Recovery Act recipient reporting clarification

Accessible letter PDF: https://www.dol.gov/sites/dolgov/files/ETA/advisories/TEGL/2009/TEGL01-09C1ACC.pdf

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                 ARRA
               ADVISORY SYSTEM                            CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                        OFAM/TMG
             Washington, D.C. 20210                       DATE
                                                          September 21, 2009




TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 01-09, CHANGE 1

TO:                STATE WORKFORCE AGENCIES
                   STATE WORKFORCE LIAISONS
                   STATE WORKFORCE ADMINISTRATORS
                   STATE AND LOCAL WORKFORCE INVESTMENT BOARDS
                   ALL DIRECT ETA RECIPIENTS

FROM:              JANE OATES /s/
                   Assistant Secretary

SUBJECT:           Reporting Requirements under Section 1512 of the American Recovery and
                   Reinvestment Act of 2009


1. Purpose. To provide additional guidance on the reporting requirements included in Section
1512 of the American Recovery and Reinvestment Act of 2009 (Recovery Act) and to provide
clarification of selected data requirements.

2. References.
   • The American Recovery and Reinvestment Act of 2009, Public Law 111-5
   • OMB Implementing Guidance for the Reports on Use of Funds Pursuant to the American
       Recovery and Reinvestment Act of 2009 (OMB M-09-21), dated June 22, 2009.
   • TEGL 17-08, dated April 23, 2009: “American Recovery and Reinvestment Act
       (Recovery Act) Funds Financial Reporting Requirements”
   • Recipient Reporting Data Model, V.3.0 dated August 17, 2009

3. Background. Section 1512 of the Recovery Act requires recipients to report on the use of
Recovery Act funding, and provide detailed information, such as: total amount of funds
received; the amount spent on projects and activities; a list of those projects and activities
funded, including name, description, completion status and estimates of jobs created and
retained; and details on subawards and other payments.

The Office of Management and Budget (OMB) issued implementing guidance which provides
details on Section 1512 recipient reporting on June 22, 2009 (OMB M-09-21). The Employment
and Training Administration (ETA) synthesized this information to provide initial guidance to its
grantees, including reporting requirements and data elements and this information was issued as
TEGL 01-09.


 RESCISSIONS                                              EXPIRATION DATE
 None                                                     Continuing

Technical questions on the calculations and requirements for the data elements related to jobs
created or retained have arisen subsequent to the issuance of TEGL 01-09 and this Change 1 is
designed to provide additional clarification of OMB requirements.

4. Clarification of Reporting on Jobs Creation Estimates by Recipients. Prime
recipients are required to report an estimate of jobs directly created or retained to administer and
implement Recovery Act-funded projects, activities, and contracts (e.g., workforce managers,
supervisors, counselors, job coaches, etc.), as required by Section 1512(c)(3)(D) of the Recovery
Act. Recipients are required to report an aggregate number for the cumulative jobs created or
retained for the quarter in a separate numeric field. Recipients are also required to provide a
narrative description of the employment impact.

Prior guidance did not address the reporting requirements associated with the summer youth
employment opportunities component funded with ARRA under the Workforce Investment Act
(WIA) Youth Program. Consistent with OMB guidance, summer youth employment
opportunities and employment opportunities occurring outside the summer months funded
with the Recovery Act WIA Youth funds are to be included in the Jobs Creation Estimates
by prime recipients. For prime recipients, this will include all paid work opportunities funded
with the Recovery Act WIA Youth funds and would not include academic opportunities.

The estimate of the number of jobs funded by the Recovery Act must be expressed as “full-time
equivalents” (FTE), which is calculated as total hours worked (paid) divided by the number of
hours in a full-time schedule, as defined by the recipient. The FTE estimates must be reported
cumulatively each calendar quarter. These FTE will primarily be reported in the first quarterly
report as the jobs are short-term summer employment. For summer youth employment
opportunities, prime recipients must determine the actual hours worked. Possible sources of this
information may be payroll records or time distribution records maintained by subrecipients.

