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25th Annual MIS Conference
Presenters:
Matthew Case, U.S. Department of Education
Nancy J. Smith, DataSmith Solutions
Ross Lemke, AEM Corporation
The Collection and Reporting of the General Education Provisions
Act and Federal Sub-Award Reporting System Fiscal Data
This presentation reviews how potentially duplicative fiscal reporting requirements at the federal level are being handled in a
number of states and discusses alternatives being considered by ED.
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• Issue: Multiple overlapping statutory requirements
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1994• GEPA Section 424
2006• Federal
Funding and Accountability Act (FFATA)
2007•USASpending.gov Launched
2008• Recovery
Act (Section 1512)
• Recovery.gov
2010• FFATA
Subaward Reporting
• FSRS Launch
• 2/11 - Executive Order 13563 and Presidential Memorandum on “Administrative Flexibility” http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://www.whitehouse.gov/the-press-office/2011/02/28/presidential-memorandumadministrative-flexibility
• Directs agencies to review current agency requirements for flexibility
• 4/11 - OMB M-11-21 http://www.whitehouse.gov/sites/default/files/omb/memoranda/2011/m11-21.pdf
• Facilitate use of robust and authoritative data • Eliminate duplicative and unnecessary reporting
7/11 - ED RFI on Implementing Administrative Flexibility http://www.gpo.gov/fdsys/pkg/FR-2011-07-06/html/2011-16901.htm
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• Convene GEPA/FSRS Working Group at ED• Cross-functional stakeholder group – included Budget/CFO, NCES,
Policy, CIO, and General Counsel.• Identify potential risks and benefits associated with eliminating the
GEPA 424 collection.
• Develop GEPA/FSRS White Paper
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GEPA FSRSPurpose Biennial Congressional reporting
about federal spending in federal program areas
Public accountability & transparency about federal spending in federal program areas
Frequency & Timeliness Required: Bi-annually for two prior fiscal years
Encouraged: Annually for prior fiscal year
Monthly for awards made in previous month
Access to Data Limited to USED Public
Reporting Requirements All subgrants & subcontracts by SEA*; allocations from prior fiscal year
Sub awards over $25,000 by SEA; reporting is continuous throughout the year, as obligating actions from prime to subaward recipients occur
Use of Data Limited Congressional reporting, supplement NCES survey, State total federal spending figure in ED Data Express
Publicly available on USASpending.gov
Source: Downey, 2010; EDEN, 2011; Sauls, 2009* Applicable federal program areas included in GEPA, Section 424 are listed in EDFacts File 035. FSRS applies to all federal programs..
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GEPA FSRSFrequency Annually Monthly, unless no new
obligations made or updates to previous submissions are necessary
Time ½ to 2 ½ weeks 1-3 days per month when updates are needed. Extrapolated up to 2 ½-3 weeks per year on average
Staff 2-3 staff work on different aspects: extracting data, formatting files, submission process
2-3 ½ staff work on different aspects: extracting data, formatting files, submission process
Source: Estimates received via email from five states: Arkansas, Kansas, New York, Texas, and Washington.
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Data Element Name Definition / Comments
Corresponding FSRS Data Element Name
Same variable forGEPA and FSRS
File Record Number A sequential number assigned by the State that is unique to each record entry within the file.
N/A
ID 559FIPS State Code
The two–digit Federal Information Processing Standard (FIPS) Code for the State, District of Columbia, and the possessions and freely associated areas of the United States (e.g., Puerto Rico).
Recipient_state_code √
ID 570State Agency Number
The identifier assigned by the state education agency (SEA). This ID is a required field. This data element cannot be updated through this file.
DUNS?
Table Name An indication that the federal program(s) is offered in the state. FEDPROG N/A
Federal Program Code The unique five–digit number assigned to each Federal program as listed in the Catalog of Federal Domestic Assistance (CFDA), plus the letter associated with the subprogram if specified in Appendix A.
