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Business and Policy Areas
Business and Policy Areas

Recovery Act Reporting Requirements for FWS Still Undefined

October 2, 2009

UPDATED: The Department of Education released temporizing guidance on October 2 on American Recovery and Reinvestment Act (ARRA) reporting for the Federal Work-Study program. ED is sending an email to financial aid directors with the electronic announcement. Notably, the announcement does not provide any guidance about how institutions are to report on the FWS program, but promises to provide detailed instructions by October 9.

Information is provided on registering at, reiterating the October 10 deadline to register and noting that the system will allow more than one registration per institution. NACUBO urges members to communicate with your financial aid director to coordinate ARRA reporting for FWS to avoid confusion and duplication of effort.

The announcement also noted that institutions would have additional time beyond the October 10 deadline for the first quarter ARRA reports to provide FWS data. The system will remain open for these reports until October 21.

An announcement last week had informed institutions that they needed to comply with ARRA reporting requirements if they received $25,000 or more in FWS funds from ARRA. That announcement included a list of affected institutions and their FWS funding allocations.

From September 28, 2009:

Colleges and universities are awaiting guidance on how to report on Federal Work Study (FWS) expenditures attributable to the American Recovery and Reinvestment Act (ARRA) after last- minute changes added FWS to the list of reportable programs. As a first step, affected institutions must register by October 10.

ARRA provided an additional $200 million for the FWS program. In August 2009, the Office of Management and Budget (OMB) added FWS to the list of programs subject to Use of Funds Reporting (Section 1512) under ARRA. (Earlier guidance had indicated that no special reporting would be required for Pell Grant or FWS funds.) On September 24, the Department of Education informed approximately1800 institutions, by email, that they had received more than the $25,000 threshold in ARRA funds for FWS and were subject to ARRA reporting requirements. As a first step, these institutions must register by October 10 at An institution may only register once, and those with other stimulus funds may have already registered.

On the same date as the email, an electronic announcement from ED clarified that additional ARRA-related FWS funds are for the 2009-2010 award year and attached an excel spreadsheet that lists all affected institutions. The spreadsheet lists each institution's FWS funding for the 2009-2010 award year and the portion attributable to ARRA. ED has promised to provide a follow-up email with guidance on how to estimate the number of FWS jobs created or retained and instructions on how to submit the quarterly report required for the FWS program. In general, the first reports on use of ARRA funds are due October 10.

Institutions should note that these announcements do not change information provided in the June 2009 A-133 (Single Audit) Compliance Supplement. Because the ARRA-related FWS funds are for the 2009-2010 award year, information provided on page 5-4-1 of the Compliance Supplement continues to be authoritative for FWS for the 2008-2009 award year. 


Sue Menditto
Director, Accounting Policy