Assistant Secretary of Indian Affairs Office of the Chief Financial Officer

Recovery ActPrime Recipient Reporting Training

Bureau of Indian AffairsAlaska Region

May 25-27, 2010

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Presenter

Frank Dumanal, PMP Prime Recipient ReportingSenior Project ManagerOffice of the Chief Financial OfficerE-mail: Frankie.dumanal@bia.govPhone: (703) 390-6379

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Introductions

Name

Affiliation

ARRA Role

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Overview and Objectives

Course Format Recovery Update/Status Definition of Terms FederalReporting.gov and

Recovery.gov Relationship Basic Recipient Framework Recipient Reporting Example Prime Recipient Responsibilities Sub-Recipient Responsibilities July 2010 Reporting Cycle

Registration Initial Submission Specific Data Elements Guidance Recipient/Sub-Recipient Review Agency Review Lessons Learned Timeline and Activities for

Continuous QA Reporting Assistance

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Various Recovery Act Reports

Section 1512, FederalReporting.gov Quarterly Report

DOI Monthly/Quarterly Project Status Report; Risk Mangement

DOI/OMB Weekly Financial Report

Federal Highway Quarterly Report (Roads)

Government Performance Results Act (GPRA)

Data Reconciliation Report; Continuous Data Quality Review

Ad Hoc Reporting

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Recovery Act Update/Status

• 556 out of 564 Recipients Reported; highest DOI percentage• Report data can be corrected on a continuous basis until June 15• Reports will updated on Recovery.gov

– Wednesday, May 19– Wednesday, June 2– Wednesday, June 16 (Final)

• Quality Review Process– Involves extracting data from FederalReporting.gov on who reported– Compares extract file with Department and Indian Affairs procurement and acquisition data– Comparison creates a file of mismatched data for resolution

• Award number• Award amount• DUNS number

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Definition of Terms

Prime Recipient – Non-Federal entity that receives Recovery Act funding as Federal awards in the form of grants, cooperative agreements, or loans directly from the Federal Government.

Sub-Recipients – Non-Federal entity that is 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 Recovery funding. The terms and conditions of the Federal award are carried forward to the sub-recipient.

Vendor – Entities or individuals from which the prime recipient or sub-recipient procures goods or services needed to carry out the project or program. 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.

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Definition of Terms

So what’s the difference between a Sub-recipient and a Vendor?

Answer: Sub-recipients support performance of a mission. Vendors provide products or services in support of the mission. Data requirements for vendors are reduced. Prime Recipients may not delegate reporting to vendors.

Vendor characteristics that make it distinct from a sub-recipient are summarized below:

1. Provides goods and services within normal business operations2. Provides similar goods or services to many different purchasers3. Operates in a competitive environment4. Provides goods or services that are ancillary to the operation of the Federal

program5. Is not subject to compliance requirements of the Federal program

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Definition of Terms

Data Universal Numbering System (DUNS) number – unique nine-digit number that identifies your organization. A tool of the federal government to track how federal money is distributed. Provided by Dun & Bradstreet (D&B).

Central Contractor Registration (CCR) – Primary registrant database for the U.S. Federal Government. CCR collects, validates, stores, and disseminates data in support of agency acquisition missions, including Federal agency contract and assistance awards.

Catalog of Federal Domestic Assistance Number (CFDA) – Number associated with the published description of Federal assistance programs in the catalog for a Recipient Award. The 6-character CFDA number is formatted as follows: ##.###.

Treasury Account Symbol (TAS) – Serves as the identifier of the funding program source

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Definition of Terms (cont’d)

North American Industry Classification System (NAICS) – Developed as the standard for use by Federal statistical agencies in classifying business establishments for the collection, analysis, and publication of statistical data related to the business economy of the U.S.

National Taxonomy of Exempt Entities – Nonprofit Program Classification (NTEE-NPC) – National Center for Charitable Statistics code used to describe Recovery Act projects or activities. Specifically for FederalReporting.gov, NTEE-NPC code should be entered as the Activity Code for award funding of non-infrastructure projects for grants and loans award types. Serves as the identifier of the funding program source

www.FederalReporting.gov – OMB’s on-line web portal that will collect all Recovery Act recipient reports. This is the central reporting solution for Federal agencies, prime recipients, and sub-recipients.

www.Recovery.gov – A website that allows taxpayers to see how funds from the American Recovery and Reinvestment Act is being distributed and managed. The American public will be able to see the states, Congressional districts, and even Federal contractors that receive Recovery funds.

