ARRA Reporting Change Hits 'Raw Nerve'
| Date Posted: January 13, 2010 |
Some State, District Officials Say They Can't Comply With Last-Minute Changes
Washington, Jan. 9 — State and district officials are balking at implementing a late change in stimulus reporting announced just prior to the Christmas holiday, with a sizeable number of them saying they will not comply with the requirement to submit recalibrated data by the Jan. 15 deadline.
Gene Wilhoit, executive director of the Council of Chief State Officers, explained in a letter that the federal government's decision to change procedures at the last minute "has frankly hit a raw nerve across many states." The Dec. 23 letter to Education Department (ED) Secretary Arne Duncan cautioned that the move sends a signal about "the potential for arbitrary federal demands" and called it "wasteful and a distraction from the significant challenges states and local agencies are currently engaged in."
Simplification
The controversy centers around guidance issued by the White House Office of Management and Budget (OMB) on Dec. 18. The changes were designed to simplify a process many federal grantees found too complex and produce more precise job counts that are less apt to attract political criticism as "puffery."
Prior to the guidance, recipients were required to total all stimulus-funded hours worked from the current quarter and all prior quarters and divide that total against the number of hours a full-time employee would have worked in the same period. This ratio provided a full-time equivalent estimate by project over all reporting quarters since the enactment of the American Recovery and Reinvestment Act (ARRA) on Feb. 17, 2009. The job estimate calculation now has been changed so that recipients will report job estimate totals by dividing the hours worked in the reporting quarter (i.e., the most recent quarter) by the hours in a full-time schedule in that quarter. OMB no longer requires recipients to total jobs data across multiple quarters.
But at the time the guidance was issued, many districts had completed their data crunching under the old system in anticipation of closing over the holiday break. For many districts, the new guidance raised the daunting prospect of having to compile and verify a complex data set in a matter of days. In his letter, Wilhoit asked Duncan to make the changes "prospective only"— a request that was denied. ED, however, extended the original deadline for submitting quarterly reporting information by five days, with data due no later than Jan. 15 instead of Jan. 10.
Responding to the criticism, an ED spokeswoman said, "Adjustments to the quarterly reporting requirements will make the process simpler for recipients," adding that after the deadline, there will be an opportunity for states to submit corrections.
'Piling On'
Jeff Berger, chief financial officer and government relations coordinator for the Iowa department of education and leader of a national consortium of federal relations directors, said he's heard from officials in 10-15 states that they couldn't collect the data in time and planned to submit reports calculated under the old system.
"The man hours involved are just ridiculous," he said. "We can't change a huge national data collection in a few days."
Elizabeth Carpentier, deputy superintendent in South Carolina, said the change was an unnecessary burden on states, many of which are also preparing applications for the first round of the Race to the Top competition, due Jan. 19. Additionally, ED's Office of Inspector General made a monitoring visit to her state between Jan 4-8.
"As I mentioned earlier to a USED contact, if this was football, they would be facing penalties for piling on and unnecessary roughness," she said in an e-mail.
Some States Will Comply
Nonetheless, not all states are planning to bypass the requirement. Missouri and Texas, both of which have several large school districts, released guidance on how to comply with the new reporting requirements. Bette Morff, Missouri's coordinator of federal grants and financial management, said that all of the schools were responding to the call for new data. "We feel that we will be able to report the information on time," she said.
Neither ED nor OMB have indicated how they will handle states that don't comply with the new guidance. One thing is certain: The fact that different states will be submitting data using different calculations has the potential to further disrupt a reporting process that has already been criticized for lack of rigor.
"It has the potential to muddy an already soft data pool," said Iowa's Berger.
Definition of ARRA "Job" Revised
In another key change outlined in the guidance, OMB changed the definition of a "job created or retained." Previously, recipients were required to make a subjective judgment on whether a given job would have existed were it not for the ARRA. This was easy when ARRA funds were used to directly fund jobs otherwise scheduled for termination without the federal funding. But it was much harder to estimate the domino effect when ARRA funds were used for other purposes, such as equipment, and the state and local monies freed up were used to fund jobs elsewhere in the organization. Oftentimes, the number of jobs saved or created was difficult to determine and led to claims by some critics that ARRA job counts were exaggerated.
The updated guidance eliminates this subjective assessment and defines jobs created or retained as those directly funded in the quarter by the ARRA. Jobs funded with non-ARRA funds will not be counted unless the relevant accounts will be reimbursed with ARRA funds. Jobs funded partially with ARRA funds will only be counted based on the proportion funded by the ARRA.