Cfda_num √
ID 547Federal Programs Funding Allocation Table
The amount of federal dollars retained by the state education agency (SEA) for program administration or other approved state-level activities, transferred to another state agency, distributed to non-LEAs, or unallocated.
Total_funding_amount √
Federal Programs Funding Allocation Type
The Funding Allocation Type allows for the identification of whether the SEA retained the funds for distribution, transferred the funds to another state agency, distributed to non-LEAs, or the amount is unallocated.
N/A
Explanation Submitted files will be processed through various edit checks. When unusual conditions are detected, warning errors may be issued, even though the data may be valid. When this occurs, an explanation responding to the warning may be submitted with the data, or after files have been processed.
N/A
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Data Element Name Definition / CommentsFSRS Data
Element NameSame variable forGEPA and FSRS
File Record Number A sequential number assigned by the State that is unique to each record entry within the file.
N/A
ID 559FIPS State Code
The two–digit Federal Information Processing Standard (FIPS) Code for the State, District of Columbia, and the possessions and freely associated areas of the United States (e.g., Puerto Rico).
Recipient_state_code √
ID 570State Agency Number
The identifier assigned by the state education agency (SEA). This ID is a required field. This data element cannot be updated through this file.
DUNS?
ID 4State LEA Identifier
The identifier assigned to a local education agency (LEA) by the state education agency (SEA). Also known as State LEA ID. This ID is a required field. This data element cannot be updated through this file.
DUNS?
Table Name An indication that the federal program(s) is offered by this district. FEDPROG N/A
Federal Program Code The unique five–digit number assigned to each Federal program as listed in the Catalog of Federal Domestic Assistance (CFDA), plus the letter associated with the subprogram if specified in appendix A.
Cfda_num √
ID 547Federal Programs Funding Allocation Table
The amount of federal dollars distributed to local education agencies (LEAs). The dollar amount is expressed as a numeric value in whole dollars, no decimal places or "$."
Total_funding_amount √
Explanation Submitted files will be processed through various edit checks. When unusual conditions are detected, warning errors may be issued, even though the data may be valid. When this occurs, an explanation responding to the warning may be submitted with the data, or after files have been processed.
N/A
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FSRS Elements EDFacts Directory (N029) and GEPA (N035) Elements
Federal Award Identifier Number (FAIN)
Federal Agency Name
Prime Awardee ‐ DUNS Number
Prime Awardee ‐ DUNS Number +4
Prime Awardee ‐ Name Education Entity Name (N029)
Prime Awardee ‐ DBA Name
Prime Awardee - Address Address Mailing (N029)
Prime Awardee ‐ Parent DUNS Number
Principal Place of Performance Address Location (N029)
CFDA Program Number (and Program title) Federal Program Code (N035)
Project Description
Total Federal Funding Amount Federal Programs Funding Allocation Table (N035)
Obligation/Action Date
Report Month
Awardee Names and Compensation of Highly Compensated Officers at the Prime Awardee Chief State School Officer Contact Information (N029)
Date of Report Submission
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FSRS Elements EDFacts Directory (N029) and GEPA (N035) Elements
Sub‐awardee ‐ DUNS Number
Sub‐awardee ‐ DUNS Number +4
Sub‐awardee ‐ Name Education Entity Name (N029)
Sub‐awardee ‐ DBA Name
Sub‐awardee ‐ Address Address Mailing (N029)
Sub‐awardee Parent DUNS Number
Amount of sub‐award Federal Programs Funding Allocation Table (N035)
Sub‐award Obligation/Action Date
CFDA Program Number (and Program Title) Federal Program Code (N035)
Federal Agency Name
Sub‐award Project Description
Sub‐awardee Principal Place of Performance Address Location (N029)
Sub‐award Number
Sub‐awardee Names and Compensation of Highly Compensated Officers
• Maintain Both Collections
• Retire GEPA, Section 424
• Retire FSRS Education Data
• Merge GEPA and FSRS Collections
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Risks• Burden that duplicate collections place on SEAs, particularly
under difficult state and federal budget constraints • Potential for discrepancies between the data sources and
multiple “versions of the truth”• Federal: Separate administration and governance• SEA: FSRS submissions are typically managed and conducted by a
different office or division than the GEPA submission
Benefits• As summary data, GEPA collection provides ED a potential
source of a “control total” to validate data submitted through FSRS
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Risks• SEAs provide data that are not collected in FSRS, including type of sub
recipients (i.e., LEA, non-LEA, other state agency), SEA retained funds, and ED-specific entity identifiers.
