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Section 1512 - Recipient Reporting under the American Recovery and Reinvestment Act of 2009

Frequently Asked Questions

Section 1512 Recipient Reporting
Q1. Is my understanding correct that the State Agency is the prime recipient of WIA ARRA funding with the Local Boards being subrecipients and their (LWIBS) service providers being Vendors?
A. The State is the prime recipient for formula grant ARRA WIA funding. LWIB’s would be considered as subrecipients for such funds. Service providers under the LWIB would be either a subrecipient or a vendor, depending on the type of work performed. Other direct recipients of federal funds, such as discretionary grantees, are also prime recipients.
Q2. In the OMB supplement 1 to the 6/22 guidance, the list of programs that are subject to Section 1512 reporting, under DOL, "Unemployment Insurance – CFDA 17.225" is listed as reportable. Is this just the admin portion of UI or UI modernization funding or does it include each payment to individuals from UI funds?
A. UI is not included in the list of programs under ARRA that are subject to the reporting requirements found under section 1512 of the Act. On August 7, 2009 UI was erroneously included in Supplement 1 of OMB Memorandum No. M-09-2. It was removed from the list by OMB in subsequent listings and is no longer referenced as a required program on
Q3. I have heard some programs are reporting monthly. Are there programs reporting monthly? Which programs are reporting monthly and which are reporting quarterly?
A. Monthly ARRA reporting is required by ETA for performance and enrollment purposes. See TEGL 24-08 for more information on monthly reporting requirements. Section 1512 reporting is a separate report required by OMB for all ARRA programs on a quarterly basis, ten (10) days following the end of each quarter.
Q4. Based on the ARRA Section 1512 Reporting Requirement webinar on 8/19/09 the presenters indicated that both a DUNS# and CCR# were needed for the prime recipient and subrecipient. If the subrecipient will not be submitting a report, do we still need to provide the CCR#? If yes, where is the CCR# for sub recipients requested on the EXCEL template, I see DUNS# but not CCR# on the sub recipient tab.
Q4A. Do the subrecipients (local area workforce investment boards) have to register in CCR? We have confirmed that they all have DUNS numbers and Wisconsin is NOT delegating any reporting to them.
A. TEGL 29-08, published June 10, 2009, requires that a CCR number be obtained by each prime recipient and subrecipient who received ARRA funds from DOL/ETA. The CCR number is not entered in the data elements for subrecipients in the 1512 report.
Q4B. Where is the CCR# requested for the prime recipient on the EXCEL spreadsheet?
A. If the prime recipient has not delegated reporting responsibilities, subrecipients are not required to register with All subrecipients are reminded of the requirements for obtaining a DUNS number and registration with the CCR as specified in TEGL 29-08.
Q5. On lines 21, 23, 32, and 68 does the prime recipient include information on the subs here as well?
A. No, those lines are for reporting information on the prime recipient. These data elements are not required to be reported for subrecipients. The reporting elements for subrecipients that are required are identified in the OMB Memo 09-21, paragraph 2.3 and further outlined in the supplement to this memo, Recipient Reporting Data Model V3. These references can be accessed at
Q6. For the Top 5 Officers names and compensation, is this needed even if they are not charged to ARRA?
A. Yes. OMB guidance indicates that if the organization receives ARRA funding, this information is required if the prime recipient meets the funding threshold requirements identified the OMB Recipient Reporting Data Model V3.0 and the public does not already have access to this compensation information as described in the OMB Recipient Reporting Data Model V3.0.
Q7. Where can the NTEE-NPC code be found?
A. The codes can be found at the website of the National center for Charitable Statistics. The Recipient Reporting Data Model V3 indicates that the specific location on a list of these codes can be found at: More than one applicable code may be entered in the report.
Q8. It is our understanding that ARRA-funded UI is not subject 1512 recipient reporting. In fact, in the introductory paragraph to Supplement 1 to the OMB memorandum M-09-21, it states that "[p]rograms identified in Division B of the Act are not subject to section 1512 reporting requirements." It further states that "awards to individuals" are exempt from 1512 reporting.