— Andrew Brownstein, Jerry Ashworth and Charles Edwards
For Your Information
The complete OMB guidance is available at http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-08.pdf.
Washington, Jan. 9 — State and district officials are balking at implementing a late change in stimulus reporting announced just prior to the Christmas holiday, with a sizeable number of them saying they will not comply with the requirement to submit recalibrated data by the Jan. 15 deadline.
Gene Wilhoit, executive director of the Council of Chief State Officers, explained in a letter that the federal government's decision to change procedures at the last minute "has frankly hit a raw nerve across many states." The Dec. 23 letter to Education Department (ED) Secretary Arne Duncan cautioned that the move sends a signal about "the potential for arbitrary federal demands" and called it "wasteful and a distraction from the significant challenges states and local agencies are currently engaged in."
Simplification
The controversy centers around guidance issued by the White House Office of Management and Budget (OMB) on Dec. 18. The changes were designed to simplify a process many federal grantees found too complex and produce more precise job counts that are less apt to attract political criticism as "puffery."
Prior to the guidance, recipients were required to total all stimulus-funded hours worked from the current quarter and all prior quarters and divide that total against the number of hours a full-time employee would have worked in the same period. This ratio provided a full-time equivalent estimate by project over all reporting quarters since the enactment of the American Recovery and Reinvestment Act (ARRA) on Feb. 17, 2009. The job estimate calculation now has been changed so that recipients will report job estimate totals by dividing the hours worked in the reporting quarter (i.e., the most recent quarter) by the hours in a full-time schedule in that quarter. OMB no longer requires recipients to total jobs data across multiple quarters.
But at the time the guidance was issued, many districts had completed their data crunching under the old system in anticipation of closing over the holiday break. For many districts, the new guidance raised the daunting prospect of having to compile and verify a complex data set in a matter of days. In his letter, Wilhoit asked Duncan to make the changes "prospective only"— a request that was denied. ED, however, extended the original deadline for submitting quarterly reporting information by five days, with data due no later than Jan. 15 instead of Jan. 10.
Responding to the criticism, an ED spokeswoman said, "Adjustments to the quarterly reporting requirements will make the process simpler for recipients," adding that after the deadline, there will be an opportunity for states to submit corrections.
'Piling On'
Jeff Berger, chief financial officer and government relations coordinator for the Iowa department of education and leader of a national consortium of federal relations directors, said he's heard from officials in 10-15 states that they couldn't collect the data in time and planned to submit reports calculated under the old system.
"The man hours involved are just ridiculous," he said. "We can't change a huge national data collection in a few days."
Elizabeth Carpentier, deputy superintendent in South Carolina, said the change was an unnecessary burden on states, many of which are also preparing applications for the first round of the Race to the Top competition, due Jan. 19. Additionally, ED's Office of Inspector General made a monitoring visit to her state between Jan 4-8.
"As I mentioned earlier to a USED contact, if this was football, they would be facing penalties for piling on and unnecessary roughness," she said in an e-mail.
Some States Will Comply
Nonetheless, not all states are planning to bypass the requirement. Missouri and Texas, both of which have several large school districts, released guidance on how to comply with the new reporting requirements. Bette Morff, Missouri's coordinator of federal grants and financial management, said that all of the schools were responding to the call for new data. "We feel that we will be able to report the information on time," she said.
Neither ED nor OMB have indicated how they will handle states that don't comply with the new guidance. One thing is certain: The fact that different states will be submitting data using different calculations has the potential to further disrupt a reporting process that has already been criticized for lack of rigor.
"It has the potential to muddy an already soft data pool," said Iowa's Berger.
Definition of ARRA "Job" Revised
In another key change outlined in the guidance, OMB changed the definition of a "job created or retained." Previously, recipients were required to make a subjective judgment on whether a given job would have existed were it not for the ARRA. This was easy when ARRA funds were used to directly fund jobs otherwise scheduled for termination without the federal funding. But it was much harder to estimate the domino effect when ARRA funds were used for other purposes, such as equipment, and the state and local monies freed up were used to fund jobs elsewhere in the organization. Oftentimes, the number of jobs saved or created was difficult to determine and led to claims by some critics that ARRA job counts were exaggerated.
The updated guidance eliminates this subjective assessment and defines jobs created or retained as those directly funded in the quarter by the ARRA. Jobs funded with non-ARRA funds will not be counted unless the relevant accounts will be reimbursed with ARRA funds. Jobs funded partially with ARRA funds will only be counted based on the proportion funded by the ARRA.
— Andrew Brownstein, Jerry Ashworth and Charles Edwards
For Your Information
The complete OMB guidance is available at http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-08.pdf.
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