Recovery Act

Recipient Reported Jobs Data Provide Some Insight into Use of Recovery Act Funding, but Data Quality and Reporting Issues Need Attention Gao ID: GAO-10-223 November 19, 2009

The American Recovery and Reinvestment Act of 2009 (Recovery Act) requires recipients of funding from federal agencies to report quarterly on jobs created or retained with Recovery Act funding. The first recipient reports filed in October 2009 cover activity from February through September 30, 2009. GAO is required to comment on the jobs created or retained as reported by recipients. This report addresses (1) the extent to which recipients were able to fulfill their reporting requirements and the processes in place to help ensure data quality and (2) how macroeconomic data and methods, and the recipient reports, can be used to assess the employment effects of the Recovery Act. GAO performed an initial set of basic analyses on the final recipient report data that first became available at www.recovery.gov on October 30, 2009; reviewed documents; interviewed relevant state and federal officials; and conducted fieldwork in selected states, focusing on a sample of highway and education projects.

On October 30, www.recovery.gov (the federal Web site on Recovery Act spending) reported that more than 100,000 recipients reported hundreds of thousands of jobs created or retained. Given the national scale of the recipient reporting exercise and the limited time frames in which it was implemented, the ability of the reporting mechanism to handle the volume of data from a wide variety of recipients represents a solid first step in moving toward more transparency and accountability for federal funds. Because this effort will be an ongoing process of cumulative reporting, GAO's first review represents a snapshot in time. While recipients GAO contacted appear to have made good faith efforts to ensure complete and accurate reporting, GAO's fieldwork and initial review and analysis of recipient data from www.recovery.gov, indicate that there are a range of significant reporting and quality issues that need to be addressed For example, GAO's review of prime recipient reports identified the following: Erroneous or questionable data entries that merit further review: (1) 3,978 reports that showed no dollar amount received or expended but included more than 50,000 jobs created or retained; (2) 9,247 reports that showed no jobs but included expended amounts approaching $1 billion, and (3) Instances of other reporting anomalies such as discrepancies between award amounts and the amounts reported as received which, although relatively small in number, indicate problematic issues in the reporting. Coverage: While OMB estimates that more than 90 percent of recipients reported, questions remain about the other 10 percent. Quality review: While less than 1 percent were marked as having undergone review by the prime recipient, over three quarters of the prime reports were marked as having undergone review by a federal agency. Full-time equivalent (FTE) calculations: Full-time equivalent (FTE) calculations: Under OMB guidance, jobs created or retained were to be expressed as FTEs. GAO found that data were reported inconsistently even though significant guidance and training was provided by OMB and federal agencies. While FTEs should allow for the aggregation of different types of jobs--part time, full time or temporary--differing interpretations of the FTE guidance compromise the ability to aggregate the data. Although there were problems of inconsistent interpretation of the guidance, the reporting process went relatively well for highway projects. Transportation had an established procedure for reporting prior to enactment of the Recovery Act. In the cases of Education and Housing, which do not have this prior reporting experience, GAO found more problems. Some of these have been reported in the press. State and federal officials are examining these problems and have stated their intention to deal with them.

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GAO-10-223, Recovery Act: Recipient Reported Jobs Data Provide Some Insight into Use of Recovery Act Funding, but Data Quality and Reporting Issues Need Attention This is the accessible text file for GAO report number GAO-10-223 entitled 'Recovery Act: Recipient Reported Jobs Data Provide Some Insight into Use of Recovery Act Funding, but Data Quality and Reporting Issues Need Attention' which was released on November 19, 2009. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Report to the Congress: United States Government Accountability Office: GAO: November 2009: Recovery Act: Recipient Reported Jobs Data Provide Some Insight into Use of Recovery Act Funding, but Data Quality and Reporting Issues Need Attention: GAO-10-223: GAO Highlights: Highlights of GAO-10-223, a report to the Congress. Why GAO Did This Study: The American Recovery and Reinvestment Act of 2009 (Recovery Act) requires recipients of funding from federal agencies to report quarterly on jobs created or retained with Recovery Act funding. The first recipient reports filed in October 2009 cover activity from February through September 30, 2009. GAO is required to comment on the jobs created or retained as reported by recipients. This report addresses (1) the extent to which recipients were able to fulfill their reporting requirements and the processes in place to help ensure data quality and (2) how macroeconomic data and methods, and the recipient reports, can be used to assess the employment effects of the Recovery Act. GAO performed an initial set of basic analyses on the final recipient report data that first became available at [hyperlink, http://www.recovery.gov] on October 30, 2009; reviewed documents; interviewed relevant state and federal officials; and conducted fieldwork in selected states, focusing on a sample of highway and education projects. What GAO Found: As of September 30, 2009, approximately $173 billion of the $787 billion”or about 22 percent”of the total funds provided by the Recovery Act had been paid out by the federal government. Nonfederal recipients of Recovery Act-funded grants, contracts, and loans are required to submit reports with information on each project or activity, including the amount and use of funds and an estimate of jobs created or retained. Of the $173 billion in funds paid out, about $47 billion”a little more than 25 percent”is covered by this recipient report requirement. Neither individuals nor recipients receiving funds through entitlement programs, such as Medicaid, or through tax programs are required to report. In addition, the required reports cover direct jobs created or retained as a result of Recovery Act funding; they do not include the employment impact on materials suppliers (indirect jobs) or on the local community (induced jobs). (See figure.) Figure: Fiscal Year 2009 Recovery Act Funds Paid Out and Recipient Reporting Coverage: [Refer to PDF for image: pie-chart and illustration] Recovery Act funds paid out, end of fiscal year 2009 (in billions): Entitlements: $63.7; Tax relief: $62.5; Contracts, grants, and loans: $47; Total: $173. Potential employment effects of Recovery Act contracts, grants and loans: Contracts, grants, and loans: Recipient reporting coverage: Direct. [End of figure] On October 30, www.recovery.gov (the federal Web site on Recovery Act spending) reported that more than 100,000 recipients reported hundreds of thousands of jobs created or retained. Given the national scale of the recipient reporting exercise and the limited time frames in which it was implemented, the ability of the reporting mechanism to handle the volume of data from a wide variety of recipients represents a solid first step in moving toward more transparency and accountability for federal funds. Because this effort will be an ongoing process of cumulative reporting, GAO‘s first review represents a snapshot in time. Data Reporting and Quality: While recipients GAO contacted appear to have made good faith efforts to ensure complete and accurate reporting, GAO‘s fieldwork and initial review and analysis of recipient data from www.recovery.gov, indicate that there are a range of significant reporting and quality issues that need to be addressed. For example, GAO‘s review of prime recipient reports identified the following: Erroneous or questionable data entries that merit further review: * 3,978 reports that showed no dollar amount received or expended but included more than 50,000 jobs created or retained; * 9,247 reports that showed no jobs but included expended amounts approaching $1 billion, and; * Instances of other reporting anomalies such as discrepancies between award amounts and the amounts reported as received which, although relatively small in number, indicate problematic issues in the reporting. Coverage: While OMB estimates that more than 90 percent of recipients reported, questions remain about the other 10 percent. Quality review: While less than 1 percent were marked as having undergone review by the prime recipient, over three quarters of the prime reports were marked as having undergone review by a federal agency. Full-time equivalent (FTE) calculations: Under OMB guidance, jobs created or retained were to be expressed as FTEs. GAO found that data were reported inconsistently even though significant guidance and training was provided by OMB and federal agencies. While FTEs should allow for the aggregation of different types of jobs”part time, full time or temporary”differing interpretations of the FTE guidance compromise the ability to aggregate the data. To illustrate, in California, two higher education systems calculated FTE differently. In the case of one, officials chose to use a 2-month period as the basis for the FTE performance period. The other chose to use a year as the basis for the FTE. The result is almost a three-to- one difference in the number of FTEs reported for each university system in the first reporting period. Although the Department of Education provides