1. 25 th Annual MIS Conference Presenters: Matthew Case, U.S. Department of Education Nancy J. Smith, DataSmith Solutions Ross Lemke, AEM Corporation The Collection and Reporting of the General Education Provisions Act and Federal Sub-Award Reporting System Fiscal Data

2. This presentation reviews how potentially duplicative fiscal reporting requirements at the federal level are being handled in a number of states and discusses alternatives being considered by ED. | 2 |

3. Issue: Multiple overlapping statutory requirements Issue: Multiple overlapping statutory requirements | 3 | 1994 GEPA Section 424 2006 Federal Funding and Accountability Act (FFATA) 2007 USASpending.gov Launched 2008 Recovery Act (Section 1512) Recovery.gov 2010 FFATA Subaward Reporting FSRS Launch

4. 2/11 - Executive Order 13563 and Presidential Memorandum on “Administrative Flexibility” http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf http://www.whitehouse.gov/the-press-office/2011/02/28/presidential-memorandumadministrative-flexibility 2/11 - Executive Order 13563 and Presidential Memorandum on “Administrative Flexibility” http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf http://www.whitehouse.gov/the-press-office/2011/02/28/presidential-memorandumadministrative-flexibility Directs agencies to review current agency requirements for flexibility Directs agencies to review current agency requirements for flexibility 4/11 - OMB M-11-21 http://www.whitehouse.gov/sites/default/files/omb/memoranda/2011/m11-21.pdf 4/11 - OMB M-11-21 http://www.whitehouse.gov/sites/default/files/omb/memoranda/2011/m11-21.pdf Facilitate use of robust and authoritative data Facilitate use of robust and authoritative data Eliminate duplicative and unnecessary reporting Eliminate duplicative and unnecessary reporting 7/11 - ED RFI on Implementing Administrative Flexibility http://www.gpo.gov/fdsys/pkg/FR-2011-07-06/html/2011-16901.htm | 4 |

5. Convene GEPA/FSRS Working Group at ED Convene GEPA/FSRS Working Group at ED Cross-functional stakeholder group – included Budget/CFO, NCES, Policy, CIO, and General Counsel. Cross-functional stakeholder group – included Budget/CFO, NCES, Policy, CIO, and General Counsel. Identify potential risks and benefits associated with eliminating the GEPA 424 collection. Identify potential risks and benefits associated with eliminating the GEPA 424 collection. Develop GEPA/FSRS White Paper Develop GEPA/FSRS White Paper | 5 |

6. | 6 | Source: Downey, 2010; EDEN, 2011; Sauls, 2009 * Applicable federal program areas included in GEPA, Section 424 are listed in EDFacts File 035. FSRS applies to all federal programs..

7. | 7 | Source: Estimates received via email from five states: Arkansas, Kansas, New York, Texas, and Washington.

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12. Maintain Both Collections Maintain Both Collections Retire GEPA, Section 424 Retire GEPA, Section 424 Retire FSRS Education Data Retire FSRS Education Data Merge GEPA and FSRS Collections Merge GEPA and FSRS Collections | 12 |

13. Risks Burden that duplicate collections place on SEAs, particularly under difficult state and federal budget constraints Burden that duplicate collections place on SEAs, particularly under difficult state and federal budget constraints Potential for discrepancies between the data sources and multiple “versions of the truth” Potential for discrepancies between the data sources and multiple “versions of the truth” Federal: Separate administration and governance SEA: FSRS submissions are typically managed and conducted by a different office or division than the GEPA submissionBenefits As summary data, GEPA collection provides ED a potential source of a “control total” to validate data submitted through FSRS As summary data, GEPA collection provides ED a potential source of a “control total” to validate data submitted through FSRS | 13 |

14. Risks SEAs provide data that are not collected in FSRS, including type of sub recipients (i.e., LEA, non-LEA, other state agency), SEA retained funds, and ED-specific entity identifiers. SEAs provide data that are not collected in FSRS, including type of sub recipients (i.e., LEA, non-LEA, other state agency), SEA retained funds, and ED-specific entity identifiers. GEPA data process is more mature and may be more reliable, valid, or complete. GEPA data process is more mature and may be more reliable, valid, or complete.Benefits Reduction of reporting burden on SEAs. States report using 2-3 full- time-equivalent staff and spending between 20 hours and two and a half weeks fulfilling the GEPA submission requirements annually. (FSRS is submitted only when new sub awards are made. Might not be monthly.) Reduction of reporting burden on SEAs. States report using 2-3 full- time-equivalent staff and spending between 20 hours and two and a half weeks fulfilling the GEPA submission requirements annually. (FSRS is submitted only when new sub awards are made. Might not be monthly.) Reduces EDFacts system impacts of maintaining separate GEPA collection. Reduces EDFacts system impacts of maintaining separate GEPA collection. | 14 |

