Grantee Learning Series for COVID-19 Relief Programs: FFATA & APR Reporting

Summary

This is a slide presentation titled Grantee Learning Series for COVID-19 Relief Programs: FFATA & APR Reporting from the Office of State and Grantee Relations at the U.S. Department of Education. Its stated purpose is to ensure all Grantees are aware of the reporting requirements under the ESSER, GEER, and EANS programs and to highlight solutions to known reporting challenges. The objectives are to review the requirements of the Federal Funding Accountability and Transparency Act (FFATA) and Annual Performance Reporting (APR) and key resources for completing them. The agenda covers FFATA reporting requirements, key terms and common challenges, and the APR overview, timeline, data collection process and tips.

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Issuer: Congressional materials
Document type: Department Of Education Presentation Www Ed Gov 0Db5339Ea1
Case: Department Of Education Presentation Www Ed Gov 0Db5339Ea1

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“Grantee Learning Series for COVID-19 Relief Programs: FFATA & APR Reporting.” Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-presentation-www-ed-gov-0db5339ea1/, SHA-256 2a3952aefc83d2e1c818a7511d79b9c72190152ecaf8e08964005f81284280c6.

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Grantee Learning Series for
COVID-19 Relief Programs:
FFATA & APR Reporting
The Office of State and Grantee Relations

Laura Jimenez, Director, Office of State and Grantee Relations

1
Purpose
• Ensure all Grantees are aware of the reporting requirements
under the ESSER, GEER, and EANS programs.

• Highlight solutions to known FFATA and APR reporting
challenges.

U.S. Department of Education 2
Objectives

Participants in this meeting will:

1. Review the reporting requirements of the Federal
Funding Accountability and Transparency Act (FFATA) and
the Annual Performance Reporting (APR) for the ESSER,
GEER, and EANS programs.

2. Review key resources available to help grantees
successfully complete FFATA and APR reporting
requirements for the GEER, ESSER, and EANS programs.

U.S. Department of Education 3
FFATA and APR Reporting
FFATA Reporting
1. Acronyms & Quick Links
2. FFATA Reporting Requirements
3. Key Terms
4. Common FFATA Challenges and How to Overcome Them
5. Reminders & Resources
APR Reporting
1. Overview of Annual Performance Reporting Requirements
2. Timeline
3. Data Collection Process
4. Tips for Successful Reporting
5. Q&A U.S. Department of Education 4
FFATA Reporting

5
FFATA Table of Contents
• Acronyms & Quick Links: Slide 7
• FFATA Reporting Requirements: Slide 8-9
• Key Terms: Slide 10
• Common Reporting Challenges: Slides 11-15
• What To Do when Issues Arise: Slide 16
• Helpful Reminders: Slide 17
• FFATA Resources: Slide 18

U.S. Department of Education 6
Acronyms & Quick Links
• FFATA: Federal Funding Accountability and Transparency Act - FFATA Act (2006) | GRANTS.GOV
• FSRS: FFATA Subaward Reporting System - https://www.fsrs.gov/
• USAspending: FFATA Statute requires that information about Federal awards (Federal financial
assistance and subawards) be made available to the public via a single, searchable website and
maintained by OMB. That site is www.USAspending.gov
• ESF: Education Stabilization Fund
• ESF Transparency Portal (Portal): https://covid-relief-data.ed.gov/
• SAM: System for Award Management - https://sam.gov/
• OMB: Office of Management and Budget
• GSA: General Services Administration
• FSD: Federal Service Desk - GSA Federal Service Desk Service Portal
• UEI: Unique Entity Identifier - Used within SAM.gov as a primary key to uniquely identify an
entity or part of an entity. In April 2022, the UEI replaced the DUNS number as the primary
identifier for Federal awards.
• FAIN: Federal Awardee Identification Number - Synonym for ED’s PR Award Number. The FAIN is
a Federal-wide term used in FFATA reporting in FSRS and other reporting systems.

U.S. Department of Education 7
FFATA Reporting Requirements

eCFR :: 2 CFR Part 170 -- Reporting Subaward and Executive Compensation Information

• First-tier sub-award information and first-tier subaward executive compensation (if not
already entered in SAM.gov or self-reported by the subawardee to the SEC or IRS) must
be reported by the prime awardee in the FFATA Subaward Reporting System (FSRS.gov)
• FFATA sub-award reports are to be submitted by the end of the month following the
month in which the prime awardee awards any subaward equal to or greater than
$30,000.
• This requirement is for both mandatory and discretionary grants awarded on or after
October 1, 2010.

