Q. Reporting Requirements for Recovery Act Transit Awards
Will the Financial Status Report and Milestone Progress Report reporting requirements for ARRA grants be different than current requirements?
No. In the Federal Register of March 5, 2009, FTA stated that FFRs and MPRs were due 10 days after the end of the quarter. However, effective with the quarter ended 12/31/09 reporting and beyond, FTA will allow recipients of ARRA funding to submit FFRs and MPRs by the 30th day after the end of the calendar quarter. Reports for the quarter ending 12/31/09 are due on January 30, 2010.
What is the definition of “infrastructure investments” for the purposes of Section 1512 reporting? Is it all capital such as bus purchases or Preventive Maintenance?
For the purposes of Section 1512, FTA considers all capital investments as “infrastructure” investments.
Do MPO’s and/or Urbanized Area direct grantees have to submit a Section 1511 certification to DOT before FTA can award an ARRA grant?
Maybe. DOT has determined that the FHWA/FTA joint planning requirements provide a robust process to ensure that projects have been properly reviewed and vetted and are an appropriate use of taxpayer dollars. Therefore, the Governor or his/her designee's signature on one Section 1511 certification can cover all highway and transit projects in a State under certain conditions.
In order for the Governor's certification to satisfy the Section 1511 requirement for transit projects in urbanized areas, the certification must cite the TIP/STIP planning process as the basis for certifying that the projects have been properly reviewed and vetted and are an appropriate use of taxpayer dollars. The State must also provide a link to the public web posting the STIP that includes (or will include prior to the grant award for a particular project) any highway and transit project designated to receive ARRA funding.
U.S. DOT will ensure that the certifications received from the State are posted on DOT's Recovery site.
If the Governor's certification includes only highway projects and not transit projects, or if the certification does not provide a link to the proposed transit projects included in the STIP for ARRA funding, it will be necessary for a direct recipient to submit an additional certification or project listing.
Secretary LaHood's letter to the Governors, dated February 27, 2009, which is posted on DOT's site at the Recovery link, includes sample formats for the Section 1511 certification and two other certifications by the Governor.
If an FTA grantee or FTA determines that no satisfactory 1511 certification has previously been made and posted, the grantee should ensure that an appropriate official (for example, a mayor, chairman of the MPO or transit board, or State transit division chief) signs a certification for the project (or a list of projects) and emails it to email@example.com so that FTA can review the certification and ensure that it is posted on the DOT website, and linked to Recovery.Gov as required prior to grant award. While the project must be included on the TIP/STIP, as appropriate, before grant award, it is not required that the TIP/STIP amendment process be complete before the 1511 certification is signed. If a previous certification was based on the TIP/STIP process and included a link to the TIP/STIP, when a new or revised ARRA project is reflected in the TIP/STIP as posted on a website, it is not necessary to submit a new 1511 certification.
Note that the certification requirement only applies to infrastructure projects, so a new certification is not required for an operating assistance project under Section 5307 and 5311.
Do all grantees have to submit the certifications required by Section 1201(a) (Maintenance of Effort) and Section 1607 (accepting ARRA funds)?
No. These certifications are one-time certifications at the State level.
What reports does ARRA require and when do grantees have to begin submitting reports?
There are several reporting deadlines in the ARRA. Some of them apply to the Federal agency (DOT) and some to grantees.
- All FTA grantees receiving grants under any FTA ARRA program will be expected to submit standard Financial Status Reports (FSR) and Milestone Progress Reports (MPR) and accompanying narrative reports quarterly ten days after the end of each quarter, starting with the first quarter that ends after grant award. (Note: a grantee that has used pre-award authority also has to submit an initial FSR when it executes the grant.) Except for being due 10 days after the end of the quarter instead of 30, and being quarterly instead of annual in the case of States and small urbanized areas, these reports are the same reports required in FTA Circular 5010 and the relevant program circulars.
- DOT began submitting weekly reports to Recovery.gov beginning March 3, 2009. These reports include obligations and disbursements by program and FTA generates all the financial information needed from the grant award information in TEAM, and for DELPHI, the Department's financial system. FTA encourages grantees to share noteworthy Recovery program accomplishments and "good news" stories and pictures with us so that we can pass them on to Recovery.gov to demonstrate to the public that the ARRA is working. Similarly, we encourage grantees to share less positive experiences with us so that we can work with the rest of DOT and the Office of Management and Budget (OMB) to address any potential issues. Grantees must report to the Inspector General any suspected incidence of waste, fraud and abuse related to ARRA funds, and should notify FTA regional offices of any problems encountered as they occur.
- The ARRA requires DOT grantees to report the information specified in Section 1201(c), 90 days, 180 days, one year, two years, and three years after February 17, 2009, which DOT then transmits to Congress. The grantee's first report was due May 18, 2009. Subsequent reports are due August 16, 2009, and thereafter on February 17, 2010, 2011, and 2012, for a cumulative reporting period ending at the end of the month preceding the due date.
The four FTA grantees that had received an ARRA grant before May 1, 2009, reported through a web based DOT reporting portal. Before the second report was due in August 2009, FTA provided access to the 1201(c) reporting form through TEAM. Further reporting instructions can be found at FAQ's on 1201(c) reports. FTA may issue revised or supplemental guidance before the next reporting period.
