, and/or any other organization?
All recipients are encouraged to confer with each relevant organization to understand different reporting requirements.
- Q: Why do I need to complete quarterly, monthly, and/or weekly reporting requirements to DOE if I need to submit something to FederalReporting.gov every quarter?
To effectively manage Recovery Act projects, DOE has established reporting requirements in addition to FederalReporting.gov, as allowed by Office of Management and Budget guidance.
- Q: Are Recipients required to meet DOE 4600.2 requirements?
FederalReporting.gov requirements do not exempt a recipient from meeting DOE requirements.
- Q: We received notice by email to register with PAGE to file the DOE reports...can you please discuss the role of PAGE?
The PAGE website is a tool designed for recipients of DOE funding through the Office of Energy Efficiency and Renewable Energy Weatherization and Intergovernmental Program to meet their program-specific reporting requirements. It is not associated with ARRA reporting through FederalReporting.gov. Please note that reporting through FederalReporting.gov does not exempt recipients from meeting any program-specific reporting requirements, nor does program-specific reporting exempt any ARRA recipient from meeting their reporting requirements through FederalReporting.gov. For further details of DOE program-specific reporting requirements, please contact your DOE grant administrator.
- Q: Do all recipients have to register at FederalReporting.gov?
All recipients that will be reporting directly into FederalReporting.gov must register within 10 business days of receiving the award. This includes all Prime Recipients and Sub-Recipients that have been delegated reporting requirements by the Prime Recipient.. For example, a Sub-Recipient that has been delegated authority to report is required to register. A Sub-Recipient which has not been delegated reporting responsibility, however, is not required to register. Vendors are never required to register in FederalReporting.gov.
- Q: Is it necessary for recipients to register multiple times if receiving multiple awards?
Each recipient or sub-recipient of ARRA funds, as identified by their DUNS numbers, need only register once in FederalReporting.gov. Once registered, the recipient can report on any number of awards associated with that DUNS number. Please note that if a single entity has awards under multiple DUNS numbers, each DUNS number must register separately.
- Q: Is it a requirement that any vendor receiving funds through a prime recipient must have a DUNS number?
Prime recipients are required to report vendor payments in excess of $25,000 per award individually. OMB prefers the vendor DUNS number for identification, however if the vendor does not have a DUNS number, the vendor name and zip code of the vendor headquarters will be used for identification. Please reference OMB Memoranda M-09-21 (pdf) section 2.3 (pdf) for further information.
- Q: I am a sub-recipient and my prime recipient will enter the data for me. Do I still need to register in CCR and get a CCR number?
Yes. All prime and sub-recipients of financial assistance (i.e. loans and grants) must be registered in the CCR. Please note that CCR registrations require regular renewal. An expired CCR registration will prevent the Recipient from submitting and updating reports in FederalReporting.gov. Information on renewing CCR registration can be found at the Central Contractor Registry. Please note that Federal Contractors and sub-contractors are also required to be registered in the Central Contractor Registration database.
- Q: I registered and then my City Manager registered and then my finance guy registered. Does anyone else have to register?
The recipient needs to determine which individuals within the recipient organization should register and receive a FederalReporting.gov user name and password. . In addition to the user name and password, the FederalReporting.gov personal identification number (FRPIN) for the reporting DUNS is required in order to submit a report. The FRPIN will be sent to the Government Business Primary Point of Contact (POC) as designated in CCR and should be shared by the POC with all registered users for a specific DUNS. Please contact the FederalReporting.gov Service Desk at 877-508-7386 for additional information on permissions and roles within the FederalReporting.gov reporting solution.
- Q: What data sources support the xml format necessary to export data to FederalReporting.gov?
For technology support questions when submitting data into FederalReporting.gov, please contact the Federal Reporting help desk, found at FederalReporting.gov.
- Q: My reporting system has been approved by Office of Management and Budget and all award agreements sent out require the use of this particular system for reporting purposes. Does this mean I can bypass use of FederalReporting.gov?
No. Recipients are required to use FederalReporting.gov to comply with ARRA Section 1512 reporting requirements.
- Q: Is there a computerized system to input reporting data for the grant funds?
Yes, FederalReporting.gov will be available for the quarterly report due by the 10th day following each quarter. FederalReporting.gov will accept both XML and MS Excel uploads as well as direct online data entry.
- Q: Can I do a test upload of the data to FederalReporting.gov to make sure it works and then replace it on the 10th with the actual file? Where on the FederalReporting.gov website can we find this feature?
Yes, Registered users of the system have the ability to validate their data file being submitted prior to final submission. For information on the validation process please review the information available in the User Guide via the "Downloads" section of FederalReporting.gov. Please note it is strongly suggested that recipients not wait until the final day of the reporting period to submit their report. Please also note that validating a report or saving the report as a draft does not fulfill the report submission requirement.
- Q: Based on the FAQ web page and the information presented during DOE Reporting Webinars there is now a copy forward function for OMB Reporting purposes but that certain fields cannot be changed using the copy forward function. How do we correct those fields if they were reported incorrectly in the first round of reporting, and what are those fields?
The only field that cannot be changed is the Award Type. If you have been requested to change this field, you cannot use the copy forward function and will need to submit a new report under the correct award type.