U.S. Department of Education 8
FFATA Reporting Requirements (continued…)
• If the initial award is below $30,000 but subsequent grant modifications result in a total award
equal to or over $30,000, the award will be subject to the reporting requirements, as of the date
the award exceeds $30,000.
• Example: Entity A received a $20,000 subaward in May 2022. On August 15, 2022, entity A
receives a supplemental $15,000. As the total award received by Entity A now exceeds the
reporting threshold, the Prime awardee would submit a $35,000 subaward made on August
15, 2022, in their September 2022 FFATA report.

• If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that
the total award amount falls below $30,000, the award continues to be subject to the reporting
requirements of the Transparency Act and this Guidance.
• Example: Entity B receives a $35,000 subaward in December 2022, so the Prime awardee
submits this in their January 2023 FFATA report. In February 2023, the Prime awardee
realizes that Entity B should have only received $25,000. The Prime awardee will then need
to edit their January 2023 report to change the subaward amount to $25,000. The Prime
awardee can add a comment in the subaward description to explain the change.

U.S. Department of Education 9
Key Terms
See Title 2 of the Federal Code of Regulations, Grants and Agreements Part 200 Subpart A for a more complete listing of acronyms and definitions.

ED Grantee: Non-Federal Entity that received an award from the U.S. Department of Education (grantee, grant recipient, prime
awardee, prime recipients are all synonyms)

Pass-through Entity: Non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.

Subaward: An award provided by a pass-through entity to a subrecipient to carry out part of a Federal award received by the
pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal
program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through
entity considers a contract. [See eCFR :: 2 CFR 200.331 -- Subrecipient and contractor determinations.]

Subrecipient: Entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry
out part of a Federal award but does not include an individual that is a beneficiary of such award. Subrecipients may also be
recipients of other Federal awards directly from a Federal awarding agency.

U.S. Department of Education 1
0
Common Reporting Challenges & Solutions

• When should subawards be reported? Subawards are required to be reported by
the end of the month following when the subaward was made/obligated. The
“Action Date” when reporting subawards in FSRS should match the date listed on
the subrecipient’s GAN.

• How should adjusted subaward amounts be reported? The correct process is to
reopen the submitted report containing the originally reported subaward and
process an Overwrite (batch upload or web services process) of the report to
update the data for that reporting period or manually correct the reopened
report to add in the adjusted subaward amount. (See FSRS FAQs for additional
information)

U.S. Department of Education 1
1
Common Reporting Challenges & Solutions (continued…)

• How is a Subrecipient Relationship determined? The SEA/pass-through entity
must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in
the role of a subrecipient or a contractor. Review eCFR :: 2 CFR 200.331 --
Subrecipient and contractor determinations.

• How can I resolve Zip+4 errors? When reporting subawards made to entities
without a “+4” it is recommended that those subawards be reported manually so
that the Congressional District Code can be reported. The FSRS Batch Upload
template currently does not include a field for the Congressional District Code.

U.S. Department of Education 1
2
Common Reporting Challenges & Solutions (continued…)

• How does the FSRS Batch Upload function work? See FSRS Grants Batch Upload
User Guide. Note: FSRS does not have system validations in place, so if duplicates
are present, the system will not flag this. Please ensure no over or duplicative
reporting is submitted.

• How can I access FFATA reports submitted by a former staff member? Submit a
FSD ticket to request that the past reports be migrated to your account. (See FSRS
FAQs for additional information)

U.S. Department of Education 1
3
Common Reporting Challenges & Solutions (continued…)

• Why are changes made to my reported data in FSRS not being reflected in
USAspending? When additional subaward data is reported in FSRS, USAspending is
automatically refreshed on a weekly basis to reflect newly reported FSRS data. If
FFATA reports were deleted from FSRS, however, it can take 30-60 days for
deletions to reflect in USAspending. Deletions require the FSRS Support Team/FSD
to include the specific, deleted FFATA report in a “Deletions Report” that the FSD
sends manually to the USAspending technical team on a monthly basis.
Considering this timeline, if you still do not see the changes reflected in
USAspending, please submit a FSD Incident/Ticket to confirm that your previously
deleted report was in fact included in FSRS’ “Deletions Report” to USAspending.

