Posted Date: October 9, 2009
Author: Jeff Baker, Director Policy Liaison and Implementation, Federal Student Aid
Subject: Reporting Guidance for Federal Work-Study funds received under the American Recovery and Reinvestment Act of 2009 (ARRA)
In Electronic Announcements posted to our IFAP website (ifap.ed.gov) on September 24, 2009 and October 2, 2009, we provided information on the reporting requirements for schools that received $25,000 or more in 2009-2010 Federal Work-Study (FWS) funding from the American Recovery and Reinvestment Act (ARRA). Both announcements advised affected schools that the first reporting step was for the school to register by October 10, 2009 at www.federalreporting.gov. We also informed schools that while the stated ARRA reporting deadline for the calendar quarter ending September 30, 2009 is October 10, 2009, the ARRA reporting system will remain open through October 21, 2009 to accommodate institutions that are unable to meet the October 10 reporting date due to late notification of FWS reporting guidance from the Department. We reminded schools that they should report as soon as possible after receiving reporting guidance from the Department and must report no later than October 21, 2009, as the system will close on that date for the quarter ending September 30, 2009. If an institution reports after October 10, 2009 the system will ask for a “late justification”. For FWS reporting only, institutions may enter “Late notification of Federal Work-Study reporting requirements from the U.S. Department of Education”.
We also stated in the earlier announcements that we would be providing guidance on how schools are to report their expenditures for the portion of their 2009-2010 FWS allocation that was funded by the ARRA. The information that follows is the current guidance from the Office of Management and Budget (OMB) on how schools that received $25,000 or more in 2009-2010 FWS funding from the ARRA should report1. We have also attached to this Electronic Announcement a Federal Work-Study Program – ARRA Reporting Tip Sheet that institutions should follow when reporting on their ARRA Federal Work-Study funds.
Reporting is required by the 10th day of the month following the end of the calendar quarter. However, as noted above, for the quarter ending September 30, 2009 only, schools should report as soon as possible but no later than October 21, 2009.
For administrative ease and reporting consistency, conventions and assumptions have been established for all schools as follows:
a. The first funds drawn from the school’s 2009-2010 FWS allocation are assumed to be ARRA funds.
b. Total ARRA expenditures to be reported are equal to the total actual net drawdowns of 2009-2010 FWS funds received from the Department (using the Department’s G5 system) during the quarter ending September 30, 2009, not to exceed the amount of the school’s FWS funding from ARRA for the full award year. Note that it is drawdowns that equals expenditures and not payments made to FWS employed students. [See Field #10 of the Tip Sheet to verify the total amount of 2009-2010 FWS funding that came from the ARRA].
c. The current Federal minimum Federal hourly wage rate of $7.25 may be used by all schools in the calculation of the number of jobs created or retained regardless of the actual hourly wage rate paid to their FWS students. Schools may, but are not required to use an alternate average wage rate.
d. The standard FWS matching rate of 75% is to be used by schools in the calculation of the number of jobs funded from ARRA funds, regardless of the actual matching rate used for all or a portion of the institution’s FWS jobs. However, Title III/IV schools that have been granted an FWS institutional share waiver should use 100% instead of the 75% matching rate.
The number of FWS jobs reported is on a fulltime equivalent basis regardless of the number of part-time jobs actually funded.
To determine the number of fulltime equivalent jobs created or maintained, the school performs the following calculation. Note that if the institution chooses to use an average hourly wage different than the $7.25 Federal minimum wage rate, it must perform the following steps using the appropriate alternate wage rate.
a. Multiply the $7.25 Federal minimum wage rate by 2,000 hours (an approximation of the number of work hours in a year). This will equal $14,500.
b. Multiply $14,500 by the standard FWS Federal share of 75% (regardless of the actual Federal share for all or some jobs at the school) which equals $10,875. Institutions that have been granted an FWS institutional share waiver should not perform this step in the calculation and should use the full $14,500 in the next step.
c. To calculate the number of fulltime equivalent FWS jobs that were funded using ARRA funds, divide the ARRA drawdown amount (see guidance point #2b above) for the quarter ending September 30, 2009 by $10,875 and round the result up to the next highest whole number.
As noted, we have attached to this Electronic Announcement a Federal Work-Study Program – ARRA Reporting Tip Sheet this describes how a school should report each item.
Finally, as a reminder, neither schools nor states have any responsibility for reporting on the increased Federal Pell Grant awards created as a result of AARA funding.
If you have any questions regarding ARRA reporting requirements, contact the Service Desk for Federal Reporting at 877-508-7386 or by email at: Support@FederalReporting.gov.
Thank you for your patience and understanding as we try to minimize the impact of ARRA reporting on schools.
1. Use amount for institution from Column F (Portion Attributed to ARRA 2009-2010) by linking to the Excel spreadsheet at FWS ARRA Reporting Act of 2009 in Excel Format, 289KB