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Definition of Terms

FederalReporting PIN (FRPIN) – A nine-digit number created by FederalReporting.gov. For each DUNS number for which you will be reporting, you will need a FederalReporting PIN (FRPIN) to submit your report.

– FederalReporting.gov assigns each DUNS number a unique FRPIN– Your organization may have received multiple ARRA awards under multiple

DUNS numbers– You will need to identify each DUNS number for which you will be

reporting.– FRPIN is provided to your organization POC as listed in the Central

Contractor Registration (CCR) database.– POC will serve as your DUNS administrator or will delegate that

responsibility to another person in your organization

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FederalReporting.gov & Recovery.gov Relationship

Federalreporting.govRecipient Reporting

DatabaseSupports:• Recipient Registration• Recipient Reporting• Report Review and

Validation

Recovery.govReporting Data Portal

Database

Provides:• Public data access• Coverage Maps• Standard Reports• Reported Data

Publish

On-line web browserMethod 1

Excel SpreadsheetMethod 2

Custom software XMLMethod 3

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Basic Recipient Framework

Federal Agency

Prime Recipient

Sub-Recipient

Vendor

Vendor

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Recipient Reporting Example

BIA

Tribe A(Prime Recipient)

Corporation(Sub-Recipient)

123 Corp(Vendor)

XYZ Corp (Vendor)

Tribe A purchases computer equipment worth $200K from XYZ Corp

BIA awards $1M Recovery Act grant to Tribe A

Tribe A sub-awards $500K to Corporation

Corporation purchases road equipment worth $50K from 123 Corp.

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Prime Recipient Responsibilities

• Ultimately responsible for reporting ALL data required by Section 1512 of the Recovery Act and OMB Guidance

• Includes Federal Funding Accountability and Transparency Act (FFATA) data elements for the sub-recipients of the prime recipient

• May delegate certain reporting requirements to sub-recipients (in writing)

• Must report three additional elements associated with any vendors receiving funds from the prime recipient for payments greater than $25K

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Sub-Recipient Responsibilities

• May be required by Prime recipient to report Federal Funding Accountability and Transparency Act (FFATA) data elements

• Must also report one data element associated with any vendors receiving funds from the sub-recipient

– Vendor DUNS number

– Name and zip code of vendor HQ if vendor does not have a DUNS number

• Must report payments greater that $25K

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July 2010 - Reporting timeline and activities

Reporting is a quarterly responsibility that begins for the reporting period in which the award is made.

1 -10 11-21 22-29

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Registration FederalReporting.gov Pre-requisites

• Valid email address

• All recipients must have a DUNS number

• Central Contractor Registration (CCR)

– Prime and Sub Recipients must be registered

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RegistrationDUNS: getting started

• Does your organization already have a DUNS number? Multiple DUNS numbers?

– Check at http://fedgov.dnb.com/webform

• What is the DUNS number associated with this award?

– Check award documentation

– If not on the award documentation, use the DUNS number your organization provided on the award application

• Do you already have a DUNS number registered in CCR?

• If you don’t have a DUNS number, you may obtain on at http://fedgov.dnb.com/webform

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RegistrationDUNS: obtaining a DUNS

To request a new DUNS number, you will need the following information:

• Legal name• Headquarters name and address• “Doing business as” name

• Physical address• Mailing address (if different)• Telephone number• Contact name and title• Number of employees at your

physical location

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RegistrationCCR Registration

• Check to see if you have either an active or inactive CCR registration

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RegistrationCCR Registration (cont’d)

• If you do not have a CCR registration, use the “Start New Registration” button

• If you have an inactive registration, contact the CCR Assistance Center

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RegistrationFederalReporting.gov user types

There are several different types of users in FederalReporting.gov:

Federal Agency User

• Award and/or fund Recovery Act grants, loans, and/or contracts

• Track and monitor awards

• Review and comment on recipient reports

Recipient Point of Contact

• Validates recipient users reporting on behalf of the organization

• Assigns DUNS Administrators

• Removes users from DUNS organizations

• Administers FRPIN

Recipient DUNS Administrator

• Shares responsibilities with Recipient POC for one particular DUNS number

• Can only serve as DUNS Administrator for one DUNS number

• Remove users from DUNS organizations

• Administer FRPIN

Recipient User

• Able to submit recipient reports

• Must have FRPIN number approved by the Recipient POC or DUNS Administrator

1 2 3 4

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RegistrationCCR / FR.GOV Points of Contact

• Once an organization has registered in CCR, it has two defined Points-of-Contact:

– The CCR Primary POC

– The CCR Electronic Business POC

• The POC User for FR.GOV (“Recipient POC”) will be the same individual(s) named within the organization’s CCR registration.