However, under "Department of Labor" in the list included in Supplement 1, Unemployment Insurance (CFDA 17.225) is listed as a program subject to 1512 reporting. All of the UI programs for which we receive funding are in Division B of the Recovery Act, but the CFDA number is the same as the one listed:

  • EUC extension - section 2001
  • FAC (the extra $25 per check) - section 2002
  • Special Transfer for UI Modernization - section 2003
  • Special Transfer in FY 2009 for Administration - section 2003
  • Extended Benefits funded at 100% - section 2005

Will you please explain this apparent contradiction and confirm our understanding that we do not need to provide a 1512 report for the above programs? Thank you for this courtesy.

A. UI is not included in the list of programs under ARRA that are subject to the reporting requirements found under section 1512 of the Act. On August 7, 2009 UI was erroneously included in Supplement 1 of OMB Memorandum No. M-09-21. It was removed by OMB from subsequent listings of programs required to report.
Q9. WIA - Do the following jobs count in 1512 reporting?
  1. Summer Youth Jobs for participants: A. Yes.

  2. Incumbent Worker funded positions: A. Yes, if the position is one that would not have been continued to be filled were it not for ARRA funding.

  3. Employed worker positions: A. If the positions are newly created or filled as result of ARRA funding.

  4. Training positions at training providers for ARRA WIA funded programs: A. No
Q9A. Has there been a decision on whether summer youth employment should be reported under the job creation category? TEGL 1-09 indicated No; however, the webinar on 8/19/09 indicated this may change.
A. Yes, Summer Youth jobs will be included in the calculations. Please refer to TEGL 01-09, Change 1, dated September 21, 2009 for more details.
Q10. What information can a recipient require a subrecipient to report?  For example, data elements in the subrecipient report are limited to 10 items, and do not include information such as job creation narrative and number. Can the recipient delegate the subrecipient to report on the recipient data elements?

If yes, how is this done using the registration and reporting model (i.e., can a subrecipient be delegated to complete all or part of the recipient report)?  Or would the subrecipient report on data elements such as job creation directly to the recipient, who would still be responsible for completing the recipient report?

A. Recipients are responsible for gathering and submitting all information required to complete the Section 1512 reports. Each recipient is therefore responsible for determining the best method to obtain information which may include requiring subrecipients to provide information on jobs created or completion status or activities, etc. The mechanisms and time frames for gathering such information are at the discretion of the prime recipients.
Q11. We’ve received mixed messages on how to report hours worked to use with the full-time equivalency formula. OMB M-09-21 on page 36 suggests it is paid hours for full-time workers ("A faculty member charging 50% effort on an ARRA award will be counted as .5 FTE"), and actual hours worked for part-timers and hourly workers. A speaker on the August 19 Webinar indicated that for full-time workers it might be actual hours worked rather than paid hours (i.e., paid sick and annual leave would be excluded from the FTE basis).

We would like clarification on which is correct, because in our organization, a full-time worker charging time to more than one grant has leave time charged on a prorated basis to each grant based on hours worked. The time charged to an ARRA award on any given pay period, might or might not include paid leave. We believe this is equivalent to the OMB faculty member example. We also do not pay for overtime work, common among our full-time workers. If we go with the "actual hours worked" Webinar definition, we would have to subtract paid leave hours and collect data to add unpaid overtime hours in order to report actual time worked each pay period. This seems unduly burdensome. Please let us know what we should do.