- Q: When do I need to first report?
No later than 10 days following the end of the calendar quarter that the award is made. If your award document was signed by the DOE Awarding Official on or before the last day of the quarter, even if funds have not yet been received and/or expended you must still register and input data by entering "0's" in the appropriate data fields. Please note: the schedule is subject to change. DOE will make every effort to notify recipients of schedule changes. Recipients should also regularly check FederalReporting.gov for schedule updates.
- Q: The process of closing my books takes longer than 10 days and therefore my quarterly report will not be fully reflective of progress to date and may lag as much as a full quarter. How should I handle this situation?
The recipient should turn in the most up to date information possible on the 10th. If there are corrections or changes that need to be made after the 10th, these can occur during the prime recipient review period. To make updates during the agency review period, please contact your DOE contracting officer. The agency reviewer can open your report for correction. Additionally, following the end of the reporting period, recipients are able to make additional corrections to their submitted reports during the continuous correction period. For further information on the continuous correction period, please reference OMB Memoranda M-10-08 (pdf) Section 5.2. Up to date information on this quarter's reporting period, including recipient review timelines and agency review timelines, can be found at FederalReporting.gov.
- Q: How long will the reporting process take?
DOE advises recipients to register almost a month in advance to assure identity numbers can be obtained in a timely fashion. Office of Management and Budget has estimated that the average recipient reporting burden will be approximately 14 hours per year.
- Q: What is the interim change control process; and the process moving forward from the 10th of the month?
Recipients must submit a final report to FederalReporting.gov prior to the 11:59 PM Eastern Time on the 10th day of the reporting period. Please note: the schedule is subject to change. DOE will make every effort to notify recipients of schedule changes. Recipients should also regularly check FederalReporting.gov for schedule updates.
The Recipients may make changes to their submitted reports freely during the recipient review period and changes are tracked through version control. Following the recipient review period, changes to submitted reports may only occur following an agency reviewer's unlocking of the report through the submission of a comment. Reports are expected to be complete and accurate when submitted within the timelines indicated in the Recovery Act. Recipients may make changes to their submitted reports following the end of the reporting period as part of the continuous corrections period. This period lasts until the first day of the next quarter's reporting period. Information on the Continuous Correction period can be found in OMB Memoranda M-10-08 (pdf) Section 5.2, and on the FederalReporting.gov website.
- Q: I am a Vendor who serves recipients of Recovery Act grants or loans, do I have any reporting responsibility?
The Prime Recipient of the ARRA funding will be required to report basic information about vendor purchases and may contact you to provide information. . Vendors have no direct reporting requirements into FederalReporting.gov.
- Q: I am a Prime Recipient; can I delegate any reporting requirements to my Vendors?
No, you cannot delegate the limited data elements to your Vendors. If you have delegated sub-award reporting to your Sub-Recipient, however, they will report their own Vendor purchases, which also cannot be delegated by Sub-Recipients.
- Q: I am a Prime Recipient of Recovery Act funds What information am I required to report about purchases from Vendors under $25,000? How will I report this information
All vendor payments made by the prime recipient must be reported Vendor payments totaling $25,000 or more by either the prime or sub-recipients must be reported as line items on the vendor tab. Payments totaling $25,000 or more in a single quarter must also include either the DUNS or the name plus zip code of the vendor. Prime recipients are required, and sub-recipients are encouraged, to provide a payment description and payment amount. Prime recipients may aggregate reporting for payments to vendors made by the prime totaling less than $25,000 in a quarter. This data may be reported on the prime recipient tab.
- Q: I am a Sub-Recipient who has been delegated responsibility to report by my Prime Recipient, what information do I need to report about my purchases from Vendors?
Sub-Recipients are required to report only the Data Universal Numbering System (DUNS) number or name/zip code of the vendor’s headquarters for Vendor payments over $25,000. Reporting the amount of the purchase is recommended, but not required.
- Q: I made a purchase that was only partially funded by the Recovery Act. How should I report that purchase into FederalReporting.gov?
If your award is in the form of a grant, loan or cooperative agreement, only report the portion of the purchase that was paid directly out of Recovery Act funds using the appropriate data fields for vendor purchases. If your award is in the form of a contract with DOE you would not report vendor purchases.
- Q: I am a Recipient who made a purchase over $25,000 from a Vendor who is not located in the United States. The Vendor has neither a Data Universal Numbering System (DUNS) number nor a US zip-code. How should I report that purchase?
If the vendor does not have a Data Universal Numbering System (DUNS) number, then the name and zip code of the vendor's headquarters will be used for identification. Vendors, as defined in this guidance, are not required to obtain a DUNS number. In this case where the vendor does not have a US zip code, enter "000000000" (nine zeros) in the field.
- Q: My sub-recipient has made payments to vendors which do not total $25,000 in a single quarter. Should these payments be included in the aggregated vendor fields on the prime recipient tab?
Vendor payments totaling less than $25,000 in a quarter by the sub-recipient should not be reported in the aggregate field on the prime recipient tab. Instead these payments may be reported as line items in the vendor section, or else not reported at all. See the recipient reporting data dictionary for definitions and comments on the vendor data elements.