alternative methods for calculating an FTE, in neither case does the guidance explicitly state the period of performance of the FTE. Although there were problems of inconsistent interpretation of the guidance, the reporting process went relatively well for highway projects. Transportation had an established procedure for reporting prior to enactment of the Recovery Act. In the cases of Education and Housing, which do not have this prior reporting experience, GAO found more problems. Some of these have been reported in the press. State and federal officials are examining these problems and have stated their intention to deal with them. GAO will continue to monitor and review the data reporting and quality issues in its bimonthly reviews and fieldwork on the use of funds in the 16 states and the District of Columbia, and in GAO‘s analysis of future quarterly recipient reporting. Recommendations for Executive Action: To improve the consistency of FTE data collection and reporting, OMB should (1) clarify the definition and standardize the period of measurement for FTEs and work with federal agencies to align this guidance with OMB‘s guidance and across agencies; (2) given its reporting approach, consider being more explicit that ’jobs created or retained“ are to be reported as hours worked and paid for with Recovery Act funds; and (3) continue working with federal agencies and encourage them to provide or improve program-specific guidance to assist recipients, especially as it applies to the full-time equivalent calculation for individual programs. OMB should also work with the Recovery Accountability and Transparency Board and federal agencies to re-examine review and quality assurance processes, procedures, and requirements in light of experiences and identified issues with this round of recipient reporting and consider whether additional modifications need to be made and if additional guidance is warranted. Employment Effects: Even if the data quality issues are resolved, it is important to recognize that the FTEs in recipient reports alone do not reflect the total employment effects of the Recovery Act. As noted, these reports solely reflect direct employment arising from the expenditure of less than one-third of Recovery Act funds. Therefore, both the data reported by recipients and other macroeconomic data and methods are necessary to gauge the overall employment effects of the stimulus. The Recovery Act includes entitlements and tax provisions, which also have employment effects. The employment effects in any state will vary with labor market stress and fiscal condition, as discussed in this report. What GAO Recommends: GAO is recommending steps OMB should take in continuing to work with federal agencies to increase recipients‘ understanding of the reporting requirements and guidance. OMB staff generally agreed with our recommendations. View [hyperlink, http://www.gao.gov/products/GAO-10-223] or key components. For more information, contact J. Christopher Mihm at (202) 512-6806 or mihmj@gao.gov. [End of section] Contents: Letter: Background: Recipients of Recovery Act Funds We Contacted Appear to Have Made Good Faith Efforts to Ensure Complete and Accurate Reporting, but It Will Take Time to Improve Data Quality: Recommendations for Executive Action: Despite Limitations, Economic Methods and Recipient Reports Together Can Provide Insight into the Employment Effects of Fiscal Stimulus: Agency Comments: Appendix I: Calculating Full-Time Equivalent Data--Examples of Guidance and Challenges: Appendix II: Department of Education Calculations to Determine Full- Time Equivalents (FTE) for Jobs Created or Retained: Appendix III: GAO Contacts and Staff Acknowledgments: Tables: Table 1: Jobs Created or Retained by States as Reported by Recipients of Recovery Act Funding: Table 2: Jobs Created or Retained by Federal Program Agency as Reported by Recipients of Recovery Act Funding: Table 3: Count of Prime Recipient Reports by Presence or Absence of FTEs and Recovery Act Funds Received or Expended: Table 4: Aggregation of FHWA FTE Data: Table 5: OMB's Cumulative FTE versus a Standardized Measure: Table 6: Prime Recipient Reports Reviews and Corrections: Table 7: Estimated Multipliers for Recovery Act Spending and Tax Expenditures: Table 8: State Unemployment Rates, Peak and Most Recent: Table 9: Change in Employment, December 2007 to September 2009: Table 10: Derivation of Number of Hours Created or Retained: Figures: Figure 1: The Potential Employment Effects of Recovery Act Funds: Figure 2: Recipient Reporting Time Frame: Figure 3: Distribution of Recovery Act Funds through the End of Fiscal Year 2009: Figure 4: FHWA's Recipient Reporting Data Structure: Figure 5: Composition of Recovery Act Outlays by Jobs Multiplier Category: Figure 6: State Unemployment Rates, September 2009: Figure 7: State Unemployment Rate Growth during Recession (Percent Increase): Figure 8: State and Local Tax Receipts: Figure 9: Total Year-End Balances as a Percentage of Expenditures, Fiscal Year 2009: Abbreviations: CBO: Congressional Budget Office: CCR: Central Contractor Registration: CEA: Council of Economic Advisers: CFDA: Catalog of Federal Domestic Assistance: CIO: chief information officer: DOT: Department of Transportation: EBO: Equitable Business Opportunities: Education: Department of Education: FDOT: Florida Department of Transportation: FHWA: Federal Highway Administration: FRPIN: Federal Reporting Personal Identification Number: FTE: full-time equivalent: GDOT: Georgia Department of Transportation: GDP: gross domestic product: HHS: Department of Health and Human Services: HUD: Department of Housing and Urban Development: IG: inspector general: LEA: local education agency: OIG: Office of Inspector General: OMB: Office of Management and Budget: RADS: Recovery Act Data System: RAMPS: Recovery Act Management and Performance System: Recovery Act: American Recovery and Reinvestment Act of 2009: Recovery Board: Recovery Accountability and Transparency Board: SEA: state education agency: SFSF: State Fiscal Stabilization Fund: TAS: Treasury Account Symbol: [End of section] United States Government Accountability Office: Washington, DC 20548: November 19, 2009: Report to the Congress: Congress and the new administration crafted the American Recovery and Reinvestment Act of 2009 (Recovery Act)[Footnote 1] with the broad purpose of stimulating the economy. One of the express purposes of the act was to preserve and create jobs. To help measure the progress of this effort, Congress and the administration built into the act numerous provisions to increase transparency and accountability over spending that require recipients of Recovery Act funding to report quarterly on a number of measures. Nonfederal recipients of Recovery Act funded grants, contracts, or loans are required to submit reports with information on each project or activity, including the amount and use of funds and an estimate of the jobs created or retained.[Footnote 2] Neither individuals nor recipients receiving funds through entitlement programs, such as Medicaid, or tax programs are required to report. The first of these recipient reports cover cumulative activity since the Recovery Act's passage in February 2009 through the quarter ending September 30, 2009. The Recovery Act requires GAO to comment on the estimates of jobs created or retained in the recipient reports no later than 45 days after recipients have reported.[Footnote 3] The final recipient reporting data for the first round of reports were first made available on October 30, 2009. The transparency that is envisioned for tracking Recovery Act spending and results is unprecedented for the federal government. Both Congress and the President have emphasized the need for accountability, efficiency, and transparency in the expenditure of Recovery Act funds and have made it a central principle of the act. As Congress finished work on the Recovery Act, the House Appropriations Committee released a statement saying, "A historic level of transparency, oversight and accountability will help guarantee taxpayer dollars are spent wisely and Americans can see results for their investment." In January, the new administration pledged that the Recovery Act would "break from conventional Washington approaches to spending by ensuring that public dollars are invested effectively and that the economic recovery package is fully transparent and accountable to the American people." However, tracking billions of dollars that are being disbursed to thousands of recipients is an enormous effort. The administration expects that achieving this degree of visibility will be an iterative process in which the reporting process and information improve over time and, if successful, could be a model for transparency and oversight beyond the Recovery Act. This report, the first in response to the Recovery Act's section 1512 mandate that GAO comment on the estimates of jobs created or retained by direct recipients of Recovery Act funds, addresses the following: (1) the extent to which recipients were able to fulfill their reporting requirements and the processes in place to help ensure recipient reporting data quality and (2) how macroeconomic data and methods, and the recipient reports, can be used to assess the employment effects of the Recovery Act, and the limitations of the data and methods. To meet our objectives, we performed an initial set of edit checks and basic analyses on the final recipient report data that first became available at www.recovery.gov, the federal government's official Web site on Recovery Act spending, on October 30, 2009. We calculated the overall sum, as well as sum by states, for the number of full-time equivalents (FTE) reported, award amount, and amount received and found that they corresponded closely with the values shown for these data on Recovery.gov. We built on information collected at the state, local, and program level as part of our bimonthly reviews of selected states' and localities' uses of Recovery Act funds. These bimonthly