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Compilation of Comments Received on PL 102‐477 Forms
Narrative Report: A Reporting System for Public Law 102‐477, Indian Employment, Training, and Related Services Demonstration Act
Comment
Under the Paperwork Reduction Act Statement, this section states, “The report is used to
monitor the progress of the grantees in delivering services to Tribal members, to identify
unmet needs, to identify any other problems, and to provide information to justify budget
submissions by the three federal agencies involved.” However, the first paragraph
(correctly) identifies four federal agencies. Three should be corrected to four.
Page 2, item #1, strike the first sentence (“If the Tribe includes Child Care and
Development Funds (CCDF)…”) because such a report is required only for Tribes with a
CCDF allotment of $500,000 or more.
1
Response
Change “justify budget submissions by the three
federal agencies involved” to “justify federal
agency budget submissions.” While the law
applies to four Federal agencies, only three
have participated to date. This edit would
leave open the possibility that the fourth could
participate.
The CCDF Notice of Proposed Rule Making
(NPRM) proposes to require all Tribes,
regardless of their funding amount to spend a
minimum of 4 percent on quality activities. We
note that the policy in the proposed rule is not
yet final but changes to the language in the
form should allow Tribes the flexibility to
respond to the current requirement and any
changes that would be made in the CCDF Final
Rule.
Item #1, changed to read: Tribes subject to the
4 percent quality should describe efforts that
were implemented to promote higher quality
child care (e.g., provider training and
professional development, health and safety
requirements, etc).
TANF 2a‐f
Accepted. Clarified by keeping the first
• Instructions regarding TANF 2a‐f in Family Assistance Plan. Please clarify (or correct?) paragraph and other references deleted.
reference.
• Item 2 second paragraph stated if the Tribal TANF grantee has submitted the
information in #2a‐f in its Tribal Assistance Plan (TFAP). This has no explanation of
what #2a‐f is.
• On the General Overview of the Program Document and on the 2nd page in the
Narrative Report, second paragraph of number 2 refers to “If the Tribal TANF grantee
has submitted the information required in #2a‐f in its TFAP. As there is no longer a
separate TANF report, this reference does not make sense and should be removed.
It states substantive change in certain data elements but does not say detail the elements. A change in data element refers to a change in
the information required at 45 CFR 286.275(b),
now incorporated into the annual 477 narrative
report. This information includes TANF work
activity definitions; description of transitional
services; sanction processes for non‐
compliance; description of nonrecurring short‐
term benefits; description of displacement
complaint resolution processes; and
description of FVO strategies and procedures.
Changes to these aspects of the TFAP or
P.L.102‐477 Plan must be filed as amendments
to the Plan.
2
Statistical Report
Comment
Section II.A.4 “Average Adult Earnings Gain”
Asks for the Average Adult Earnings Gain. However, in the column for Cash Assistance
Recipients both adults and youth are included. Is the Average Earnings Gain to be listed
only for adult cash assistance recipients? Or is the intent to report Average Earnings Gain
for all (drop specification “adult”)? We would recommend that the answer would include
information for any CAR recipient.
Section II.A.4 asks for the Average Adult Earnings Gain. However, in the column for Cash
Assistance Recipients both adults and youth are included. Is the average earnings gain to
be listed only for adult cash assistance recipients?
There needs to be a category for Average Youth Earnings Gain.
In Section II.A.4, insert the phrase “To illustrate” at the beginning of the third sentence to
read: “To illustrate, if at termination such a person entered…” The reason for this change
is to make clear that it is intended as an example of gain for purposes of determining
average gain.
Section II.A.4 asks for Average Adult Earnings Gain. We recommend adding specific
guidance that would clarify whether an Adult or Cash Recipient who entered unsubsidized
employment and then received child care services to retain that employment would be
reported in this row. The current guidance for the Average Adult Earnings Gains does not
accurately capture this type of success as this type of terminee would not be reported until
after overall 477 program termination.
Section II, B(1), insert a forward slash between Degree and Certificate (Degree/Certificate)
in order to distinguish the separate types of documents.
Instructions should CLEARLY specify that the demographics of the participant is determined
at time of application, for both total participants and total terminees. (If the participant
was over 21 at time of application, the participant should be counted in the second column
labeled, “Youth”, except for persons receiving cash assistance. Additionally, the education
level at the time of entry is what is reported in the terminee section.) This means that if a
participant was a “dropout” at entry, and during the service period, obtained their GED,
they would still be reported has a “dropout” in this report.
3
Response
DOL Component and GPRA Measure.
See above.
See above.
Accepted.
This is a GPRA Measure.
Accepted.
Accepted ‐ More clearly designate that age is
determined as of date of enrollment.