As indicated in the OMB guidance, the requirement for reporting 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 FTE jobs. In order to perform the
calculation, the recipient will need the total number of hours worked by quarter that are funded
by the Recovery Act. The recipient will also need the number of hours in a full-time schedule
for a quarter. The formula for reporting can be represented as:

                       Cumulative Recovery Act Hours Worked (Qtr1…n)
                                                                                =FTE
                       Cumulative Hours in a Fulltime Schedule (Qtr1…n)

Reporting is cumulative across the project lifecycle, and will not reset at the beginning of each
calendar or fiscal year. Detailed information about reporting on jobs created is provided in the
OMB guidance [OMB M-09-21].

As specified in TEGL 01-09, ETA Recovery Act recipients must include employment (which
includes the summer work) in the estimate of jobs created or retained on projects and activities
managed by their funding recipients in their aggregate number and their narrative description.
This information will be provided for each project and activity funded by the Recovery Act.
Prime recipients are required to generate an estimate of job impact by directly collecting specific
data from sub-recipients and vendors on the total FTE resulting from a sub-award. Prime


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recipients should collect the information from all sub-recipients and vendors in order to generate
the most comprehensive and complete job impact data available.

5. Examples. A subrecipient placed 100 youth in summer employment. The youth worked
between the period June 15 and August 15, 2009. Based on a review of available
documentation, the subrecipient determined that the total number of hours worked by the 100
youth over the 8 week period is 16,000 hours. This number is then divided by the standard hours
for an FTE of 520 for the quarter (2080 divided by 4) resulting in 30.77 FTE. This calculation is
displayed using the OMB formula below:

                       Cumulative Recovery Act Hours Worked (Q=16,000)
                                                                                       =Q 30.77 FTE
                        Cumulative Hours in a Fulltime Schedule (Q=520)

These FTE will primarily be reported in the first quarterly report as the jobs are short-term
summer employment. For example, a subrecipient placed 50 older youth in employment that
began on July 1 and ends on November 30, 2009. The hours worked from July 1 through
September 30, 2009 total 18,000 hours and an additional 11,000 for the quarter ending December
30, 2009. The FTE impact using the OMB formula is displayed below for both quarters:
                     Cumulative Recovery Act Hours Worked (Q1=18,000)
                                                                                 =Q 34.62 FTE
                      Cumulative Hours in a Fulltime Schedule (Q1=520)

                      Cumulative Recovery Act Hours Worked (Q2=29,000)
                                                                        =Q 27.88 FTE
                      Cumulative Hours in a Fulltime Schedule (Q2=1040)

It is important to remember that reporting is cumulative across the project lifecycle, and will not
reset at the beginning of each calendar or fiscal year. The table below shows the FTE
calculations through the lifecycle of an 18 month project that uses full-time, part-time, and
temporary workers.

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

Full-Time Schedule                  520     1040          1560       2080      2600        3120

Full Time Employee 1                520     1040          1560       2080      2600        3120
Full Time Employee 2                520     1040          1560       2080      2600        3120
Part Time Employee (half time)      260      520           780       1040      1300        1560
Temporary Employee (650
hrs.)                                 0        0           130        390       650         650
Total Hours Worked                 1300     2600          4030       5590      7150        8450

Quarterly FTE                       2.5       2.5          2.58      2.69      2.75         2.71

6. Technical Assistance. A series of webinars on Section 1512 recipient reporting was offered
by OMB the week of July 20, 2009. The list of OMB webinars is posted on www.Recovery.gov
and recordings are available. ETA conducted a webinar on August 17, 2009 and a recording is
available at www.workforce3one.org . Additionally, ETA plans to continue to provide technical
assistance, training and outreach to recipients. Please check www.doleta.gov for further details.

7. Inquiries. Questions regarding this guidance should be directed to the appropriate regional
office.

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