A. All job creation estimates should be based on paid time worked which would include paid leave time but not include unpaid accruals. Please refer to the Recipient Data Model V.3.0 and to OMB Memorandum M-09-21, dated June 22, 2009 for additional information on calculating the FTE for jobs created and retained.
Q12. Where/how do we report expenditures, sub-awards and jobs created/retained for the WIA Statewide Activities Governor’s Discretionary 15% and the 10% administration for the local areas?
A. OMB Guidance excludes from reporting the costs incurred by State recipients in the management and administration of the Recovery Act (up to .5%) as stated on page 10 of OMB Memorandum 09-21 dated June 22, 2009. The composition of the administrative costs excluded from reporting was addressed in the OMB Recovery FAQs in question 2 of the section Recovering State Administrative Costs and is available at Please see OMB Memorandum M-09-18,(May 11, 2009) and  M-10-03 (Oct. 13, 2009) for further information on the methodology for recovering such costs. Expenditures for WIA Statewide activities and local area administration are reported as part of the overall WIA program in accordance with the requirements of the Recipient Data Model, V.3.0.
Q13. According to the OMB reporting model, the number of jobs reported should include the number for subrecipients and vendors. Should this number include jobs by only the vendors of the prime recipient or jobs by the vendors of by both the prime and subrecipients?
A. OMB Memo 09-21, paragraph 5.4, footnote 13, provides the answer. Direct jobs created and retained by prime recipient vendors and sub-recipient vendors are to be counted.
Q14. Do the total number and amount of payments to vendors less than $25,000/award only include those made by the prime recipient or does it also include vendor payments made by the subrecipients?
A. Under the Recipient Reporting Data Model V 3.0, "total number and amount of payments to vendors less than $25,000" is only applicable to prime recipients. Therefore, any vendor payments made by subrecipients are not included on the prime recipient's vendor payment number.
Q15. Is infrastructure investment reporting expected for WIA, Wagner-Peyser, and RES?
A. Infrastructure expenditure reporting is not expected for any ETA programs.
Q16. We are the prime recipient (state) reporting for our local workforce areas. We understand the local workforce areas to be the subrecipients in 1512 reporting. How is their local service providers considered in 1512 reporting? The only separate reporting document is for vendors. The OMB definition of vendor does not seem to fit that of a local service provider. If this is the case, how are their expenditures reported – as the subrecipient’s expenditures (even though the funds were not truly expended by the subrecipient)?
Q16A. We are seeking the following clarification prior to submitting 1512 reporting guidance to our local workforce areas and state grantees:
We are the prime recipient (state) reporting for our local workforce areas. We understand the local workforce areas to be the subrecipients in 1512 reporting. How is the local service providers considered in 1512 reporting?
Q16B. The only separate reporting document is for vendors. The OMB definition of vendor does not seem to fit that of a local service provider. If this is the case, how are their expenditures reported – as the subrecipient’s expenditures (even though the funds were not truly expended by the subrecipient)?
A. Local service providers would be considered as subrecipients or vendors depending on the type of work performed. No further reporting of subrecipient activity is required and reporting of vendor activity at the subrecipient level is limited.

The website provides the following information (copied directly from the website)

  • Reporting begins Thursday, October 1, 2009. The system opens for reporting on Thursday, October 1, 2009. The Service Desk will be available 24 hours, 7 days a week during reporting period.
  • Reports publicly available Sunday, October 11, 2009. Initial submission reports will be available for public view at beginning Sunday, October 11, 2009.

At a recent webinar the USDOL provided a template (copied directly from the webinar info) which indicates a review period for DOL will be from October 11 through October 29, 2009 after which the data becomes public. Which is correct?

A. According to our understanding, information reported as of October 10 will be available for public inspection on October 11. Consequently, it is imperative that recipients and subrecipients, if they have been delegated reporting responsibility, enter correct information as of October 10. From October 11-21, the reporting entity (recipient or subrecipient) will have the opportunity to officially correct any errors or omissions that occurred in the initial reporting. During the October 11-21 period USDOL will also be performing its own "informal" review of the reported data. If DOL finds significant errors or material omissions during this Oct 11-21 review, DOL will informally, outside of the  website system, notify the reporting entity of such errors/omissions to facilitate early corrections of any reporting problems. During the Oct 22-29 period DOL will complete its "official" review of the reported data and "officially through the reporting system" notify the reporting entity of any uncorrected errors. OMB has stated that recipients should be aware that their data could be used at any time during this period for public reporting.
Q18. Does reporting on vendors receiving $25,000 or more mean a single payment to a vendor of $25,000 or more or does it mean that once a vendor receives multiple payments totaling $25,000 or more (i.e. several payments of less than $25,000 add up to $25,000 or more), it subjects the vendor and the ARRA recipient to the reporting requirement of $25,000 or more.
A. OMB has been clear on this subject in the Recipient Reporting Data Model, V3.0 which is available at The reporting trigger for vendors over $25,000 is single payment of $25,000 or more, not aggregate payments.
Q19. Where can we get the TAS#, the template says to contact the contracting office?
A. The TAS code for ARRA WIA funded programs is 1609100184. Also, the help desk has provided the following information about TAS codes:"We have received your request regarding the TAS code on the reporting template. You can obtain TAS code directly from the excel template. There is a search code drop down box located on the side of the template highlighted in yellow in red text. You can search your Federal Agency name and the codes you are requesting will pre-populate in the field".