In general, the 1201(c) report requests aggregate information for each ARRA program from February 17, 2009, through the end of the reporting period. FTA will collect this information from grantees in a report in TEAM for each grant awarded and will aggregate the information for DOT's 1201(c) report to Congress on the number of projects for which funding has been awarded, expenditures, number of contracts that have been put out to bid, number of contracts that have been awarded, number of contracts for which work has begun, and number of contracts completed, and the ARRA funding associated with each category of contracts. The report will also request information on the number of direct on-site job hours associated with the ARRA funds awarded as of the end of the reporting period (both in-house labor and through contracts.) Grantees will not be expected to estimate employment data other than the direct on-site jobs (for example, construction workers building a maintenance facility, or transit agency workers doing preventive maintenance). DOT economists will compute the number of indirect jobs or induced jobs (for example, jobs at suppliers or in unrelated industries as a result of the money flowing through the economy.) The report also calls for information about State funding the grantee expected to receive and actually received between February 17, 2009 and September 30, 2010, for any projects that would be eligible for ARRA funding under the program for which the grantee is reporting. These questions are related to the Governor's 1201(a) certification of maintenance of effort, but only apply to the State funding directed to the grantee that is reporting.
FTA will aggregate the information from the grantee reports into reports for each of the three major FTA ARRA programs: Transit Capital Assistance - which includes money apportioned by the 5307 and 5311 formulas as well as TIGGER and Tribal discretionary grants; Fixed Guideway modernization formula; and Capital Investment Grants - discretionary ARRA funds for New Starts or Small Starts projects. FTA will also aggregate reports on any subsequent FTA grants awarded under the Departmental TIGER grant program.
Section 1512 includes specific reporting requirements for recipients of ARRA funds from all Federal agencies, not just DOT. The ARRA (section 1512(f)) requires Federal agencies to impose the reporting requirement on grantees. FTA has implemented this requirement through a special condition in each ARRA grant.
On June 22, 2009, the Office of Management and Budget (OMB) released new guidance for recipient reporting. This guidance, Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009 ("Recovery Act"), implements the reporting requirements for recipients of grants loans, and other forms of assistance. The page links provides access to:
- The new guidance [PDF]
- The recipient reporting data model, including data dictionary [PDF]
- The list of programs subject to recipient reporting [PDF]
In addition, FTA has published Section 1512 guidance for its grantees which can be found here
OMB has deployed a nationwide data collection system at the website http://www.federalreporting.gov/ that will reduce information reporting burden on recipients by simplifying reporting instructions and providing a user-friendly mechanism for submitting required data.
Each grantee that has received an ARRA grant as of the end of the reporting period must report. The 1512(c) reporting requirements include detailed information about the grant award(s) and about each project and sub-awardee (both sub-recipients and first tier contractors). Direct recipients may delegate some reporting to subrecipients, but remain responsible for the data quality of their subrecipients. Grantees (and any subrecipients that they have delegated to report directly) must register in advance in order to report through http://www.federalreporting.gov/. FTA encourages grantees to register as soon as possible, to be prepared to submit quarterly reports. Check the FTA and FederalReporting.Gov sites frequently for new information.
Under ARRA, all direct recipients and first tier sub-awardees (including both sub-recipients and contractors) must obtain a Data Universal Numbering System (DUNS) number. Direct recipients must also register with the Central Contractors Registration (CCR). Unless the CCR applicant intends to pursue other Federal business, they do not have to complete the Online Representations and Certifications Application (ORCA) as part of the CCR registration process. [See questions IV, C, 8-20 for information about how to obtain a DUNS number and register with the CCR.] [Note: Previous OMB guidance indicated that first tier sub-awardees would also be required to register on CCR, but more recently OMB has indicated that only Direct Recipients must register with CCR, except in the case where a sub-recipient has been delegated by the direct recipient to report sub-recipient information directly to FederalReporting.Gov.]
The President has to report to Congress every 90 days on status and progress of projects and activities funded by ARRA with respect to NEPA compliance. Each Department is reporting the information to the President's council on Environmental Quality (CEQ). FTA has submitted data for the reports due to CEQ in April and July, 2009. FTA is currently reporting based on the environmental determinations recorded in grant records in TEAM but may request supplemental information from grantees or applicants in the future.
Additional reporting may be required by the Inspector General (IG), the Government Accountability Office (GAO), or other entities, for example Congressional committees or individual members of Congress. If any of these entities requests information directly from an FTA recipient, the recipient may respond directly. FTA encourages grantees to copy the regional office on any responses to such requests for information.
In regard to Preventive Maintenance, and reporting concerning job creation- what if we did not create jobs but were able to save jobs through the ARRA funds, how do we report?
DOT is not making any distinction between jobs created and jobs maintained in the reporting of direct jobs for purposes of the 1201(c) reports. The 1201(c) reports will collect direct job hours related to the funding during the reporting period, but will not expect grantees to estimate indirect or induced jobs that result from the project OMB has provided similar guidance for the reporting of jobs for purposes of the Section 1512 reports.
Will FTA be issuing guidance on how to calculate direct and indirect jobs created, for reporting purposes?
Grantees will not be expected to calculate indirect jobs. The reporting guidance developed by FTA instructing grantees how to report job hours for direct jobs can be found at FAQ's on 1201(c) reports and in the 1201(c) Reporting Form.
FTA's reporting guidance for how to report jobs for 1512 can be found here.
For quick links to additional FTA resources, go to http://www.fta.dot.gov/index_9118.html
For more information on federal Recovery Act provisions,