Job Creation and Retention Requirements
Guidance from M-10-08
Based on feedback from the recipient community and the Federal agencies, the Job Creation and Retention section of M-09-21,
Implementing Guidance for the Reports on the Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009, published June 22, 2009, was updated as of December 18, 2009 in M-10-08,
Updated Guidance on the American Recovery and Reinvestment Act - Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates.
This updated guidance reflects an important change and simplification to the manner in which job estimates are calculated and reported. It also reflects a change in the definition of a job created or retained.
Definitions of jobs considered to be created or retained:
a. A job created is a new position created and filled, or an existing unfilled position that is filled, that is funded by the Recovery Act;
b. A job retained is an existing position that is now funded by the Recovery Act.
Using the definitions above, recipients must estimate the total number of jobs that were funded in the quarter by the Recovery Act. A funded job is defined as one in which the wages or salaries are either paid for or will be reimbursed with Recovery Act funding.
The requirement for reporting estimates of the "Number of Jobs" is based on a simple calculation used to avoid overstating the number of other than full-time permanent jobs. This calculation converts part-time or temporary jobs into fractional "full-time equivalent" (FTE) jobs.
In order to perform the calculation, a recipient will need the total number of hours worked by employees in the most recent quarter (the quarter being reported) in jobs that meet the definition of a job created or a job retained as defined. The recipient will also need the number of hours in a full-time schedule for the quarter. For instance, if a full-time schedule is 2,080 hours/year, the number of hours in a full-time schedule for a quarter is 520 (2,080 hours/4 quarters = 520). The formula for reporting can be represented as:
Total Number of Hours Worked and Funded by Recovery Act within Reporting Quarter
Quarterly Hours in a Full-Time Schedule
Note Relating to OMB Circular A-21:OMB Circular A-21 recognizes that practices vary among educational institutions as to the activity constituting a full workload. Compensation charged to sponsored projects must conform to the institution's established policies and reasonably reflect the activity for which the employee is compensated. Charges to sponsored projects may be expressed as a percentage of their total activities. Therefore, for purposes of ARRA reporting of jobs created or retained, colleges and universities may count, proportionately, the percentage of effort directly charged to ARRA awards as an FTE equivalent.
Under this alternative calculation and consistent with this Guidance, job estimates will be reported:
1. Based on the total available time in the reporting period, regardless of when the grant period or employment period begins.
For example, if a lab technician charges 100% effort on a project for only one month in the quarter being reported (but zero effort the other two months because no work was performed or the grant was not yet awarded), then the recipient report should reflect 0.33 FTE for that individual.
2. For all reporting periods that the grant is active.
For example, if a researcher provides 100% effort in the grant's first quarter and 50% effort in the grant's second quarter, the recipient report for the first quarter will reflect 1 FTE and the second will reflect 0.5 FTE.
Prime recipients of grants, cooperative agreements, and loans
must include an estimate of jobs created and retained on projects and activities managed by
their funding recipients (i.e. sub-recipients). Recipients should not attempt to report the employment impact upon materials suppliers and central service providers (so-called "indirect" jobs) or on the local community ("induced" jobs).
Further job creation and retention estimation guidance is available at http://www.whitehouse.gov/omb/asset.aspx?AssetId=2182