• When someone registers with FederalReporting.gov (FR.GOV) using the same DUNS number as a DUNS registered with CCR, FR.GOV will automatically create a Point of Contact (POC) within the system.

• An email with a User ID and temporary password will be sent to the CCR POCs when anyone tries to register the same organization in FR.GOV.

Make sure CCR POCs understand their FR.GOV responsibilities

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RegistrationFR.GOV Registration

• After you have established a DUNS number, CCR registration, and have an administration strategy:

– Go to www.FederalReporting.gov

– Click the “Register Now” button

– Follow the registration steps

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Initial SubmissionRecipient reporting methods

Method One - Online data entry through a web browser• Data entry form• Access through user’s desktop web browser• Time-out function built-in• “Binocular” icon

Method Two - Excel spreadsheet• Download and fill out spreadsheet• Upload into FederalReporting.gov• Requires Excel 2003 or newer• Spreadsheet “locked” to prevent modifications• As of 3/09/2010, Version 1.6

Method Three - Custom software system extract in Extensible Markup Language (XML)

• OMB guidance contains data dictionary and XML schema• Must match a specific XML schema format• XML schema available on FederalReporting.gov

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Initial SubmissionAvoid duplicate reports

Scenario One - Decentralized reporting at the prime recipient level

Director A reports $100K

Director B reports $100K

$200K

$200K erroneously reported to FederalReporting.gov

instead of $100K

• Prime Recipient does not establish a single point of entry

• Allows for multiple parties to enter data

• Two different officials inadvertently create separate records and reporting on the same activity

PRIME RECIPIENT

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Scenario Two – Delegation by Prime Recipient to Sub-recipient

Prime Recipient reports $100K

$200K

$200K erroneously reported to FederalReporting.gov

instead of $100K

• Possible both Prime and Sub will report on same activity

Sub-recipient reports $100K

Initial SubmissionAvoid duplicate reports

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Scenario Three – Correction Phase

Prime-recipient “disables”his/her record of $100K

$0

$0 erroneously reported to FederalReporting.gov

Instead of $100KSub-recipient “disables”his/her record of $100K

Initial SubmissionAvoid duplicate reports

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Initial SubmissionPrime Recipient required data• Recipient Name*• Award Type• Award Number*• Final Report• Recipient DUNS Number• Recipient Account Number• Recipient Congressional District• Funding Agency Code• Awarding Agency Code• Award Date• Amount of Award*• CFDA Number• Program Source (TAS)• Sub Account Number for Program

Source (TAS)• Total Number of Sub Awards to

Individuals• Total Amount of Sub Awards to

Individuals

• Total Number of Payments to Vendors less than $25K/ Award

• Total Amount of Payments to Vendors less than $25K/ Award

• Total Number of Sub Awards less than $25K/Award

• Total Amount of Sub Awards less than $25K/Award

• Award Description• Project Name or Project/Program

Title• Project Status• Total Federal Amount ARRA

Funds Received/Invoiced• Number of Jobs*• Description of Jobs Created• Quarterly Activities/Project

Description• Activity Code (NAICS or NTEE-

NPC)* If incorrect, OMB currently considers a “Significant Error”

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Initial SubmissionPrime Recipient required data (cont’d)

• Total Federal Amount of ARRA Expenditure

• Total Federal ARRA Infrastructure Expenditure

• Infrastructure Contact Name• Infrastructure Contact Email• Infrastructure Contact Phone• Infrastructure Contact Phone Ext• Infrastructure Contact Street

Address 1• Infrastructure Contact Street

Address 2• Infrastructure Contact Street

Address 3

• Infrastructure City• Infrastructure State• Infrastructure ZIP Code+4• Street Address 1• Street Address 2• City• State• ZIP Code+4• Congressional District• Country• Prime Recipient Indication of

Reporting Applicability• Officer Name• Officer Compensation

* If incorrect, OMB currently considers a “Significant Error”

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Initial SubmissionPrime Recipient required data: vendor information

1. DUNS or Name and Zip Code of Headquarters

2. Expenditure amount

3. Expenditure description

Federal Agency

Prime Recipient

Sub-Recipient

Vendor

Vendor

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Initial SubmissionSub Recipient required data

1. Award Type

2. Award Number

3. Sub-recipient DUNS

4. Sub-recipient Congressional District

5. Amount awarded to sub-recipient

6. Total amount disbursed

7. Sub-award date

8. Sub-recipient place of performance

9. Sub-recipient officer names and compensation (Top 5)

Federal Agency

Prime Recipient

Sub-Recipient

Vendor

Vendor

For Financial Assistance awards only: Sub Recipient data may be reported by Sub Recipient or Prime Recipient