reviews focus on Recovery Act implementation in 16 states and the District of Columbia, which contain about 65 percent of the U.S. population and are estimated to receive collectively about two-thirds of the intergovernmental federal assistance funds available through the Recovery Act. A detailed description of the criteria used to select the core group of 16 states and the District is found in appendix I of our April 2009 Recovery Act bimonthly report[Footnote 4]. Prime recipients and delegated subrecipients[Footnote 5] had to prepare and enter their information by October 10, 2009. The days following up to October 30, 2009, included the data review period, and as noted previously, on October 30, 2009, the first round of recipient reported data was made public. Over the course of three different interviews, two with prime recipients of Recovery Act funding and one with subrecipients, we visited the 16 selected states and the District of Columbia during late September and October 2009. We discussed with prime recipients projects associated with 50 percent of the total funds reimbursed, as of September 4, 2009, for that state, in the Federal-Aid Highway Program administered by the Department of Transportation (DOT). Prior to the start of the reporting period on October 1, we reviewed prime recipients' plans for the jobs data collection process. After the October 10 data reporting period, we went back to see if prime recipients followed their own plans and subsequently talked with at least two vendors in each state to gauge their reactions to the reporting process and assess the documentation they were required to submit. We gathered and examined issues raised by recipients in these jurisdictions regarding reporting and data quality and interviewed recipients on their experiences using the Web site reporting mechanism. During the interviews, we used a series of program reviews and semistructured interview guides that addressed state plans for managing, tracking, and reporting on Recovery Act funds and activities. In a similar way, we examined a nonjudgmental sample of Department of Education (Education) Recovery Act projects at the prime and subrecipient level. We also collected information from transit agencies as part of our bimonthly Recovery Act reviews. In addition, we interviewed federal agency officials who have responsibility for ensuring a reasonable degree of quality across their program's recipient reports. We assessed the reports from the Inspector Generals (IG) on Recovery Act data quality review from 15 agencies. We are also continuing to monitor and follow up on some of the major reporting issues identified in the media and by other observers. For example, a number of press articles have discussed concerns with the jobs reporting done by Head Start grantees. According to a Health and Human Services (HHS) Recovery Act official, HHS is working with the Office of Management and Budget (OMB) to clarify the reporting policy as it applies to Head Start grantees. We will be reviewing these efforts as they move forward. To address our second objective, we analyzed economic and fiscal data using standard economic principles and reviewed the economic literature on the effect of monetary and fiscal policies for stimulating the economy. We also reviewed guidance that OMB developed for Recovery Act recipients to follow in estimating the effect of funding activities on employment, reviewed reports that the Council of Economic Advisers (CEA) issued on the macroeconomic effects of the Recovery Act, and interviewed officials from the CEA, OMB, and the Congressional Budget Office (CBO). We conducted this performance audit with field work beginning in late September 2009 and began analysis of the recipient data that became available on October 30, 2009, in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Background: In December 2007, the United States entered what has turned out to be its deepest recession since the end of World War II. Between the fourth quarter of 2007 and the third quarter of 2009, gross domestic product (GDP) fell by about 2.8 percent, or $377 billion. The unemployment rate rose from 4.9 percent in 2007 to 10.2 percent in October 2009, a level not seen since April 1983. The CBO projects that the unemployment rate will remain above 9 percent through 2011. Confronted with unprecedented weakness in the financial sector and the overall economy, the federal government and the Federal Reserve together acted to moderate the downturn and restore economic growth. The Federal Reserve used monetary policy to respond to the recession by pursuing one of the most significant interest rate reductions in U.S. history. In concert with the Department of the Treasury, it went on to bolster the supply of credit in the economy through measures that provide Federal Reserve backing for a wide variety of loan types, from mortgages to automobile loans to small business loans. The federal government also used fiscal policy to confront the effects of the recession. Existing fiscal stabilizers, such as unemployment insurance and progressive aspects of the tax code, kicked in automatically in order to ease the pressure on household income as economic conditions deteriorated. In addition, Congress enacted a temporary tax cut in the first half of 2008 to buoy incomes and spending[Footnote 6] and created the Troubled Asset Relief Program[Footnote 7] in the second half of 2008 to give Treasury authority to act to restore financial market functioning.[Footnote 8] The federal government's largest response to the recession to date came in early 2009 with the passage of the Recovery Act, the broad purpose of which is to stimulate the economy's overall demand for goods and services, or aggregate demand. The Recovery Act is specifically intended to preserve and create jobs and promote economic recovery; to assist those most impacted by the recession; to provide investments needed to increase economic efficiency by spurring technological advances in health and science; to invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits; and to stabilize the budgets of state and local governments.[Footnote 9] The CBO estimates that the net cost of the Recovery Act will total approximately $787 billion from 2009 to 2019. The Recovery Act uses a combination of tax relief and government spending to accomplish its goals. The Recovery Act's tax cuts include reductions to individuals' taxes, payments to individuals in lieu of reductions to their taxes, adjustments to the Alternative Minimum Tax, and business tax incentives. Tax cuts encompass approximately one-third of the Recovery Act's dollars. Recovery Act spending includes temporary increases in entitlement programs to aid people directly affected by the recession and provide some fiscal relief to states; this also accounts for about one third of the Recovery Act. For example, the Recovery Act temporarily increased and extended unemployment benefits, temporarily increased the rate at which the federal government matched states Medicaid expenditures, and provided additional funds for the Supplemental Nutrition Assistance and the Temporary Aid to Needy Families programs, among other things. Other spending, also accounting for about a third of the act falls into the category of grants, loans, and contracts. This includes government purchases of goods and services, grants to states through programs such as the State Fiscal Stabilization Fund for education and other government services, and government investment in infrastructure, health information technology, renewable energy research, and other areas. In interpreting recipient reporting data, it is important to recognize that the recipient reporting requirement only covers a defined subset of the Recovery Act's funding. The reporting requirements apply only to nonfederal recipients of funding, including all entities receiving Recovery Act funds directly from the federal government such as state and local governments, private companies, educational institutions, nonprofits, and other private organizations. OMB guidance, consistent with the statutory language in the Recovery Act, states that these reporting requirements apply to recipients who receive funding through the Recovery Act's discretionary appropriations, not recipients receiving funds through entitlement programs, such as Medicaid, or tax programs. Recipient reporting also does not apply to individuals. In addition, the required reports cover only direct jobs created or retained as a result of Recovery Act funding; they do not include the employment impact on materials suppliers (indirect jobs) or on the local community (induced jobs). Figure 1 shows the division of total Recovery Act funds and their potential employment effects. Figure 1: The Potential Employment Effects of Recovery Act Funds: [Refer to PDF for image: pie-chart and illustration] Total Recovery Act funds (in billions): Entitlements: $224; Tax relief: $288; Contracts, grants, and loans: $275; Total: $787. Potential employment effects of Recovery Act contracts, grants and loans: Contracts, grants, and loans (concentric circles): Indirect (small circle): Tax relief employment effect; Indirect (large circle): Entitlements employment effect; Direct (smallest circle): Recipient reporting coverage. Source: GAO. Note: The potential employment effects of the different types of Recovery Act funds are based on historical data and are reflected in the size of the circles. [End of figure] Tracing the effects of the Recovery Act through the economy is a complicated task. Prospectively, before the act's passage or before funds are spent, the effects can only be projected using economic models that represent the behavior of governments, firms, and households. While funds are being spent, some effects can be observed but often relevant data on key relationships and indicators in the economy are available only with a lag, thereby complicating real-time assessments. When a full range of data on outcomes becomes available, economic analysts undertake