[Busmgrs] ARRA Reporting Follow-up for 2008-09 4th Qtr SFSF

[WILTFONG Michael]

Good afternoon everyone:

The ARRA reporting collection for the fourth quarter of 2008-09 just closed and ODE staff have had some time to review the preliminary results. First, I would like to thank everyone for your hard work in completing the report. Considering we have not had much time with this new collection, the preliminary results are promising. However, we do have some concerns that I'd like to address in an attempt to improve upon the next round of ARRA reporting for the cumulative period through the first quarter of 2009-10, which is set to close September 30, 2009.

Because the reporting is cumulative, it is very important we all have a consistent understanding of terminology and requirements from this point forward. Now that we have one round of reporting complete, I would strongly encourage everyone to revisit the ARRA reporting FAQs sent out to the business managers and superintendents on 9/15/2009. I believe taking the time to review the FAQs will save a lot of time and will prevent misunderstandings in the long term. The link to the FAQs on ODE's K-12 stimulus website is: http://stimulus.k12partners.org/sites/stimulus.k12partners.org/files/FAQsAboutARRAReporting9-14-09.doc

As I said before, we have some concerns about a few items. We will not be asking you to correct errors in your 6/30 submission, but it is important that you make necessary corrections to the data because you will be incorporating them into your 9/30 submission due to the cumulative nature of the reporting. Before you complete your data collection for the period ending September 30, please carefully read the highlighted list below:

1.      Use of the Vendor field: For those of you that identified vendors in your data collection, please review the definition of a vendor under section 5 in the FAQs to ensure you're using this field correctly.  Typically, teachers are not vendors.  Listing the school district as a vendor for the entire amount of your grant is also not a correct interpretation of "vendor."

2.      Use of the Infrastructure field: For those of you that entered data and narratives in the Infrastructure field, please review section 4 of the FAQs to ensure you are using this field correctly.  Salaries and benefits are not infrastructure for purposes of this collection.

3.      Use of funds: There were a number of districts that submitted questionable items in the narratives in the 2008-09 4th quarter collection. I would ask that you review the list below, which was copied from the SFSF application districts submitted in May, and ensure what you have identified in your narratives aligns in some manner with the list below.

In its application, each district assures it has used or will use funds consistent with the intent and overall goals of ARRA: to create and save jobs and to advance education reforms set forth in ARRA.  These reform goals are to:

*       Increase teacher effectiveness and address inequities in the distribution of highly qualified teachers;
*       Establish and use a pre-K-through-college and career data system to track progress and foster continuous improvement;
*       Make progress towards rigorous college-and-career-ready standards and high-quality assessments that are valid and reliable for all students, including limited English proficient students and students with disabilities;
*       Provide targeted, intensive support and effective interventions to turn around schools identified for corrective action and restructuring; and
*       Improving results for all students, including early learning, extended learning time, use of technology, preparation for college and school modernization.

Funds may be used to pay salaries to avoid layoffs of teachers and other school employees.

Funds may not be used for:

*       Payment of maintenance costs;
*       Stadiums or other facilities primarily used for athletic contests or exhibitions or other events for which admission is charged to the general public;
*       Purchase or upgrade of vehicles;
*       Improvement of stand-alone facilities whose purpose is not the education of children; or
*       School modernization, renovation, or repair that is inconsistent with State law;
*       Restoration or supplementation of a "rainy day" fund; and
*       Other items as noted in the grant application documents.  See http://stimulus.k12partners.org/sites/stimulus.k12partners.org/files/581-1459-A%20ARRA%20Application(2).doc

For example, lawn maintenance is not an allowable use of the SFSF grant.

4.      Several districts indicated they had nothing to report.  For purposes of the ODE's Recovery Act Reporting Collection, you may not have information to report on jobs or infrastructure (e.g., you used your SFSF grants to purchase textbooks or other supplies).

However, if you received grant funds, you must have documentation to support how you used the funds.  Please remember the SFSF grant is made on a reimbursement basis - similar to IDEA, Title 1, and other federal grants. The SFSF monies are to reimburse expenditures that align with the core reforms identified in the ARRA SFSF application.

As we've communicated to you earlier, we want to stress that all ARRA funds are subject to a high degree of accountability and transparency.  We've been assured they will be a focus of upcoming federal and state audits.  Reporting is mandatory under federal law and there are no provisions at this time to waive reporting requirements.

I strongly encourage everyone to make sure your strategies for the use of these federal stimulus funds are well planned. If you have questions, please consult the appropriate Grant Manager. Thank you.



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