U.S. Department of Education 1
4
Common Reporting Challenges & Solutions (continued…)
• What should I report if my agency receives funds through the Governors' office via an
Interagency agreement? (GEER) If the Governor established an agreement (memorandum
of understanding (MOU), interagency agreement, etc.) with the State agency that
delegates authority to the State agency for the administration of the program, then the
awards made by the State agency will be treated as subawards and the Governor will need
to report them FSRS. If the Governor subawarded those funds to a State agency without an
agreement delegating authority to the State agency, then the Governor would treat the
State agency as the subrecipient and would not be required to report any further
subawards made by the State agency. Note: As the Governor was the prime grantee for
GEER, the Governor's Office would be responsible for submitting the FFATA reports. See
Question 1 of the https://api.covid-relief-
data.ed.gov/collection/api/v1/public/docs/ESSER-GEER-QA.pdf

• What should be reported for FFATA for the EANS program? See G-1 and G-2 of Final-EANS-
FAQ-Update-9.17.21.pdf (ed.gov). Note: Even though leftover EANS funds are “reverting”
to the Governor for allowable uses under GEER, the reverted funds remain EANS funds. As
such, any subawards made of $30,000 or more should be reported under the EANS Federal
Award Identification Number (FAIN).
U.S. Department of Education 1
5
Reporting Issue?

1. Alert your ED Program Officer—Email your State Mailbox [STATE].oese@ed.gov
(i.e. Alabama.oese@ed.gov)
2. For FSRS system issues contact the Federal Service Desk.
3. If you are provided with an Incident/Ticket Number, please share this with your
Program Officer via your State Mailbox
4. Document your challenges and efforts to fully comply
5. Verify that your subaward information displayed in USAspending is accurate
6. Work to resolve the issue(s) and submit your monthly report even if it will be past
due

U.S. Department of Education 1
6
Helpful Reminders

• Your Program Officer’s contact information can be found in section 3 of your
Grant Award Notification (GAN)
• Each month’s FFATA report should only contain subawards made within the
month prior. FFATA reports should not be cumulative.
• Negative subawards should not be reported to demonstrate a deobligation.
• When reporting a Zip+4, do not use hyphens.
• Subaward data displayed in USAspending is also displayed on the ESF
Transparency Portal. The Portal is refreshed on a monthly basis.
• If you have questions specific to USAspending, reach out to the USAspending help
desk by emailing usaspending.help@fiscal.treasury.gov

U.S. Department of Education 1
7
FFATA Resources
FSRS Provided Resources
1. FSRS FAQs (From the FSRS homepage, navigate to the FAQ tab)
2. FSRS Awardee Guide
3. Resources – FSRS
4. FSRS Awardee User Demonstration
5. GSA Federal Service Desk Service Portal
• Submit a FSD Incident/Ticket for technical assistance
• Search the FSD Knowledge Base
SGR Provided Resources
6. ESSER Reporting, GEER Reporting, & EANS Reporting
• FFATA Reporting Webinar & Forum (2/1/23)
• GSA’s FSRS Demonstration (4/28/23)
7. Department of Education Job Aid
8. Grants Training and Management Resources, Online Grants Training Courses (ed.gov) - Federal
Funding Accountability and Transparency Act FY22
9. Grant Award Notification (GAN) Attachment 9 U.S. Department of Education 1
8
Annual Performance Reporting
(APR)

19
APR Reporting:
Overview of Annual Performance Reporting

Data collection and reporting requirements under the COVID-relief
programs provide the public an understanding of how States,
including State educational agencies (SEAs), local educational
agencies (LEAs), institutions of higher education (IHEs), and other
education related entities are spending and planning to spend the
historic levels of emergency funding. The Office of State and
Grantee Relations (SGR) administers the ESSER, GEER, and EANS
programs and monitors grantees to ensure compliance with the
reporting requirements.