retrospective analyses, where the findings are often used to guide future policy choices and to anticipate effects of similar future policies. Stimulus spending under the broad scope of the Recovery Act will reverberate at the national, regional, state, and local levels. Models of the national economy provide the most comprehensive view of policy effects, but they do not provide insight, except indirectly, about events at smaller geographical scales. The diversity and complexity of the components of the national economy are not fully captured by any set of existing economic models. Some perspective can be gained by contemporaneous close observation of the actions of governments, firms, and households, but a complete and accurate picture of the Recovery Act's impact will emerge only slowly. Section 1512 of the Recovery Act requires recipients of recovery funds to report on those funds each calendar quarter. These recipient reports are to be filed for any quarter in which a recipient receives Recovery Act funds directly from the federal government. The recipient reporting requirement covers all funds made available by appropriations in division A of the Recovery Act. The reports are to be submitted no later than 10 days after the end of each calendar quarter in which the recipient received Recovery Act funds. Each report is to include the total amount of Recovery Act funds received, the amount of funds expended or obligated to projects or activities, and a detailed list of those projects or activities. For each project or activity, the detailed list must include its name and a description, an evaluation of its completion status, and an estimate of the number of jobs created or the number of jobs retained by that project or activity. Certain additional information is also required for infrastructure investments made by state and local governments. Also, the recipient reports must include detailed information on any subcontracts or subgrants as required by the Federal Funding Accountability and Transparency Act of 2006.[Footnote 10] Section 1512(e) of the Recovery Act requires GAO and CBO to comment on the estimates of jobs created or retained reported by recipients. In its guidance to recipients for estimating employment effects, OMB instructed recipients to report only the direct employment effects as "jobs created or retained" as a single number.[Footnote 11] Recipients are not expected to report on the employment impact on materials suppliers (indirect jobs) or on the local community (induced jobs). According to the guidance, "A job created is a new position created and filled or an existing unfilled position that is filled as a result of the Recovery Act; a job retained is an existing position that would not have been continued to be filled were it not for Recovery Act funding. Only compensated employment... should be reported. The estimate of the number of jobs... should be expressed as 'full-time equivalents (FTE),' which is calculated as total hours worked in jobs created or retained divided by the number of hours in a full-time schedule, as defined by the recipient." Consequently, the recipients are expected to report the amount of labor hired or not fired as result of having received Recovery Act funds. It should be noted that one FTE does not necessarily equate to the job of one person. Firms may choose to increase the hours of existing employees, for example, which can certainly be said to increase employment but not necessarily be an additional job in the sense of adding a person to the payroll. To implement the recipient reporting data requirements, OMB has worked with the Recovery Accountability and Transparency Board (Recovery Board)[Footnote 12] to deploy a nationwide data collection system at [hyperlink, http://www.federalreporting.gov] (Federalreporting.gov), while the data reported by recipients are available to the public for viewing and downloading on [hyperlink, http://www.recovery.gov (Recovery.gov). Recovery.gov, a site designed to provide transparency of information related to spending on Recovery Act programs, is the official source of information related to the Recovery Act. The Recovery Board's goals for the Recovery Act Web site include promoting accountability by providing a platform to analyze Recovery Act data and serving as a means of tracking fraud, waste, and abuse allegations by providing the public with accurate, user-friendly information. In addition, the site promotes official data in public debate, assists in providing fair and open access to Recovery Act opportunities, and promotes an understanding of the local impact of Recovery Act funding. In an effort to address the level of risk in recipient reporting, OMB's June 22, 2009, guidance[Footnote 13] on recipient reporting includes a requirement for data quality reviews. OMB's data quality guidance is intended to address two key data problems--material omissions and significant reporting errors. Material omissions and significant reporting errors are risks that the information is incomplete and inaccurate.[Footnote 14] As shown in figure 2, OMB gave specific time frames for reporting that allow prime recipients and delegated subrecipients to prepare and enter their information on days 1 through 10 following the end of the quarter. During days 11 through 21, prime recipients will be able to review the data to ensure that complete and accurate reporting information is provided prior to a federal agency review and comment period beginning on the 22nd day. During days 22 to 29 following the end of the quarter, federal agencies will perform data quality reviews and will notify the recipients and delegated subrecipients of any data anomalies or questions. The original submitter must complete data corrections no later than the 29th day following the end of the quarter. Prime recipients have the ultimate responsibility for data quality checks and the final submission of the data. Since this is a cumulative reporting process, additional corrections can take place on a quarterly basis. Figure 2: Recipient Reporting Time Frame: [Refer to PDF for image: illustration] No less than 35 days prior to the end of the quarter: * Prime and subrecipient registration. 1-10 days after end of quarter (Recipient report adjustments possible): * Prime recipients and delegated subrecipients enter draft reporting data; * Initial submission. 11-21 days after end of quarter (Recipient report adjustments possible) (Agency "view only"): * Prime recipients review data submitted by subrecipients; * Prime recipients and subrecipients make corrections. 22-29 days after end of quarter (Recipient report adjustments possible) (Agency comment period): * Agency review of data submitted; * Prime recipients and subrecipients make corrections. 30 days after end of quarter: * Recipients reports published on Recovery.gov. 90 days after end of quarter: * Next quarterly reporting cycle begins”updates reflected cumulatively. Source: OMB. [End of figure] OMB guidance does not explicitly mandate a methodology for conducting data quality reviews at the prime and delegated subrecipient level or by the federal agencies. Instead, the June 22, 2009, guidance provides the relevant party conducting the data quality review with discretion in determining the optimal method for detecting and correcting material omissions or significant reporting errors. The guidance says that, at a minimum, federal agencies, recipients, and subrecipients should establish internal controls to ensure data quality, completeness, accuracy, and timely reporting of all amounts funded by the Recovery Act. The Recovery Board published the results of the first round of recipient reporting on Recovery.gov on October 30, 2009. According to the Web site, recipients submitted 130,362 reports indicating that 640,329 "jobs" were created or saved as a direct result of the Recovery Act. These data solely reflect the direct FTEs reported by recipients of Recovery Act grants, contracts, and loans for the period beginning when the act was signed into law on February 17, 2009 through September 30, 2009. As shown in figure 3, grants, contracts, and loans account for about 27 percent, or $47 billion, of the approximately $173 billion in Recovery Act funds paid out as of September 30, 2009. Figure 3: Distribution of Recovery Act Funds through the End of Fiscal Year 2009: [Refer to PDF for image: pie-chart] Entitlements ($63.7 billion): 37%; Tax relief ($62.5 billion): 36%; Contracts, grants, and loans ($47 billion): 27%; Total: $173 billion. Source: Recovery.gov. [End of figure] Recipients in all 50 states reported jobs created or retained with Recovery Act funding provided through a wide range of federal programs and agencies. Table 1 shows the distribution of jobs created or retained across the nation as reported by recipients on Recovery.gov. Not surprisingly, California, the most populous state, received the most Recovery Act dollars and accounted for the largest number of the reported jobs created or retained. Table 1: Jobs Created or Retained by States as Reported by Recipients of Recovery Act Funding: Rank: 1; State: California; Jobs: 110,185. Rank: 2; State: New York; Jobs: 40,620v Rank: 3; State: Washington; Jobs: 34,517. Rank: 4; State: Florida; Jobs: 29,321v Rank: 5; State: North Carolina; Jobs: 28,073. Rank: 6; State: Georgia; Jobs: 24,681. Rank: 7; State: Illinois; Jobs: 24,448. Rank: 8; State: New Jersey; Jobs: 24,109. Rank: 9; State: Michigan; Jobs: 22,514. Rank: 10; State: Texas; Jobs: 19,572. Rank: 11; State: Indiana; Jobs: 18,876. Rank: 12; State: Puerto Rico; Jobs: 17,597. Rank: 13; State: Ohio; Jobs: 17,095. Rank: 14; State: Missouri; Jobs: 15,149. Rank: 15; State: Minnesota; Jobs: 14,315. Rank: 16; State: Massachusetts; Jobs: 12,374. Rank: 17; State: Arizona; Jobs: 12,283. Rank: 18; State: Wisconsin; Jobs: 10,073. Rank: 19; State: Oregon; Jobs: 9,653. Rank: 20; State: Tennessee; Jobs: 9,548. Rank: 21; State: Louisiana; Jobs: 9,136. Rank: 22; State: Oklahoma; Jobs: 8,747. Rank: 23; State: Virginia; Jobs: 8,617. Rank: 24; State: