Q. FAA Recipient Reporting under the Recovery Act, Section 1201(c)
FAA Recipient Reporting under the Recovery Act, Section 1201(c)
(1) What is the ARRA, or "American Recovery and Reinvestment Act of 2009"?
The ARRA, or "American Recovery and Reinvestment Act of 2009," appropriates Federal funds for the purpose of stimulating economic recovery. The law was signed by the President on February 17, 2009 as Public Law 111-5. You may access the complete text of the Act here.
The Department of Transportation has received funding to carry out ten transportation infrastructure investment programs. Information about the DOT programs is available here.
(2) Where can I get more information about the ARRA as a whole?
More information is available on the Recovery.gov website.
(3) Are grant recipients and contract awardees that receive ARRA funds required by law to report specific information to the Federal Government about the expenditure of ARRA funds?
Yes. Section 1201(c) of the ARRA requires reports to DOT, and section 1512(c) requires more extensive reporting by all recipients of ARRA funds, including transportation recipients.
The FTA has prepared a convenient summary of various certification and reporting requirements applicable to DOT grantees.
(4) Do these FAQ's cover section 1512(c) reporting under ARRA?
No. Section 1201 applies to DOT grantees and contract awardees only and is the subject of these FAQs.
The Office of Management and Budget has published proposed forms and reporting instructions for the Section 1512 reports grantees must submit quarterly if they receive ARRA funds. You are encouraged to review the proposed guidance and submit comments and questions directly to OMB as directed in the FR Notice.
(5) Is 1201(c) reporting connected to the reports recently filed with the Transportation and Infrastructure Committee?
No, submitted data must be consistent with any filing you made with the committee, but this is a separate requirement, which will continue for several years, and with an initial cut-off date for reporting that is later in time than the Committee's initial date.
(6) How do States and similarly situated government recipients of FHWA funding for Highway Infrastructure Investment Grants file reports required by 1201(c) of ARRA?
No. The Federal Highway Administration has fashioned a separate mechanism for 1201 reporting on Highway Infrastructure Investment grants. Detail is available here.
Note, however, that a State or similarly situated government that also obtains funding under one of the other ARRA programs subject to section 1201 would report on that funding in accordance with these FAQs.
(7) What happens to the information supplied by recipients under the section-1201(c) requirements?
In accordance with the provisions of section 1201(c), it is transmitted to Congress by the Department.
(8) What are the statutorily established reporting dates by which recipients must have completed their reports?
The reporting schedule established in statute to complete each periodic report is as follows:
May 18, 2009
August 16, 2009
February 17, 2010
February 17, 2011
February 17, 2012
(9) Will the Department of Transportation assist grant recipients and contract awardees in complying with section 1201(c)?
Yes, as discussed under section 1201(c)(1) - the Department plans to perform the calculation of estimated indirect and induced jobs created by the projects you undertake, for example. Providing an online mechanism for submitting required data elements is another example of DOT assistance.
(10) Is each report only about what has occurred since the last report, or does each report reflect cumulative data about totals since the February 17, 2009, enactment date and all ARRA grants or contracts received since then?
With one exception, section 1201(c) requires you to report, in each periodic report, cumulative data on funds received and projects that have been put out to bid, are awarded, or have been completed since the enactment date of ARRA (February 17, 2009). The exception is for "contracts out to bid." Once the contract is awarded or withdrawn, it is no longer included in this total. It is included in this total if the contract was "out to bid" during any of the period since the last filed report (or since February 17, 2009, in the case of the May 18 report).
(11) Is project-by-project reporting required, or is aggregate data to be submitted?
Aggregated financial and jobs data is filed for each Program under which the recipient has received funding. Project-by-project information is not filed.
(12) Can my initial entries be revised during the reporting period of May 8 to May 18?
Yes. You may reenter the system at any time to revise entries. After May 18, however, submitted data will be "locked" so that job calculations can be made and data reviewed for completeness, etc.
(13) What information must I provide for the number of on-project and other direct jobs created or sustained by the federal funds provided?
You are only required to report the on-project and other direct job hours related to the ARRA funding you have expended as of the reporting cut-off date. The information requested is the total cumulative number of direct hours worked on the ARRA projects both by the grant recipient and by contractors and subcontractors at the local project sites. An example of a direct job is a worker employed to construct a facility or to maintain equipment on-site whose time is charged directly to the project. In the case of a transit vehicle purchase, direct job hours would be the time spent by the grant recipient's employees in preparing specifications or conducting the procurement, if this time is charged to the ARRA grant. You are not asked to calculate, and should not report, indirect or induced job hours. An example of an indirect job is a worker who makes the steel or other construction materials used at the project site, or who manufactures a bus purchased by a transit authority using ARRA funds. These indirect jobs are not charged directly to the project but are embedded in materials costs. An example of an induced job is a fast food worker who sells lunches to your workers. DOT will calculate indirect and induced job hours from the data you provide on direct jobs and overall expenditures. Also, you do not need to distinguish between jobs created and jobs sustained.
(14) Are separate records required if the grant recipient receives funding from more than one program?
Yes. For example, if a transit operator receives funding from more than one of the Programs funding the transit sector, a separate report is made on each program, for example Transit Capital Assistance, Fixed Guideway Infrastructure Investment, and Capital Investment Grants. Note, however, that the Transit Capital Assistance program includes formula apportionments for urbanized areas and for non-urbanized areas, as well as the TIGGER and Tribal discretionary grant programs. Only one report for the AARA Transit Capital Assistance Program would be required from a grantee receiving both ARRA urbanized area formula funds and a TIGGER grant, for example, but three reports would be required from a Transit agency receiving urbanized area formula funds from the Transit Capital Assistance program, formula funds under the Fixed Guideway Infrastructure Investment Program, and discretionary funding for a New Starts project under the AARA Capital Investment Grants Program
(15) Taking FTA "Transit Capital Assistance" and FAA "Airport Improvement Grant" categories as examples, is reporting limited only to ARRA grants made in those categories or should reports cover non-ARRA grants as well?
Report only grants and contracts that involve ARRA funding.
(16) Can an umbrella group such as a Metropolitan Planning Organization take responsibility for reporting on all funding it allocates to other entities?
No, not unless the MPO is the direct recipient of the grant award. The grant recipient in this and comparable cases is deemed to be the direct recipient of the Federal grant. A direct grantee reports on all projects for which funding has been awarded to it, including any tasks that have been implemented by subrecipients.
(17) Is there a possibility that the Department's Inspector General or the Government Accountability Office (GAO) will initiate a review of the data submitted by recipients for timeliness and accuracy?
With the high degree of emphasis being placed on accountability for ARRA expenditures by all parties, it is likely the Department's Inspector General and GAO will review the 1201 reporting process and results as a whole.
(18) Who should a grant recipient or contract awardee contact for further information?
Follow directions on the web site of the agency or office that made the grant for more information, in the area dedicated to ARRA implementation.
(19) What information must be provided about planned and actual State funding?
The Governor of each state provided a certification to DOT under Section 1201(a) regarding maintenance of effort of State funding for the kinds of transportation projects eligible for ARRA funding. These aggregated figures represent the totals for each DOT program but not the specific expenditures from State sources planned for your organization. Thus, you need to report the total amount you planned for your organization alone. The same is true for the actual expenditure of funds from State sources made by your organization as of the each reporting date. Remember, you must report all the planned and actual spending from State sources for the program concerned, not just spending that matches up with ARRA projects.