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Initial SubmissionSub-Recipient Required Data: vendor information

1. DUNS or Name and Zip Code of HQ Federal Agency

Prime Recipient

Sub-Recipient

Vendor

Vendor

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Initial SubmissionLess than $25K Reporting

• Section 1512(c)(4) and OMB Guidance allows for prime recipients to aggregate reporting on:

– Sub-awards less than $25,000

– Sub-awards to individuals

– Payments to vendors less than $25,000

• Prime recipients should provide separate aggregate dollar total for each of the three categories

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Total Number of Hours Worked & Funded by Recovery Act within Reporting Quarter

Quarterly Hours in a Full-Time Schedule (520 hours)

Specific Data Elements GuidanceNumber of Jobs

• “Jobs Created/Jobs Retained” is reported in the “Number of Jobs” field

• Number of Jobs is expressed in terms of “full-time equivalents” (FTE)

• Number of Jobs is a simple calculation:

FTE =

• Financial assistance prime recipients must include the hours worked on projects and activities managed by their funding recipients (i.e., sub-recipients)

• Prime recipients should not attempt to report the employment impact upon materials suppliers and central service providers (i.e., indirect jobs) or on the local community

• Best practice: maintain documentation of how you calculated Number of Jobs and include a description of the calculation in the “Description of Jobs Created” field.

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Period 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr

One (1) FTE Full-Time Schedule 520 520 520 520 520 520

Full Time Employee 1 520 520 520 260 130 130

Full Time Employee 2 520 520 260 260 130 130

Part Time Employee (halftime) 260 260 260 260 130 130

Temporary Employee (390 hrs) 0 0 130 130 130 0

Total Hours Worked 1,300 1,300 1,170 910 520 390

Quarterly FTE 2.50 2.50 2.25 1.75 1.0 .75

EXAMPLE

Specific Data Elements GuidanceNumber of Jobs

• Jobs may be reported even though no Recovery Act dollars have been expended. Report hours in the quarter in which they were worked.

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• Brief description of the types of jobs created or jobs retained.

• Description may rely on job titles, broader labor categories, or the recipient’s existing practice for describing jobs as long as the terms used are widely understood and describe the general nature of the work.

• Best practice: include a description of how Number of Jobs was calculated.

Specific Data Elements GuidanceDescription of Jobs Created

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• One award number – One Report

• Award number should be entered exactly as it is shown on the federally awarded contract, grant or loan document

• Award numbers are case, space, and special character sensitive

Specific Data Elements GuidanceAward Number

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There are three classifications of awards for the purposes of reporting in FederalReporting.gov:

• Federally Awarded Contract• Grant• Loan

Specific Data Elements GuidanceAward Type

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Specific Data Elements GuidanceAwarding & Funding Agency

• Awarding Agency: 4 digit code for the Federal agency that awards or administers the funds on behalf of the funding agency

• Funding Agency: 4 digit code for the Federal agency that is responsible for funding/distributing the ARRA funds to recipients

• Funding and awarding agency may or may not be the same

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Specific Data Elements GuidanceProgram Source

• The Agency Treasury Account Symbol (TAS) identifies the funding program source (as based on the OMB TAS list)

• Refer to OBM Financial Handbook at:http://intranet.bia.gov/subLevel/index.cfm?

fuseaction=showSubLevel&docID=977&toplevelID=560&parentID=724

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Specific Data Elements GuidanceCFDA

• Obtained from Catalog of Federal Domestic Assistance (CFDA) - associated with grants and loans only

• ARRA Logo designates ARRA-approved CFDA

• Only CFDA numbers specific to Recovery Act funding are valid in FederalReporting.gov

• Refer To Indian Affairs CFDA Crosswalk Handout for valid ARRA codes

– https://sp.ia.doi.net/sites/ASIA/ocfo/ofm/fsd/Shared%20Documents/Forms/AllItems.aspx

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Initial SubmissionCreate report: report type

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Three Tabs - Prime Recipient, Sub Recipients and Vendors

Initial SubmissionCreate report

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Initial SubmissionCreate report: enter recipient data

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Initial SubmissionCreate report: sub-recipient data

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Initial SubmissionCreate report: vendor data

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Initial SubmissionFR.GOV Data quality checks

• When a report is submitted, either via upload or on-line, FR.GOV runs a series of data quality checks after the submission.

• If a report has any potential errors, an email with the appropriate error messages is sent to the recipient user.