15. The possibility and desirability of eliminating FSRS are small. The possibility and desirability of eliminating FSRS are small. FSRS targets subawards for all federal programs, not only education. FSRS targets subawards for all federal programs, not only education. FSRS data is more up-to-date than GEPA. FSRS data is more up-to-date than GEPA. Analyses have shown a high correlation between FSRS and GEPA data. Analyses have shown a high correlation between FSRS and GEPA data. Widespread availability of FSRS data through the USASpending.gov public portal increases the likelihood the data will be used. Widespread availability of FSRS data through the USASpending.gov public portal increases the likelihood the data will be used. | 15 |

16. Purpose is different Purpose is different Most non-financial data elements are different Most non-financial data elements are different Collection schedule is different Collection schedule is different Managed by different agencies Managed by different agencies ED can collect data for its reports from FSRS ED can collect data for its reports from FSRS | 16 |

17. Are subaward data reported to USASpending the same or better quality than data reported via EDFacts GEPA collection? Are subaward data reported to USASpending the same or better quality than data reported via EDFacts GEPA collection? Difficult to do comprehensively because of the lags in GEPA reporting Difficult to do comprehensively because of the lags in GEPA reporting Quality of Source Data (Prime Award information) Quality of Source Data (Prime Award information) Identify Potential Reporting Gaps Identify Potential Reporting Gaps | 17 |

18. Percentage of SEA prime awards* reported to USASpending.gov that Exactly Match to USDoED Budget allocation tables (Selected Formula Programs) Percentage of SEA prime awards* reported to USASpending.gov that Exactly Match to USDoED Budget allocation tables (Selected Formula Programs) | 18 | *Includes 50 States, DC and PR. Source : www.usaspending.gov (Direct link) and USDoED Budget Service (Direct Link)

19. FFATA Subaward Reporting Required for: FFATA Subaward Reporting Required for: New awards (e.g., a new FAIN is issued) made after October 1, 2010 funded at $25,000 or more New awards (e.g., a new FAIN is issued) made after October 1, 2010 funded at $25,000 or more ARRA awards and continuations are excluded ARRA awards and continuations are excluded FFATA subaward reporting requirements are inserted into Grant Award Notification (GAN) (Attachment P) FFATA subaward reporting requirements are inserted into Grant Award Notification (GAN) (Attachment P) | 19 |

20. Are programs required for reporting under GEPA currently being required to be reported to FSRS? Are programs required for reporting under GEPA currently being required to be reported to FSRS? Estimated 70-80% of non -ARRA FY2011 awards subject to GEPA requirements required Estimated 70-80% of non -ARRA FY2011 awards subject to GEPA requirements required If required, are SEAs actually reporting? If required, are SEAs actually reporting? Example: FY2011 Title I Grants to LEAs (84.010) Example: FY2011 Title I Grants to LEAs (84.010) Number of States reporting subgrants to FSRS: 30 Number of States reporting subgrants to FSRS: 30 Of those, about 50% are within the expected dollar amounts and total subgrants when compared to prior year GEPA and FY11 Budget allocations. Of those, about 50% are within the expected dollar amounts and total subgrants when compared to prior year GEPA and FY11 Budget allocations. | 20 |

21. Presenters: Matthew Case, US Department of Education Nancy J. Smith, DataSmith Solutions Ross Lemke, AEM Corporation Back-up Slides

22. Thank You.

23. FFATA and its subsequent 2008 amendments seek to increase transparency and improve access to Federal Government information by: FFATA and its subsequent 2008 amendments seek to increase transparency and improve access to Federal Government information by: Requiring information disclosure of entities receiving Federal funding through Federal awards such as Federal contracts and their sub- contracts, and Federal grants and their subawards; Requiring information disclosure of entities receiving Federal funding through Federal awards such as Federal contracts and their sub- contracts, and Federal grants and their subawards; Requiring disclosure of executive compensation for certain entities; Requiring disclosure of executive compensation for certain entities; Requiring the establishment of a publicly available, searchable website that contains information about each Federal award; and Requiring the establishment of a publicly available, searchable website that contains information about each Federal award; and Requiring agencies to comply with the OMB guidance and instructions, and to assist OMB in the implementation of the searchable website. Requiring agencies to comply with the OMB guidance and instructions, and to assist OMB in the implementation of the searchable website. | 23 |

24. | 24 | *Source: OMB memo “Open Government Directive – Federal Spending Transparency and Executive Compensation Data Reporting, August 27, 2010 - http://www.whitehouse.gov/sites/default/files/omb/open/Executive_Compensation_Reporting_08272010.pdf