South Carolina; Jobs: 8,147. Rank: 25; State: Colorado; Jobs: 8,094. Rank: 26; State: Connecticut; Jobs: 7,551v Rank: 27; State: Pennsylvania; Jobs: 7,427. Rank: 28; State: Maryland; Jobs: 6,748. Rank: 29; State: Utah; Jobs: 6,598. Rank: 30; State: Montana; Jobs: 6,427v Rank: 31; State: Kansas; Jobs: 5,935. Rank: 32; State: Nevada; Jobs: 5,667. Rank: 33; State: Iowa; Jobs: 5,323. Rank: 34; State: New Mexico; Jobs: 5,230. Rank: 35; State: Alabama; Jobs: 4,884. Rank: 36; State: Kentucky; Jobs: 4,202. Rank: 37; State: Arkansas; Jobs: 3,742. Rank: 38; State: New Hampshire; Jobs: 3,528. Rank: 39; State: Mississippi; Jobs: 3,433. Rank: 40; State: Nebraska; Jobs: 2,840. Rank: 41; State: West Virginia; Jobs: 2,409. Rank: 42; State: Alaska; Jobs: 2,315. Rank: 43; State: District of Columbia; Jobs: 2,274. Rank: 44; State: South Dakota; Jobs: 2,198. Rank: 45; State: Idaho; Jobs: 2,103. Rank: 46; State: Vermont; Jobs: 2,030. Rank: 47; State: Rhode Island; Jobs: 2,012. Rank: 48; State: Maine; Jobs: 1,613. Rank: 49; State: Hawaii; Jobs: 1,545. Rank: 50; State: North Dakota; Jobs: 1,293. Rank: 51; State: Delaware; Jobs: 1,170. Rank: 52; State: Wyoming; Jobs: 860. State: Other; Jobs: 1,232. State: Total; Jobs: 640,329. Source: Recovery.gov. Notes: Includes the District of Columbia and Puerto Rico. "Other" includes all other U.S. territories and data that could not be assigned to a specific state. Total may not add due to rounding. [End of table] Table 2 shows the number and share of jobs created or retained by federal program agencies as reported by recipients of Recovery Act funding. The Department of Education accounted for nearly 400,000 or close to two-thirds of the reported jobs created or retained. According to the Department of Education, this represents about 325,000 education jobs such as teachers, principals, and support staff in elementary and secondary schools, and educational, administrative, and support personnel in institutions of higher education funded primarily through the State Fiscal Stabilization Fund (SFSF).[Footnote 15] In addition, approximately 73,000 other jobs (including both education and noneducation positions) were reported saved or created from the SFSF Government Services Fund, the Federal Work Study Program, and Impact Aid funds. Table 2: Jobs Created or Retained by Federal Program Agency as Reported by Recipients of Recovery Act Funding: Department/agency: Education; Jobs: 398,006; Percent of total: 62.2. Department/agency: Labor; Jobs: 76,223; Percent of total: 11.9. Department/agency: Transportation; Jobs: 46,593; Percent of total: 7.3. Department/agency: Health and Human Services; Jobs: 28,616; Percent of total: 4.5. Department/agency: Housing and Urban Development; Jobs: 28,559; Percent of total: 4.5. Department/agency: Defense; Jobs: 11,239; Percent of total: 1.8. Department/agency: Energy; Jobs: 10,021; Percent of total: 1.6. Department/agency: Agriculture; Jobs: 6,273; Percent of total: 1.0. Department/agency: Justice; Jobs: 5,575; Percent of total: 0.9. Department/agency: Corps of Engineers; Jobs: 4,354; Percent of total: 0.7. Department/agency: Environmental Protection Agency; Jobs: 4,191; Percent of total: 0.7. Department/agency: National Science Foundation; Jobs: 2,510; Percent of total: 0.4. Department/agency: Federal Communications Commission; Jobs: 1,929; Percent of total: 0.3. Department/agency: Interior; Jobs: 1,780; Percent of total: 0.3. Department/agency: Treasury; Jobs: 1,454; Percent of total: 0.2. Department/agency: Homeland Security; Jobs: 1,305; Percent of total: 0.2. Department/agency: All others; Jobs: 11,701; Percent of total: 1.8. Department/agency: Total; Jobs: 640,329; Percent of total: 100.0. Source: Recovery.gov. Note: Totals may not add due to rounding. [End of table] Recipients of Recovery Act Funds We Contacted Appear to Have Made Good Faith Efforts to Ensure Complete and Accurate Reporting, but It Will Take Time to Improve Data Quality: While recipients GAO contacted appear to have made good faith efforts to ensure complete and accurate reporting, GAO's fieldwork and initial review and analysis of recipient data from www.recovery.gov, indicate that there are a range of significant reporting and quality issues that need to be addressed. Collecting information from such a large and varied number of entities in a compressed time frame, as required by the Recovery Act, is a huge task. Major challenges associated with the new Recovery Act reporting requirements included educating recipients about the reporting requirements and developing the systems and infrastructure for collecting and reporting the required information. While recipients in the states we reviewed generally made good faith efforts to report accurately, there is evidence, including numerous media accounts, that the data reporting has been somewhat inconsistent. Even recipients of similar types of funds appear to have interpreted the reporting guidance in somewhat different ways and took different approaches in how they developed their jobs data. The extent to which these reporting issues affect overall data quality is uncertain at this point. As existing recipients become more familiar with the reporting system and requirements, these issues may become less significant although communication and training efforts will need to be maintained and in some cases expanded as new recipients of Recovery Act funding enter the system. Because this effort will be an ongoing process of cumulative reporting, our first review represents a snapshot in time. Initial Observations on Recipient Reporting Data Identify Areas Where Further Review and Guidance Are Needed: We performed an initial set of edit checks and basic analyses on the recipient report data available for download from Recovery.gov on October 30, 2009. Based on that initial review work, we identified recipient report records that showed certain data values or patterns in the data that were either erroneous or merit further review due to an unexpected or atypical data value or relationship between data values. For the most part, the number of records identified by our edit checks was relatively small compared to the 56,986 prime recipient report records included in our review. As part of our review, we examined the relationship between recipient reports showing the presence or absence of any FTE counts with the presence or absence of funding amounts shown in either or both data fields for amount of Recovery Act funds received and amount of Recovery Act funds expended. Forty four percent of the prime recipient reports showed an FTE value. As shown in table 3, we identified 3,978 prime recipient reports where FTEs were reported but no dollar amount was reported in the data fields for amount of Recovery Act funds received and amount of Recovery Act funds expended. These records account for 58,386 of the total 640,329 FTEs reported. Table 3: Count of Prime Recipient Reports by Presence or Absence of FTEs and Recovery Act Funds Received or Expended: Recovery Act funds: Received or expended funds reported[A]; Reports with FTEs: 21,280; (84%); Reports without FTEs: 9,247; (29%). Recovery Act funds: No received or expended funds reported; Reports with FTEs: 3,978; (16%); Reports without FTEs: 22,481; (71%). Recovery Act funds: Total; Reports with FTEs: 25,258; (100%); Reports without FTEs: 31,728; (100%). Source: GAO analysis of Recovery.gov data. [A] Prime recipient reports showing a non zero dollar amount in either or both Recovery Act funds received or expended data fields. [End of table] As might be expected, 71 percent of those prime recipient reports shown in table 3 that did not show any FTEs also showed no dollar amount in the data fields for amount of Recovery Act funds received and amount expended. There were also 9,247 reports that showed no FTEs but did show some funding amount in either or both of the funds received or expended data fields. The total value of funds reported in the expenditure field on these reports was $965 million. Those recipient reports showing FTEs but no funds and funds but no FTEs constitute a set of records that merit closer examination to understand the basis for these patterns of reporting. Ten recipient reports accounted for close to 30 percent of the total FTEs reported. All 10 reports were grants and the majority of those reports described funding support for education-sector related positions. For reports containing FTEs, we performed a limited, automated scan of the job creation field of the report, which is to contain a narrative description of jobs created or retained. We identified 261 records where there was only a brief description in this job creation field and that brief text showed such words or phrases as "none," "N/A," zero, or variants thereof. For most of these records, the value of FTEs reported is small, but there are 10 of these records with each reporting 50 or more FTEs. The total number of FTEs reported for all 261 records is 1,776. While our scan could only identify limited instances of apparently contradictory information between the job description and the presence of an FTE number, we suspect that a closer and more extensive review of the job description field in relation to the count of FTEs would yield additional instances where there were problems, and greater attention to this relationship would improve data quality. In our other analyses of the data fields showing Recovery Act funds, we identified 132 records where the award amount was zero or less than $10. There were also 133 records where the amount reported as received exceeded the reported award amount by more than $10. On 17 of these records, the difference between the smaller amount awarded and the larger reported amount received exceeded $1 million. While there may be a reason for this particular relationship between the reported award amount and amount received, it may also indicate an improper keying of data or an interpretation of what amounts are to be reported in which fields that is not in accordance with the guidance. We calculated the