Given the large influx of Recovery Act funds that LEAs and IHEs are receiving, the Administration has stated its intention to ensure that federal agencies provide information to the public that is transparent and useful. Further, the Act contains numerous provisions to increase transparency and accountability. For example, under section 1512 of the Act, recipients of funds are required to report certain information quarterly. In addition, the Act created the Recovery Board and required it to establish and maintain a user-friendly, publicly available Web site (Recovery.gov) to foster greater accountability and transparency in the use of Recovery Act funds. The Act directs that the Web site function as a gateway to key information relating to the Recovery Act and provide links to other government Web sites with related information. The information that is provided by recipients in accordance with the reporting requirements under section 1512 is made available to the public on Recovery.gov. The Act created broad requirements for recipient reporting. Specifically, the Act requires, among other types of information, that recipients report the total amount of Recovery Act funds received, associated obligations and expenditures, and a detailed list of the projects or activities supported by Recovery Act funds. For each project or activity, the detailed list must include the name and description of the project or activity, an evaluation of its completion status, and an estimate of the number of jobs created and the number of jobs retained through that project or activity. The prime recipient, which for these education programs is the state, is responsible for the reporting of all data required by section 1512 of the Recovery Act. To implement recipient reporting requirements, OMB worked with the Recovery Board to deploy a nationwide system for collecting data submitted by the recipients of funds. One of the functions of the Recovery Board was to establish a Web site and to publish a variety of data, including recipient data once it has been reviewed by the relevant federal agencies. These data, collected through www.FederalReporting.gov, are made available to the public for viewing and downloading on www.Recovery.gov. The Recovery Act set a demanding schedule for implementing Recovery.gov, requiring the Recovery Board to establish the Web site within 30 days of the law’s enactment. The Recovery Board’s goals for this Web site are to promote accountability by providing a platform to analyze Recovery Act data and to serve as a means of detecting fraud, waste, and abuse by providing the public with accurate, user-friendly information. Recipients are required to submit their section 1512 reports within 10 days of the end of each quarter. Federal agencies then review the reports for significant errors and missing information, and as required by law, make them available on Recovery.gov within 30 days of the end of each quarter. For the programs discussed in this report, information was submitted by recipients for the quarter ending March 31, 2010 and posted on Recovery.gov on April 30, 2010. OMB provided recipients guidance through memorandums, supplemental materials, and reporting instructions. Specifically, starting for the period ending September 30, 2009 (and repeated for the quarters ending December 31, and March 31), OMB’s reporting instructions specified that recipients must provide, among other things, the project name, which should be brief and descriptive; a project description that captures the overall purpose of the award, quarterly activities, and expected outputs and outcomes or results; an award description that describes the overall purpose, expected outputs, and outcomes or results of the award, including significant deliverables and, if appropriate, units of measure; a jobs created description that captures the types of jobs created or the project status, which was specified as not started, less than 50 percent complete, completed 50 percent or more, or complete; an activity description, which categorizes projects and activities; the amount of the award; and the primary place of performance, which is the physical location of award activities. Four of these fields—project name, description of jobs created, quarterly activities/project description, and award description—are narrative fields. In its December 2009 guidance to heads of executive departments and agencies, OMB stated that the narrative information must be sufficiently clear to facilitate the general public’s understanding of how Recovery Act funds are being used. As we reported in our May 2010 transparency report, OMB provided guidance that required general information that could be applied broadly across a wide range of recipients. OMB defined narrative fields to solicit high-level information that is not specific to a single program. OMB officials also told us the agency created generic reporting guidance that would provide basic guidance for recipient reporting and that individual agencies could provide supplemental guidance—that was more specific to their program characteristics—if the agency considered additional guidance necessary. Detailed information on how subrecipients are spending their Recovery Act funds is limited, in part because data collection for Recovery.gov, through FederalReporting.gov, does not provide specific narrative fields for collecting information on how each subrecipient is using its funds. Because OMB and Education guidance instructs prime recipients to include information about subrecipients in the information they report on FederalReporting.gov, a state is required to report information that captures the overall purpose of the award, including how subrecipients have used the funds. Information required about each subrecipient is limited to basic information, such as award amounts and place of performance. Our May 2010 report notes that this practice is not consistent with the requirement in the Act to report a detailed list of all projects and activities, each having its own name, description, completion status, and potential outcomes. In addition, we reported that requiring information on status, outcomes, or other items without information on subrecipient activities may convey an incomplete impression of how funds are being used. Furthermore, FederalReporting.gov restricts the amount of information prime recipients can report. Prime recipients are allowed to input up to 4,000 characters for each narrative field. While this limitation may not affect grants that provide funds for limited projects and activities, some states have thousands of subrecipients for each of these three education grants. For example, California’s SFSF grant has over 1,500 subrecipients. Providing detailed information on how each subrecipient is using the funds within the character limitation would be extremely challenging, if not impossible for some states. Because of these complexities, OMB officials allowed individual federal agencies to provide program-specific guidance that was tailored to the awards made under their programs, if the agency determined such guidance was necessary. They noted, however, that while information on subrecipient activities and fund uses may not be specifically included on Recovery.gov, the information included in the prime recipient reports should, as a whole, represent the entire grant, including subrecipient information. They told us that they will continue to evaluate and update guidance on Recovery Act reporting requirements, but that they do not have plans to require more information on subrecipients. The officials emphasized the need to balance transparency with the burden of recipient reporting. Education developed guidance and tip sheets with suggested text for recipients to use when reporting on Recovery Act funds. Education officials reported they provided this information to recipients to ease the burden of Recovery Act reporting. For example, each prime recipient is required to submit information each quarter for over 60 data elements for each Recovery Act grant it receives. Since the Act funded multiple formula grants to states, many were required to submit as many as nine reports totaling up to approximately 540 required data elements. Several state officials told us that including subrecipient information in their reporting required additional resources and time. For example, Colorado officials told us that summarizing information from nearly 300 separate subrecipient reports was their biggest challenge in compiling and reporting on the data required by section 1512. In its tip sheets, Education provided suggested standard language that recipients could use when reporting on three of the four narrative fields. Education officials told us they provided the language for the project name, award description, and quarterly activities/project description fields in order to balance the reporting burden with transparency by providing information on the grants without requiring each recipient to develop its own information. The only narrative field without this language was the description of jobs created. Officials told us that information in the description of jobs created field needed to be individualized for each grant and therefore standard language would not be appropriate for that field. Education’s guidance and tip sheets—including the suggested standard language—were reviewed and approved by OMB. For each of the three programs we reviewed, the standard language for two of the narrative fields in the recipient reports—award description and quarterly activities/project description—is worded almost exactly the same. By using the suggested text for both the award description and quarterly activities/project description narrative fields, recipients duplicate the generic information and lose an opportunity to provide information on how they are using their grant funds. For example, Education’s tip sheet for IDEA Part B instructs recipients to enter “Assist States in providing special education and related services to children with disabilities in accordance with Part B of the IDEA.” While this information does provide the public with a general description of whom the program serves (children with disabilities), and its purpose (providing special education and related services), it does not provide information on what specific activities or programs are being funded by the grant. Therefore when states use the standard language, the public cannot discern if the grant is paying for additional teachers, textbooks, installation of wheelchair accessible ramps, creating a tutoring program, providing professional development, purchasing technology, or any of the activities allowed by IDEA Part B. (See table 1 below for standard language.) We found that 9 percent of the awards for the three programs we reviewed were transparent—that is, they had sufficiently clear and understandable information on the award’s purpose, scope, location, award amount, nature of activities, outcomes, and status of work. We determined that 13 percent contained most, but not all, of this information.