Accepted – Clarify that education level is
determined as of date of enrollment.
Instructions should specify that the age of the participant is determined at time of
application, for both total participants and total terminees. (If the participant was 22 or
older at time of application, the participant should be counted in the first column labeled,
“Adult” except for persons receiving cash assistance.
Instructions specify that individuals receiving cash assistance also determined at time of
enrollment, or within six months prior to enrollment, or deemed eligible to receive cash
assistance at any time during enrollment.
• This manner of reporting does not accommodate a means of reporting those who
receive TANF or GA participants at any time during the service period.
• (If individuals can be terminated as a cash assistance recipient because they received
cash assistance during participation, it is conceivable that you would have more cash
assistance terminees than total cash assistance participants).
Instructions for Terminee Outcomes
Clarify that terminees can be counted once in each category. (i.e. Employment Objective,
Education/Training Objective, and Miscellaneous Objective Achieved).
This does raise a question regarding how to report a person who achieves multiple goals
and then dies? For example: this person achieves Education goal, and is seeking
employment when they lose their life.
4
See above.
If an individual is eligible for cash assistance but
never receives, doesn’t seem to be a TANF or
GA recipient unless they are receiving other
services that fall under the definition of a cash
benefit.
Clarify that terminees may be counted more
than once – once in each sub‐category
(employment objective, education/training
objective) except terminees may be counted
more than once in miscellaneous objective
subcategory if multiple miscellaneous
objectives were achieved.
Goals achieved are reported up until death.
Goals not achieved due to death will be
reported either as goal not attained (depending
on the goal – it should be recorded as not
achieved or under II. D. Other (Non‐Positive)).
Annual Financial Expenditure Report & Instructions
SF‐425 does not need to be submitted by 477 grantees. The 477 financial form replaces the SF‐425
Comment
Under item 5. Final Report, We suggest “The Total Unexpended Funds must be zero in a
final report for the Plan Period.” In order to clarify the reporting methodology by each
individual Plan Period.
Response
Accepted. Clarified on form that final report is
for a Plan Period. Also changed instructions to
read as follows:
“Specify if this is the final financial report for
the Plan Period. Mark ‘No’ if this financial
report includes funds that are unexpended. An
Annual Report must be prepared and submitted
for each Plan Period until all of the funds
available for the Plan Period have been fully
expended and reported. When the funds for
the Plan Period have been fully expended, a
final report for the Plan Period shall be
submitted that notes the Total Unexpended
Funds are zero.”
Under item 5. Final Report, We suggest “Specify if this is the final financial report for the See above.
Plan Period, Mark “No” if this financial report includes funds that are unexpended.
When the funds for the Plan Period have been fully expended, a final report shall be
submitted that notes the Total Unexpended Funds are zero” in order to clarify the
reporting methodology by each individual Plan Period.
Under item 5. Final Report, We suggest “When a plan period ends and funds have been See above.
fully expended mark the report as final. Do not mark as final if there are funds carried
over into following report period.”
See above.
Add language that explains how to report based on plan period. For example “An
Annual Report shall be prepared and submitted for each Plan Period until all of the
funds available for the Plan Period have been fully expended and reported.”
5
We recommend that this section explain the reporting methodology by Plan Period. For
example, an Annual Report shall be prepared and submitted for each Plan Period until
all of the funds available for the Plain Period have been fully expended and reported.
When the funds for a Plan Period are fully expended, the funding closeout process will
be a final report for the Plan Period submitted with Total Unexpended Funds equal to
zero.
In column 8, strike line 8(e)(i), “Child Care Quality Improvement (non‐add)” and insert it
as line 8(c)(i). The reason for this change is that only those Tribes with a CCDF allotment
of $500,000 or more are required to account for Child Care Quality Improvement
expenditures.
Clarify how to determine who is required to report child care quality improvement
based on level of funding received.
See above.
Child Care Quality Improvement is not a child
care service; it is part of the program
operations expenditure.
Clarify language in the document. It should
read: If the Tribe is subject to the 4 percent
Child Care and Development Funds (CCDF)
quality requirements the narrative report
should describe any efforts that were
implemented to promote higher quality child
care (e.g., provider training and professional
development, health and safety requirements,
etc).
In line 9 add: “Certification: This is to certify … have not been waived, and that all funds The current certification statement is sufficient
have been expended in accordance with the Tribe’s approved 477 plan.”
– will leave as is.
There are no instructions as to how to report (or not report) Program Income.
This report is solely to account for Federal
funds received. Program income is included in
the 477 plan submitted by the tribe for
approval and can also be reported in the
narrative report.
