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An alternative calculation based on the allocable and allowable portion of activities expressed as <br />a percentage of the total is acceptable for recipients of assistance agreements that must comply <br />with OMB Circular A -21, Cost Principles for Educational Institutions. OMB Circular A -21 <br />recognizes that practices vary among educational institutions as to the activity constituting a full <br />workload. Compensation charged to sponsored projects must conform to the institution's <br />established policies and reasonably reflect the activity for which the employee is compensated. <br />Charges to sponsored projects may be expressed as a percentage of their total activities. <br />Therefore, for purposes of ARRA reporting of jobs created or retained, colleges and university <br />may count, proportionately, the percentage of effort directly charged to ARRA awards as an FTE <br />equivalent. <br />For example - A faculty member charging 50% effort on an ARRA award will be counted as .5 <br />FTE. Hourly and part time employees shall be calculated based on actual hours worked on the <br />sponsored agreement and the institution's definition of a full workload for employment. <br />The total hours reported may include paid leave. <br />5.4 How should recipients estimate the job impact of funding provided to sub - <br />recipients? <br />Recipients must include an estimate of jobs created and retained on projects and activities <br />managed by their funding recipients in their aggregate number and their narrative description. <br />This information will be provided for each project and activity funded by the Recovery Act. The <br />clarification that recipients must report jobs estimates for all sub - awarded funds is an update <br />from previous guidance. <br />For example, consider a prime recipient that receives a $10 million grant from a Federal agency <br />for a specific project or activity. Assume the prime recipient hires five FTE to administer the <br />program at a total cost of $1 million, and distributes nine $1 million grants to sub - recipients. In <br />this case, the prime recipient will report the direct job creation of 5 FTE, and would also provide <br />an estimate of the total employment impact of the nine $1 million grants (using the same FTE <br />methodology discussed in 5.3). <br />Prime recipients are required to generate estimates of job impact by directly collecting specific <br />data from sub - recipients and vendors 13 on the total FTE resulting from a sub - award. To the <br />maximum extent practicable, information should be collected from all sub - recipients and vendors <br />in order to generate the most comprehensive and complete job impact numbers available. <br />However, in limited circumstances, the prime recipient can employ an approved statistical <br />methodology to generate estimates of job impact, thereby collecting data from a smaller subset <br />of sub - recipients and vendors in order to extrapolate an estimate of job impacts to all applicable <br />sub - recipients and vendors. A statistical methodology should only be employed in those cases <br />13 Job estimates regarding vendors of prime- or sub - recipients, should be limited to direct job impacts for the vendor <br />and not include "indirect" or "induced" jobs (see Section 5.2), e.g., hiring /retaining employees for infrastructure <br />projects. <br />36 <br />