overall sum and sum by states for number of FTEs reported, award amount, and amount received. We found that they corresponded closely with the values shown for these data on Recovery.gov. Some of the data fields we examined with known values such as the Treasury Account Symbol (TAS) codes and Catalog of Federal Domestic Assistance (CFDA) numbers[Footnote 16] showed no invalid values on recipient reports. However, our analyses show that there is reason to be concerned that the values shown for these data fields in conjunction with the data field identifying who the funding or awarding agency is may not be congruent. Both TAS and CFDA values are linked to specific agencies and their programs. We matched the reported agency codes against the reported TAS and CFDA codes. We identified 454 reports as having a mismatch on the CFDA number--therefore, the CFDA number shown on the report did not match the CFDA number associated with either the funding or awarding agency shown on the report. On TAS codes, we identified 595 reports where there was no TAS match. Included in the mismatches were 76 recipient reports where GAO was erroneously identified as either the funding or awarding agency. In many instances, review of these records and their TAS or CFDA values along with other descriptive information from the recipient report indicated the likely funding or awarding agencies. These mismatches suggest that either the identification of the agency or the TAS and CFDA codes are in error on the recipient report. Another potential problem area we identified was the provision of data on the number and total amount of small subawards of less than $25,000. There are data fields that collect information on small subawards, small subawards to individuals, and small subawards to vendors. There were 380 prime recipient report records where we observed the same values being reported in both small subawards and small subawards to individuals. We also identified 1,772 other records where it could be clearly established that these values were being reported separately. While we are able to establish that these data are not being consistently reported, it is not possible to assess from the data alone the full extent to which subaward data are being combined or reported separately across all recipient reports. Additionally, we noted 152 reports where, in either the subawards or subawards to individuals data fields, the value for the number of subawards and the total dollar value of subawards were exactly the same and, as such, most likely erroneous. While most recipient report records were not identified as potential problems in these initial edit checks and analyses thus far, our results do indicate the need for further data quality efforts. Various Interpretations of How to Report FTEs Produced Questionable Data on Jobs Created or Retained: Under OMB guidance, jobs created or retained were to be expressed as FTEs. We found that data were reported inconsistently even though significant guidance and training was provided by OMB and federal agencies. While FTEs should allow for the aggregation of different types of jobs--part-time, full-time or temporary--differing interpretations of the FTE guidance compromise the ability to aggregate the data. In addition to issuing guidance, OMB and federal agencies provided several types of clarifying information to recipients as well as opportunities to interact and ask questions or receive help with the reporting process. These included weekly phone calls between OMB and groups representing the state budget and comptrollers offices, weekly calls between all state reporting leads, webinars, a call center, and e- mail outreach. State officials reported they took advantage of and appreciated this outreach. For example, Ohio state officials said they were generally satisfied with the technical assistance and guidance provided by OMB--specifically, the assistance it received from the Federalreporting.gov help desk staff. OMB estimated that it had a better than 90 percent response rate for recipient reporting and said that they answered over 3,500 questions related to recipient reporting. The data element on jobs created or retained expressed in FTEs raised questions and concerns for some recipients. OMB staff reported that questions on FTEs dominated the types of questions they fielded during the first round of recipient reporting. Although the recipient reports provide a detailed account of individual projects, as Recovery.gov shows, these projects represent different types of activities and start and end at various points throughout the year, and recipients had various understandings of how to report an FTE. In section 5.2 of the June 22 guidance, OMB states that "the estimate of the number of jobs required by the Recovery Act should be expressed as 'full-time equivalents' (FTE), which is calculated as the total hours worked in jobs retained divided by the number of hours in a full time schedule, as defined by the recipient." Further, "the FTE estimates must be reported cumulatively each calendar quarter." In section 5.3, OMB states that "reporting is cumulative across the project lifecycle, and will not reset at the beginning of each calendar or fiscal year." FTE calculations varied depending on the period of performance the recipient reported on. For example, in the case of federal highways projects, some have been ongoing for six months, while others started in September 2009. In attempting to address the unique nature of each project, DOT's Federal Highway Administration (FHWA) faced the issue of whether to report FTE data based on the length of time to complete the entire project (project period of performance) versus a standard period of performance such as a calendar quarter across all projects. According to FHWA guidance, which was permitted by OMB, FTEs reported for each highway project are expressed as an average monthly FTE. This means that for a project that started on July 1, 2009, the prime recipient would add up the hours worked on that project in the months of July, August, and September and divide that number by [(3/12 x 2,080 hours)]. For a project that started on August 1, 2009, the prime recipient should add up the hours worked on that project in the months of August and September and divide that number by [(2/12 x 2,080 hours)]. For a project that started on September, 1, 2009, the prime recipient should add up the hours worked on that project in the month of September and divide that number by [(1/12 x 2,080 hours)]. The issue of a standard performance period is magnified when looking across programs and across states. To consistently compare FTEs, or any type of fraction, across projects, one must use a common denominator. Comparison of FTE calculations across projects poses challenges when the projects have used different time periods as denominators. Tables 4 and 5 below provide more detail on the problems created by not having a standard performance period for calculating FTEs. Table 4 is an application of the FHWA guidance for three projects with varying start dates. This example illustrates the way FHWA applied the OMB guidance and that the way FTEs are aggregated in Federalreporting.gov could overstate the employment effects. In this example, because the 30 monthly FTE data were aggregated without standardizing for the quarter, FTEs would be overstated by 10 relative to the OMB guidance. A standardized quarterly measure and job-years are included as examples of a standard period of performance. A job-year is simply one job for 1 year. Regardless of when the project begins, the total hours worked is divided by a full years worth of time (12 months), which would enable aggregation of employment effects across programs and time. Table 4: Aggregation of FHWA FTE Data: Start date: Project A: July 1; Project B: August 1; Project C: September 1. Full-time employees: Project A: 10; Project B: 10; Project C: 10. Duration of project as of September 30: Project A: 3 months; Project B: 2 months; Project C: 1 month. Average monthly FTE per FHWA: Project A: 10; Project B: 10; Project C: 10. Cumulative FTE per OMB guidance: Project A: 10; Project B: 6.67; Project C: 3.33. FTE standardized on a quarterly basis: Project A: 10; Project B: 6.67; Project C: 3.33. Job-years: Project A: 2.5; Project B: 1.67; Project C: 0.83. Source: GAO analysis of FHWA FTE data. Notes: Total FTE as calculated by FHWA and aggregated on Federalreporting.gov = 30. Total cumulative FTE per OMB guidance = 20. Total FTE on a standardized quarterly basis = 20. Total job-years = 5 (standardized FTE). [End of table] Table 5 is an application of the OMB guidance for two projects with varying start dates. In this example, the OMB guidance understates the employment effect relative to the standardized measure. Cumulative FTE per OMB guidance would result in 20 FTE compared with 30 FTE when standardized on a quarterly basis. Both a standardized quarterly FTE measure and a job-year measure are included as examples of a standard period of performance. Regardless of when the project begins, the total hours worked is divided by a full year's worth of time (12 months), which would enable aggregation of employment effects across programs and time. Table 5: OMB's Cumulative FTE versus a Standardized Measure: Start date: Project X: July 1; Project Y: October 1. Full-time employees: Project X: 10; Project Y: 10. Duration of project as of December 30: Project X: 6 months; Project Y: 3 months. Cumulative FTE per OMB guidance: Project X: 10; Project Y: 10. FTE standardized on a quarterly basis: Project X: 20; Project Y: 10. Job-years: Project X: 5; Project Y: 2.5. Source: GAO analysis of OMB FTE calculation guidance. Notes: Total Cumulative FTE per OMB guidance = 20. Total FTE on a standardized quarterly basis = 30. Total job-years = 7.5 (standardized FTE). [End of table] There are examples from other DOT programs where the issue of a project period of performance created significant variation in the FTE calculation. For example, in Pennsylvania, each of