U.S. Department of Education 2
0
APR Reporting:
Overview of Annual Performance Reporting,
continued

ESSER Collection

• In general, SEAs report data on the State-level activities (SEA Reserve) and on
behalf of their LEAs, including data on the LEA set-aside to address learning
loss under ARP ESSER.
• Data generally offer information on four categories of fund use: meeting
students’ academic needs; ensuring operational continuity; supporting mental
health services; and addressing physical safety.
• Beginning with Year 4 of the ESSER programs (reporting period FY 2023 and
SY 2022-23), data collection will support more detailed information such as
information on the interventions used, and disaggregated student
participation data (See Appendix, ESSER Data Collection Form).

U.S. Department of Education 2
1
APR Reporting:
Overview of Annual Performance Reporting,
continued

GEER Collection

In general, Governors’ offices report data on the recipients of GEER funding
(LEAs, IHEs, other education related entities) and the uses of funds, including
planned uses of funds not expended during the collection year.

GEER Data Collection Form

U.S. Department of Education 2
2
APR Reporting:
Overview of Annual Performance Reporting,
continued

EANS Collection

In general, Governors’ offices are responsible for reporting data on the non-
public schools that received services or assistance under the EANS programs as
well as the types of services or assistance provided.

Note: Data on EANS funds that revert to the Governor’s Office for allowable uses
under GEER are reported through the EANS APR.

EANS Data Collection Form

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3
APR Reporting:
Timeline of Annual Performance Reporting

Six years total reporting

U.S. Department of Education 2
4
APR Reporting:
Timeline of Annual Performance Reporting, cont’d
Program Year 1 2 3 4 5 6

Reporting Period 3/2020 through 10/2020 through FY 2022 FY 2023 FY 2024 FY 2025
9/2020 End of State FY 2021

School Year SY 2019-20 (partial) SY 2020-21 SY 2021-22 SY 2022-23 SY 2023-24 SY 2024-25

Collection Period Winter 2021 Spring 2022 Spring 2023 Spring 2024 Spring 2025 Spring 2026

Data from Annual Published June 2021 Published Dec. 2022 Fall 2023 (est.) Fall 2024 (est.) Fall 2025 (est.) Fall 2026 (est.)
Reports Publicly
Available

ESSER I 1st annual report 2nd annual report 3rd annual report 4th annual report N.A. N.A.

ESSER II N.A. 1st annual report 2nd annual report 3rd annual report 4th annual report N.A.

ARP ESSER N.A. 1st annual report 2nd annual report 3rd annual report 4th annual report 5th annual report

States were offered the option to use their State fiscal year for reporting following Year 1.
U.S. Department of Education 2
5
APR Reporting:
Data Collection Process

• Coordination with the Office of the Chief Data Officer
(OCDO) and Contracted Staff
• Review of the Editor and Submitter Roles
o Note: Submitters may designate Editors
• Timing of the Collections (ESSER/GEER/EANS)
o Spring and staggered for the different programs
o Correction or Reopen period for isolated data
quality issues
• Communications to Grantees – what to expect

U.S. Department of Education 2
6
APR Reporting:
Data Collection Process, continued
The Grantee Help Page of the ESF Transparency Portal provides all
of the resources you need to successfully submit your annual
performance data.
• Instructions on obtaining accounts
• Recorded webinars
• UEI Fact Sheet
• FAQs on Reporting
• Data Collection Forms
• Reporting Templates
ESF - Help (ed.gov)
ESF - Help (ed.gov) ESSER Help Page
ESF - Help (ed.gov) GEER Help Page
ESF - Help (ed.gov) EANS Help Page U.S. Department of Education 2
7
APR Reporting:
Tips for Successful Reporting

• Review Data Collection Forms prior to gathering/collecting data
from subgrantees
• Plan to attend reporting webinars or review the recordings
• Start early with collecting data from subgrantees and checking
for validity
o Review data for logical consistency and accuracy
o Ensure all subgrantees have Unique Entity IDs (UEIs)

ESF - Help (ed.gov)

U.S. Department of Education 2
8
APR Reporting:
Tips for Successful Reporting, continued
• Use the Template Upload Tool
o Completed reporting Templates can be checked for
business rule compliance
• Review reporting resources available on the Grantee Help Page
• Review prior year data submitted during reporting to check for
accuracy
• Current year reporting will include questions on prior reporting
periods’ expenditures
• Previously reported data are available for review once logged
into the reporting system

ESF - Help (ed.gov)
U.S. Department of Education 2
9
QUESTIONS

30
Thank You

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