• Two different types of data quality checks:– Hard Errors:

• Will prevent successful submission of a report

• Report must be modified to be successfully submitted

• Example: Total Federal Amount ARRA Funds Received/Invoiced must be less than or equal to Amount of Award

– Warning Messages:

• Will NOT prevent successful submission of a report

• Are meant to merely WARN recipients that an error might exist

• Example: If Number of Jobs is greater than 0, it cannot equal or exceed Total Federal Amount ARRA Funds Received/Invoiced

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Recipient ReviewMy Reports

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Recipient ReviewSub-recipient review

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Recipient ReviewSub-recipient review

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Recipient ReviewVendor review

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Recipient ReviewVendor review

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Agency Review

• During this period, reports are “locked” and may not be freely modified by recipients

• Agencies review reports, focusing on fields OMB identified as significant errors:

– Recipient Name

– Number of jobs retained or created

– Federal award number

– Recipient name

• Recipients are provided with formal comments through FR.GOV• If a recipient receives a comment, the report is “unlocked” and

able to be modified for correction• Agencies identify any non-compliant or missing reporters

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Agency ReviewSignificant error/material omission

• Agencies are required to identify both ‘significant errors’ and ‘material omissions’

• Significant Errors:– Data fields of major concern per OMB are: award amount, number of jobs

created / jobs retained, award number and recipient name

– If a recipient does not make the requested correction or submit a reasonable explanation of why the data is not incorrect, then the award report is considered to have significant errors.

• Material Omissions:– Failure of a Federal ARRA award recipient to report on a received award

– Data in a report that is not responsive to a specific data element (e.g., lack of sufficient narrative description)

• Significant Errors and Material Omissions are ultimately reported to the Recovery Act Transparency Board and OMB

• Recovery Act award recipients that do not report are published on Recovery.gov

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Agency ReviewConsequences of uncorrected data

• Recipients will be given an opportunity to correct the deficiencies before bureaus and offices take enforcement actions

• A bureau or office may take proactive action to protect the Federal government’s interests when it is determined that a recipient is noncompliant with Section 1512 reporting requirements, by:

– Placing special conditions on awards or precluding the grantee from obtaining future awards for a specified period; or

– Taking action designed to prevent future noncompliance, such as closer monitoring

– Withholding, suspending or terminating payment of funds for noncompliance with the reporting requirements.

• 1st missed report: award official sends a cure notice or other strong letter to remind the recipient that reporting is mandatory

• 2nd missed report: award official will initiate termination action or other strong sanction, including suspension or debarment

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Recipient & Agency ReviewMaking corrections

• Reports may be updated once they have been initially submitted

• Reports may be updated at any time during the Initial Submission period

• During the Agency Review period, reports may only be updated if the report is “unlocked” with an agency comment

• Any Recipient User that has access to the FRPIN for a given DUNS number may update an associated report

• Reports may be updated multiple times within the reporting cycle

• Report updates may be made via the 3 reporting methods available (i.e., Excel template, online, XML)

• Federal agencies do not make updates to reports• Each time a report is submitted, the previous version of that

report is replaced

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Recipient & Agency ReviewChanges to ‘business key”

1. Open the applicable report

2. In the Report Information section of the report, click on the Change Key button

3. In the dialogue box, click on yes to leave the report

4. The Change Business Key dialogue box appears. Change Award, Order or DUNS data

5. Confirm Change Key

6. Enter FPRIN to confirm deactivation of old report

7. A new report will display for submission

• For any current quarter reports with incorrect business key, use the change business key function to avoid duplicate records. Business key data elements are: award number, order number and DUNS number.

• This function will create a new business key and deactivate the incorrect report from the current quarter.

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Lessons Learned

• DUNS/CCR expired during registration period• Waiting on FRPIN Number• CCR – Information “Opt Out” Selection• Grant Award Number entered incorrectly • Award reported as a contract instead of a grant• Incorrect codes used: Awarding Agency, Funding Agency, CFDA, Program Source, etc.• Amount of award reported does not match amount of Title I award to school• Project name less than adequate; better name needed• Project description inadequate• BIA/Interior unable to view submitted report due to school filing under another agency’s

code (one case confirmed)

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Timeline & Activities for Continuous QA

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Reporting Assistance

Service Desk Information· Phone: 877-508-7386 · TTY: 877-881-5186 · Email: Support@FederalReporting.gov · Chat:LivePerson Support

Service Desk Hours of OperationHours of operation varies.

Begin Date End Date Hours (EST) Days / Week

May 1, 2010 - June 30, 2010 8 AM - 6 PM ET Monday - FridayJuly 1, 2010 - July 31, 2010 7 AM - 9 PM ET Monday - Friday

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Questions