four transit entities we interviewed used a different denominator to calculate the number of full-time equivalent jobs they reported on their recipients reports for the period ending September 30, 2009. Southeastern Pennsylvania Transportation Authority in Philadelphia used 1,040 hours as its denominator, since it had projects underway in two previous quarters. Port Authority of Allegheny County prorated the hours based on the contractors' start date as well as to reflect that hours worked from September were not included due to lag time in invoice processing. Port Authority used 1,127 hours for contractors starting before April, 867 hours for contractors starting in the second quarter, and 347 hours for contractors starting in the third quarter. Lehigh and Northampton Transportation Authority in Allentown used 40 hours in the 1512 report they tried to submit, but, due to some confusion about the need for corrective action, the report was not filed. Finally, the Pennsylvania Department of Transportation in the report for nonurbanized transit systems used 1,248 hours, which was prorated by multiplying 8 hours per workday times the 156 workdays between February 17 and September 30, 2009. In several other of our selected states, this variation across transit programs' period of performance for the FTE calculation also occurred. The issue of variation in the period of performance used to calculate FTEs also occurred in Education programs. Across a number of states we reviewed, local education agencies and higher education institutions used a different denominator to calculate the number of FTEs they reported on their recipient reports for the period ending September 30, 2009. For example, two higher education systems in California each calculated the FTE differently. In the case of one, officials chose to use a two-month period as the basis for the FTE performance period. The other chose to use a year as the basis of the FTE. The result is almost a three-to-one difference in the number of FTEs reported for each university system in the first reporting period. Although Education provides alternative methods for calculating an FTE, in neither case does the guidance explicitly state the period of performance of an FTE. [Footnote 17] Recipients were also confused about counting a job created or retained even though they knew the number of hours worked that were paid for with Recovery Act funds. For example, the Revere Housing Authority, in administering one Recovery Act project, told us that they may have underreported jobs data from an architectural firm providing design services for a Recovery Act window replacement project at a public housing complex. The employees at the architecture firm that designed the window replacement project were employed before the firm received the Recovery Act funded contract and will continue to be employed after the contract has been completed, so from the Revere Housing Authority's perspective there were no jobs created or retained. As another example, officials from one housing agency reported the number of people, by trade, who worked on Recovery Act related projects, but did not apply the full-time equivalent calculation outlined by OMB in the June 22 reporting guidance. Officials from another public housing agency told us that they based the number of jobs they reported on letters from their contractors detailing the number of positions rather than FTEs. OMB staff said that thinking about the jobs created or retained as hours worked and paid for with Recovery Act funds was a useful way to understand the FTE guidance. While OMB's guidance explains that in applying the FTE calculation for measuring the number of jobs created or retained recipients will need the total number of hours worked that are funded by the Recovery Act, it could emphasize this relationship more thoroughly throughout its guidance. OMB's decision to convert jobs into FTEs provides a consistent lens to view the amount of labor being funded by the Recovery Act, provided each recipient uses a standard time frame in considering the FTE. The current OMB guidance, however, creates a situation where, because there is no standard starting or ending point, an FTE provides an estimate for the life of the project. Without normalizing the FTE, aggregate numbers should not be considered, and the issue of a standard period of performance is magnified when looking across programs and across states. Technical Reporting and Processing Glitches Occurred, but Recipients Were Able to Report: Recipients we interviewed were able to report into and review data on Federalreporting.gov. Particularly given the scale of the project and how quickly it was implemented, within several months, the ability of the reporting mechanisms to handle the volume of data from the range of recipients represents a solid first step in the data collection and reporting process for the fulfillment of the section 1512 mandate. Nonetheless, there were issues associated with the functional process of reporting. For example, state officials with decentralized reporting structures reported problems downloading submitted information from Recovery.gov to review top-line figures such as money spent and jobs created or retained. The Iowa Department of Management, which did Iowa's centralized reporting into Federalreporting.gov, said that, overall, the system was very slow. In addition to the slowness, as the system was processing input from Iowa's submission, every time it encountered an error, it kicked back the whole submission--but it showed only the one error. After fixing the one errant entry, the state resubmitted its information, which would then be completely sent back the next time an error was encountered. Iowa officials believe it would have been more efficient if the system identified all errors in submission and sent back a complete list of errors to fix. Other recipient reporters we interviewed highlighted issues around DUNS [Footnote 18] numbers and other key identifiers, along with the inability to enter more than one congressional district for projects that span multiple districts. The expectation is that many of these entry and processing errors were captured through the review process, but the probability that all errors were caught is low. Generally, state officials from our 17 jurisdictions reported being able to work through technical reporting and processing glitches. For example, Florida officials reported that they encountered many technical issues but were able to solve the problems by contacting the Recovery Board. Ohio officials noted that, although they were initially concerned, in spite of the tremendous amount of data being submitted, Federalreporting.gov held up well. While they faced some challenges, California officials reported that, overall, they were successful in reporting the numbers into Federalreporting.gov. They worked with the technical team at Federalreporting.gov and performed a test on October 1, 2009, to see if the upload of the job data was going to work. During the October reporting time frame, New Jersey officials reported that they generally did not experience significant recipient reporting problems. The few reporting problems New Jersey experienced occurred in relation to issues uploading the data onto Federalreporting.gov and issues requiring clarifying guidance from the relevant federal agency. Notwithstanding the concerns over the slowness of the reporting system and error checks, Iowa officials also reported that the process worked rather well, determining that most of their state reporting problems seemed to stem from a few recipients not fully grasping all of the training the state had provided and thus not knowing or having key information like DUNS numbers and in some cases submitting erroneous information. The state department of management plans to specifically address the 30 or so recipients associated with these issues--just about all of which were school districts. As a follow-up from this first reporting cycle, several states have developed a list of lessons learned to share with OMB and other federal agencies. An example in appendix I illustrates problems public housing authorities had with both the recipient reporting processing functions and the FTE calculation. In addition to the Federalreporting.gov Web site, the Recovery Board used a revised Recovery.gov Web site to display reported data. The revised site includes the ability to search spending data by state, ZIP code, or congressional district and display the results on a map. The Recovery Board also awarded a separate contract to support its oversight responsibilities with the ability to analyze reported data and identify areas of concern for further investigation. In addition, the board plans to enhance the capabilities of Federalreporting.gov. However, the Recovery Board does not yet use an adequate change management process to manage system modifications. Without such a process, the planned enhancements could become cost and schedule prohibitive. The board has recognized this as a significant risk and has begun development of a change management process. Finally, the board has recognized the need to improve the efficiency of its help desk operation to avoid dropped calls and is working on agreements to address this risk. Processes Are in Place at the States and Federal Agencies for Recipient Reporting Data Quality Review: State Level Data Quality Review: Recipient reporting data quality is a shared responsibility, but often state agencies have principal accountability because they are the prime recipients. Prime recipients, as owners of the recipient reporting data, have the principal responsibility for the quality of the data submitted, and subrecipients delegated to report on behalf of prime recipients share in this responsibility.