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Highlights of OMB Revised Guidance to on Measuring and Reporting Job Estimates
OMB issued Updated Guidance on the American Recovery and Reinvestment Act—Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates (memorandum M-10-08) (PDF) (188K, 24 pp., about PDF) ("OMB's guidance") on December 18, 2009. Part 2 of this memorandum updates Section 5: Reporting on Jobs Creation Estimates by Recipients (OMB memorandum M-09-21, June 22, 2009, (PDF)) (41pp, 550k, about PDF) ("OMB Memorandum M-09-21"). Below are some of the key highlights and content of the revised guidance to assist EPA’s recipients in estimating jobs created and retained. This summary does not include all of the issues raised in OMB’s guidance and we recommend that recipients also review the full OMB memorandum.
Because this new guidance modifies previous definitions and calculations, EPA has removed prior supplemental jobs guidance from this Web site.
Key Highlights
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The definitions of jobs created or retained have changed. Previous guidance required recipients to make a subjective judgment on whether a given job would have existed were it not for the Recovery Act. The updated guidance eliminates this subjective assessment and defines jobs created or retained as those funded by the Recovery Act. See sections 5.1, 5.2 key principle #2, and 5.9 of OMB’s guidance for more detail.
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The job estimate calculation has changed; recipients will now report job estimate totals by dividing the hours worked in the reporting quarter (i.e., the most recent quarter) by the full-time schedule hours in that quarter. Recipients will no longer be required to sum across multiple quarters of data as part of the FTE formula. See sections 5.1 and 5.3 of OMB’s guidance for more detail.
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Effective February 2, 2010, FederalReporting.gov will be open for continuous corrections of data for the most recent quarter. Recipients will have the ability to make corrections up until the start of the next reporting period (e.g., recipients will be able to make corrections until March 31, 2010 to data for the quarter ending December 31, 2009). See sections 5.2, key principle #12 and 5.10 of OMB’s guidance for more detail.
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For corrections to prior quarters, recipients shall maintain within their administrative records comprehensive information on any and all necessary corrections to prior quarter data. Recipients will be required, at a time and process to be specified in the future, to submit this information to the federal government.
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The clarifications in OMB’s December 18 guidance are not retroactive to the quarter ending September 30, 2009. Any corrections to job estimate totals for the quarter ending September 30, 2009 should rely on the definition of jobs created or retained in OMB Memorandum M-09-21.
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OMB’s guidance includes:
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Twelve key principles for recipient estimates of jobs created and retained (section 5.2),
- Methodology for estimating jobs created and retained with examples (section 5.3)
Total Number of Hours Worked and Funded by Recovery Act within Reporting Quarter
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= FTE
Quarterly Hours in a Full-Time Schedule
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Step by step instructions and examples for calculating estimates of jobs created and retained (section 5.4)
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Assess which hours worked should be included in the FTE calculation (the numerator of the FTE calculation). Use payroll information to include only funded jobs; i.e. those for which the wages or salaries are either paid for or will be reimbursed with Recovery Act funding.
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Represent the full-time schedule in hours, for the reporting quarter (the denominator of the FTE calculation – for a 40 hour work week, the denominator will be 520 hours)
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Enter the calculations for the numerator and denominator into the FTE formula to calculate the “Number of Jobs”
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Additional instructions for jobs partially funded by the Recovery Act
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The recipient should assess what portion of each employee’s hours worked are funded by the Recovery Act. If the recipient knows the overall portion of Recovery Act funds used to pay the salary of its employees, but does not have that information for each individual employee, the recipient should adjust the job estimate based on the proportion of funding associated with the Recovery Act. See section 5.5 for detailed examples.
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If the employees were hired for a defined period of time (e.g., one year) with a plan to use both Recovery Act and non-Recovery Act funds to pay their salaries, the recipient should adjust their FTE estimate by the share of the overall project funded by the Recovery Act, regardless of when the Recovery money was spent. See section 5.8.
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If the employees were hired for an indefinite period, each quarter the recipient must determine the percentage of work hours (if any) funded by the Recovery Act for that quarter. See section 5.8.
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Additional instructions for jobs paid initially with non-Recovery Act dollars. Jobs paid initially with non-Recovery Act dollars may be reported as created or retained as long as such dollars eventually will be reimbursed with Recovery Act funds. See section 5.9.