• GEPA data process is more mature and may be more reliable, valid, or complete.
Benefits• Reduction of reporting burden on SEAs. States report using 2-3 full-
time-equivalent staff and spending between 20 hours and two and a half weeks fulfilling the GEPA submission requirements annually. (FSRS is submitted only when new sub awards are made. Might not be monthly.)
• Reduces EDFacts system impacts of maintaining separate GEPA collection.
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• The possibility and desirability of eliminating FSRS are small.
• FSRS targets subawards for all federal programs, not only education.
• FSRS data is more up-to-date than GEPA.
• Analyses have shown a high correlation between FSRS and GEPA data.
• Widespread availability of FSRS data through the USASpending.gov public portal increases the likelihood the data will be used.
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• Purpose is different
• Most non-financial data elements are different
• Collection schedule is different
• Managed by different agencies
• ED can collect data for its reports from FSRS
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• Are subaward data reported to USASpending the same or better quality than data reported via EDFacts GEPA collection?
• Difficult to do comprehensively because of the lags in GEPA reporting
• Quality of Source Data (Prime Award information)
• Identify Potential Reporting Gaps
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• Percentage of SEA prime awards* reported to USASpending.govthat Exactly Match to USDoED Budget allocation tables(Selected Formula Programs)
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Program FY2006 Allocations FY2007Allocations
FY2008Allocations
84.010 – Title I Grants to LEAs
96% 96% 96%
84.027 – IDEA Grants to SEAs
100% 96% 96%
84.173 – IDEA Preschool Grants
100% 98% 98%
*Includes 50 States, DC and PR.Source : www.usaspending.gov (Direct link) and USDoED Budget Service (Direct Link)
• FFATA Subaward Reporting Required for:• New awards (e.g., a new FAIN is issued) made after October 1, 2010
funded at $25,000 or more
• ARRA awards and continuations are excluded
• FFATA subaward reporting requirements are inserted into Grant Award Notification (GAN) (Attachment P)
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• Are programs required for reporting under GEPA currently being required to be reported to FSRS?
• Estimated 70-80% of non-ARRA FY2011 awards subject to GEPA requirements required
• If required, are SEAs actually reporting?• Example: FY2011 Title I Grants to LEAs (84.010)
• Number of States reporting subgrants to FSRS: 30• Of those, about 50% are within the expected dollar amounts and total
subgrants when compared to prior year GEPA and FY11 Budget allocations.
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Presenters:
Matthew Case, US Department of Education
Nancy J. Smith, DataSmith Solutions
Ross Lemke, AEM Corporation
Back-up Slides
Thank You.
• FFATA and its subsequent 2008 amendments seek to increase transparency and improve access to Federal Government information by:
• Requiring information disclosure of entities receiving Federal funding through Federal awards such as Federal contracts and their sub-contracts, and Federal grants and their subawards;
• Requiring disclosure of executive compensation for certain entities;• Requiring the establishment of a publicly available, searchable
website that contains information about each Federal award; and• Requiring agencies to comply with the OMB guidance and
instructions, and to assist OMB in the implementation of the searchable website.
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*Source: OMB memo “Open Government Directive – Federal Spending Transparency and Executive Compensation Data Reporting , August 27, 2010 - http://www.whitehouse.gov/sites/default/files/omb/open/Executive_Compensation_Reporting_08272010.pdf
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