All prime recipients of American Recovery and Reinvestment Act of 2009 (Recovery Act) funds received from the Office of Justice Programs (OJP) and Office on Violence Against Women (OVW) must comprehensively count and report the total number and types of jobs created and retained as a result of that funding to www.federalreporting.gov on a quarterly basis. In very limited circumstances, OJP or OVW and the Office of Management and Budget (OMB) may approve the use of statistical methods to estimate job creation and retention for some prime recipients that prove that comprehensively counting created and retained jobs will be overly costly or burdensome. The following Frequently Asked Questions (FAQ) describe when statistical methods may be approved to estimate created and retained jobs and how to request approval to use these methods.
All data reported by Recovery Act prime recipients and subrecipients to OJP, OVW, OMB, and www.federalreporting.gov must be actual counts except, in limited cases and with OJP or OVW and OMB approval, the number and types of jobs created and retained. Additional guidance regarding the calculation and estimation of jobs created and retained is outlined in OMB M-09-21, sections 5.2 through 5.4.2
OJP and OVW expect recipients to collect job creation and retention counts directly; however, OJP or OVW may, in coordination with OMB, approve requests to statistically estimate job counts in cases where recipients demonstrate that comprehensive job counts will create an unreasonable burden and disrupt the recipient's ability to effectively implement the underlying mission of the program. However, because it is important to have accurate counts of the number of jobs created and retained by Recovery Act programs, OJP, OVW, and OMB will only approve the use of statistical estimates for reporting job counts in exceptional cases. As recipients must collect and report all other required data for the Recovery Act directly, job counts are not expected to burden recipients excessively.
Recipients should request to statistically estimate the number of jobs created/retained for subrecipients and vendors through the Grant Adjustment Notices (GAN) module of the Grant Management System (GMS). Recipients should select "Program Office Approvals" as the GAN type, select "other" as the Approval Type, and enter the written request.
Recipients must submit their request to use a statistical methodology at least 30 days before the end of the first reporting period for which they would like to use statistical methodology and must submit a separate request for each award. Only one approval is required, per award, for the duration of the grant unless there are changes to the methodology or personnel carrying out the methodology.
Prime recipients that request permission to estimate jobs created and retained using a statistical methodology must include the following in their GAN request:
The justification should include detailed estimates of the costs and burdens associated with direct collection of job creation and retention counts from sub-recipients and vendors, including the number of subrecipients and vendors, the number of subrecipients and vendors creating and retaining jobs, a thorough description of the practical difficulties or obstacles to collecting job creation and retention counts from subrecipients and vendors, and any other information deemed relevant to OJP's or OVW's consideration of the request.
The technical description must include a detailed plan for developing survey-based estimates of jobs created and retained. It must explain how the plan will result in reliable estimates of the number and types of jobs created and retained; examine the internal and external validity of data on which jobs estimates will be based; and include a description of how the recipient will address nonresponse, selection bias, and estimate robustness to alternative specifications.(1)
In its proposal, the recipient must demonstrate that the proposed methodology will be implemented by or under the supervision of a qualified statistician or highly experienced social science researcher.
In addition to the job creation and retention count estimates, the initial progress report submitted to OJP or OVW must include full documentation of all estimation methods employed as well as all data utilized by the models. This will help OJP or OVW ensure objectivity, utility, transparency, and reproducibility of the estimates and projections reported by the recipient. OJP and OVW will archive data and models so that the estimates can be independently reproduced and verified.