The Program Income is not identified on this form, which is inconsistent with the SF425 This report is solely to account for Federal
Federal Financial Report. There are no instructions as to how to report (or not report)
funds received. The 477 financial report
Program Income.
replaces the SF‐425 and does not require
reporting program income.
The Program Income is not identified on this form, which is inconsistent with the SF425 This report is solely to account for Federal
Federal Financial Report.
funds received. The 477 financial report
replaces the SF‐425 and does not require
reporting program income.
6
The financial reporting instructions do not address indirect rates in a report year
Indirect cost expenditures are reported on 8.f.
There is no requirement to report indirect rates
here.
Indirect cost information is not identified on this form, which is inconsistent with the
Indirect cost expenditures are reported on 8.f.
SF425 Financial Report.
There is no requirement to report indirect rates
here.
Financial instructions do not clarify the language in TANF purpose 3 and 4 or other TANF The cost categories documents provide
assistance
examples. See the last three bullets on the
Education, Employment, Training and
Supportive Services cost category definitions.
The last three bullets are the definition of
purpose 3 and 4 from the TANF regulations.
OMB suspended A‐133 Compliance Supplement but the new PL 102‐477 Proposed
The cost categories were created through a
Annual Financial Expenditure Report now re‐directs tribes to report again by program
long, deliberative process by the workgroup,
funding stream.
with Tribal representatives.
Increases administrative burden on tribes with implementing the use of “cost
The cost categories were created through a
categories” as tribes will have to redesign their tribal financial systems to comply with
long, deliberative process by the workgroup,
reporting needs.
with Tribal representatives.
The items listed for the various cost categories are confusing and subjective
The cost categories were created through a
long, deliberative process by the workgroup,
with Tribal representatives.
7
Combined Functional Cost Categories Guidance
Response
Administrative Cost document under the Guidance section, the last bullet point is
incomplete. It states “Other costs for goods and services required for administration,
including rental or purchase of equipment, utilities, and office supplies, and”
Administrative Cost document under the Guidance section, we recommend guidance
language regarding administrative cost caps.
Administrative Cost document under the Guidance section – we recommend guidance
language regarding administrative cost caps to allow Tribal entities to use their
federally negotiated indirect rate.
In the category form for “Program Operations” strike the second sentence in the
Definition section, which reads “Reporting for child care quality improvement… Tribes
receiving less than $500,000 in CCDF” and insert it in the Definition section in the
Category form for “Child Care Services.” The reason for this change is that “Child care”
is a specific type of activity and it would be less confusing to have the function match
the expenditure.
8
Response
The sentence should read “including rental or
purchase of equipment, utilities, and office
supplies.”
Cost caps vary by agency; follow agency
guidance.
We cannot authorize on behalf of other
agencies; follow agency guidance. As
previously stated, a workgroup involving the
respective agency staff can be formed to deal
with this issue. However, until then tribes
should follow the individual program guidance
related to administrative caps.
“Child care quality improvement…” is accurate
under Program Operations and therefore, will
not be changed.
Implementation Concerns
Comment
Transition from current reporting to proposed reporting forms:
Clarifying the timeline of these changes is paramount. An effective date needs to be
clarified to tribes to allow adequate time and provide additional funding to make
changes in accounting systems and training on the new forms.
If the new forms and functional categories are to be implemented at the beginning of
each Tribal entity’s next plan cycle, some tribes (particularly KANA) will have limited
timeline in which to prepare. To limit the burdens of reporting at the time of transition,
we suggest Tribal entities have the flexibility to report carry over funding expenses on
either current 477 forms or the proposed form.
Training:
Technical Assistance and face‐to‐face training on the proposed forms is essential.
It is impossible to judge the impact of these reporting changes without the
accompanying OMB Supplement regarding the adoption of these forms
OMB guidance issued December 26, 2013 on Uniform Administrative requirements, cost
principals and audit requirements for federal awards, final rule is being rolled out to
federal programs during 2014. Will this affect future reporting issues for tribal programs
or allow further flexibility in reporting?
Carryover Fund Reporting – instructions are confusing. It is our interpretation that Tribes
will be required to do two financial reports BUT not two statistical or narrative reports in
a final “closeout” report for a 3‐year plan period – is this correct?
9
Response
We will clarify the timeline taking into
consideration that tribes need to prepare for
the new forms.
We plan to provide training.
Noted.
The modification to the supplement will include
the new forms. A draft will be shared with the
workgroup.
This will be addressed in 477 training and
technical assistance.
File Type | application/pdf |
File Title | Microsoft Word - 477 Compilation of Comments and Proposed Responses_FOR PUBLIC POSTING |
Author | elizabeth.appel |
File Modified | 2014-09-26 |
File Created | 2014-09-26 |