[Footnote 19] In addition, federal agencies funding Recovery Act projects and activities provide a layer of oversight that augments recipient data quality. Oversight authorities including OMB, the Recovery Board, and federal agency IGs also have roles to play in ensuring recipient reported data quality, while the general public and nongovernmental entities can help as well by highlighting data problems for correction. All of the jurisdictions we reviewed had data quality checks in place for the recipient reporting data, either at the state level or a state agency level. State agencies, as entities that receive Recovery Act funding as federal awards in the form of grants, loans, or cooperative agreements directly from the federal government, are often the prime recipients of Recovery Act funding. Our work in the 16 states and the District of Columbia showed differences in the way states as prime recipients approach recipient reporting data quality review. Officials from nine states reported having chosen a centralized reporting approach meaning that state agencies submit their recipient reports to a state central office, which then submits state agency recipient reports to Federalreporting.gov. For example, Colorado's Department of Transportation provided its recipient report to a central entity, the Colorado Office of Information Technology, for submission to Federalreporting.gov. States with centralized reporting systems maintain that they will be able to provide more oversight of recipient reporting with this approach. Advocates of centralized reporting also expect that method will increase data quality, decrease omissions and duplicate reporting, and facilitate data cleanup. Officials from the remaining eight jurisdictions reported using a decentralized reporting system. In these cases, the state program office administering the funds is the entity submitting the recipient report. In Georgia, for example, the State Department of Transportation is responsible for both reviewing recipient report data and submitting it to Federalreporting.gov. Illinois, as is the case for four other decentralized states, is quasi-decentralized where the data are centrally reviewed and reported in a decentralized manner. When the audit office informs the Office of the Governor that its review is complete and if the Office of the Governor is satisfied with the results, the Illinois state reporting agency may upload agency data to Federalreporting.gov. Appendix I provides details on California's recipient reporting experiences. As a centralized reporting state, Iowa officials told us that they developed internal controls to help ensure that the data submitted to OMB, other federal entities, and the general public, as required by section 1512 of the Recovery Act, are accurate. Specifically, Iowa inserted validation processes in its Recovery Act database to help reviewers identify and correct inaccurate data. In addition, state agency and local officials were required to certify their review and approval of their agency's information prior to submission. Iowa state officials told us that they are working on data quality plans to include being able to reconcile financial information with the state's centralized accounting system. According to Iowa officials, the number of Recovery Act grant awards improperly submitted was relatively small. As a decentralized reporting state, New Jersey officials reported that a tiered approach to data quality checks was used for all Recovery Act funding streams managed by the state. Each New Jersey state department or entity was responsible for formulating a strategy for data quality reviews and implementing that strategy. The New Jersey Department of Community Affairs, for example, directed subrecipients to report data directly into an existing departmental data collection tool modified to encompass all of the data points required by the Recovery Act. This system gave the Department of Community Affairs the ability to view the data as it came in from each subrecipient. From this data collection tool, the department uploaded prime and subrecipient data to Federalreporting.gov. All departmental strategies were reviewed by the New Jersey Governor's office and the New Jersey Recovery Accountability Task Force. The Governor's office conducted a review of the reports as they were uploaded to Federalreporting.gov on a program-by-program, department-by-department basis to identify any outliers, material omissions, or reporting errors that could have been overlooked by departments. Federal Agency Data Quality Review: To help ensure the quality of recipient report data, the Recovery Board encouraged each federal Office of Inspector General overseeing an agency receiving Recovery Act funds to participate in a governmentwide Recovery Act Reporting Data Quality Review. The Recovery Board requested the IG community to determine the following: (1) the existence of documentation on the agencies' processes and procedures to perform limited data quality reviews targeted at identifying material omissions and significant reporting errors, (2) the agencies' plans for ensuring prime recipients report quarterly, and (3) how the agencies intend to notify the recipient of the need to make appropriate and timely changes. In addition, IGs reviewed whether the agency had an adequate process in place to remediate systemic or chronic reporting problems and if they planned to use the reported information as a performance management and assessment tool. We reviewed the 15 IG reports that were available as of November 12, 2009. Our review of these reports from a range of federal agencies found that they had drafted plans or preliminary objectives for their plans for data quality procedures. Published IG audits on agencies' Recovery Act data quality reviews that we examined indicated that federal agencies were using a variety of data quality checks, which included automated or manual data quality checks or a combination. Computer programs drive the automated processes by capturing records that do not align with particular indicators determined by the agency. Agencies may use a manual process where a designated office will investigate outliers that surface during the automated test. For example, the automated process for Education performs data checks to validate selected elements against data in the department's financial systems. As part of its data quality review, Education officials are to examine submitted reports against specific grant programs or contract criteria to identify outliers for particular data elements. Of the IG reports that we reviewed that mentioned systemic or chronic problems, 9 of the 11 found that their agencies had a process in place to address these problems. Although some of the IGs were unable to test the implementation of their agency's procedures for reviewing the quarterly recipient reports, based on their initial audit, they were able to conclude that the draft plan or preliminary objectives for data quality review were in place. According to OMB's guidance documents, federal agencies must work with their recipients to ensure comprehensive and accurate recipient reporting data. A September 11, 2009, memorandum from OMB directed federal agencies to identify Recovery Act award recipients for each Recovery Act program they administer and conduct outreach actions to raise awareness of registration requirements, identify actual and potential barriers to timely registration and reporting, and provide programmatic knowledge and expertise that the recipient may need to register and enter data into Federalreporting.gov. Federal agencies were also expected to provide resources to assist state and select local governments in meeting reporting requirements required by the Recovery Act. In addition, federal agencies were to identify key mitigation steps to take to minimize delays in recipient registration and reporting. OMB also requires that federal agencies perform limited data quality reviews of recipient data to identify material omissions and significant reporting errors and notify the recipients of the need to make appropriate and timely changes to erroneous reports. Federal agencies are also to coordinate how to apply the definitions of material omissions and significant reporting errors in given program areas or across programs in a given agency to ensure consistency in the manner in which data quality reviews are carried out. Although prime recipients and federal agency reviewers are required to perform data quality checks, none are required to certify or approve data for publication. However, as part of their data quality review, federal agencies must classify the submitted data as not reviewed by the agency; reviewed by the agency with no material omissions or significant reporting errors identified; or reviewed by the agency with material omissions or significant reporting errors identified. If an agency fails to choose one of the aforementioned categories, the system will default to not reviewed by the agency. The prime recipient report records we analyzed included data on whether the prime recipient and the agency reviewed the record in the OMB data quality review time frames. In addition, the report record data included a flag as to whether a correction was initiated. A correction could be initiated by either the prime recipient or the reviewing agency. Table 6 shows the number and percentage of prime recipient records that were marked as having been reviewed by either or both parties and whether a correction was initiated. OMB's guidance provided that, a federal agency, depending on the review approach and methodology, could classify data as being reviewed by the agency even if a separate and unique review of each submitted record had not occurred. Table 6: Prime Recipient Reports Reviews and Corrections: Reviewed by agency: No; Reviewed by prime recipient: No; Correction: No; Number of prime recipient reports: 2,959; Percentage: 5. Reviewed by agency: No; Reviewed by prime recipient: No; Correction: Yes; Number of prime recipient reports: 8,201; Percentage: 14. Reviewed by agency: No; Reviewed by prime recipient: Yes; Correction: Yes; Number of prime recipient reports: 1; Percentage: 1

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