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Question of the month:
Who is required to file a FFATA report in FSRS?

The FFATA Sub-award Reporting System (FSRS) will collect data from Federal prime awardees on sub-awards they make: a prime grant awardee will be required to report on its sub-grants and a prime contract awardee will be required to report on its sub-contracts.

(Effective October 1, 2015, the Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics Administration (NASA) are issuing FAR Case 2014-022 as a final rule amending the Federal Acquisition Regulation (FAR) to implement the inflation adjustment of acquisition-related dollar thresholds.)

CONTRACTS
In accordance with Federal Acquisition Regulation clause 52.204-10 (Reporting Executive Compensation and First-Tier Sub-contract Awards), Prime Contractors awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any sub-contract greater than $30,000. This reporting requirement will be phased-in (see below):

Phase 1: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $20,000,000, reporting started July 8, 2010.

Phase 2: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $550,000, reporting started October 1, 2010.

Phase 3: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $25,000, reporting starts March 1, 2011.

Phase 4: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $30,000, reporting starts October 1, 2015.

Although the requirement to report sub-awards is being phased-in at certain dollar levels, if you would like to start reporting prior to the start date for your sub-contracts, the system is available to you for reporting.

GRANTS
In accordance with 2 CFR Chapter 1, Part 170 REPORTING SUB-AWARD AND EXECUTIVE COMPENSATION INFORMATION, Prime Awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $25,000. The reporting requirements are as follows:

  1. This requirement is for both mandatory and discretionary grants awarded on or after October 1, 2010.
  2. All sub-award information must be reported by the prime awardee.
  3. For those new Federal grants as of October 1, 2010, if the initial award is equal to or over $25,000, reporting of sub-award and executive compensation data is required.
  4. If the initial award is below $25,000 but subsequent grant modifications result in a total award equal to or over $25,000, the award will be subject to the reporting requirements, as of the date the award exceeds $25,000.
  5. If the initial award equals or exceeds $25,000 but funding is subsequently de-obligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.

October 29th, 2010

Please click on the question to review the answer.

General

Q. What is the Transparency Act?

A. The Federal Funding Accountability and Transparency Act (FFATA or Transparency Act – P.L.109-282, as amended by section 6202(a) of P.L. 110-252) requires the Office of Management and Budget (OMB) to maintain a single, searchable website that contains information on all Federal spending awards. That site is www.USAspending.gov.

Q. What is required to be reported as part of the Transparency Act?

A. FFATA prescribes specific pieces of information to be reported:

1. The following data about sub-awards greater than $25K

  1. Name of entity receiving award
  2. Amount of award
  3. Funding agency
  4. NAICS code for contracts / CFDA program number for grants
  5. Program source
  6. Award title descriptive of the purpose of the funding action
  7. Location of the entity (including congressional district)
  8. Place of performance (including congressional district)
  9. Unique identifier of the entity and its parent; and
  10. Total compensation and names of top five executives (same thresholds as for primes)

2. The Total Compensation and Names of the top five executives if:

  1. More than 80% of annual gross revenues from the Federal government, and those revenues are greater than $25M annually and
  2. Compensation information is not already available through reporting to the SEC.

Classified information is exempt from the prime and sub-award reporting requirement as are contracts with individuals.

Definitions for data elements may be found beginning October 1, 2010 at the data dictionaries maintained on www.USAspending.gov.

Q. What is a sub-award?

A. The Office of Management & Budget issued guidance identifying the requirement to report first-tier sub-awards on April 6, 2010 and that guidance may be found at the OMB Open Government site at http://www.whitehouse.gov/omb/open. That guidance defines a sub-award as generally referring to a monetary award made as a result of a Federal award to a grant recipient or contractor to a sub-recipient or sub-contractor respectively.

Q. Why is sub-award information being collected?

A. The Federal Funding Accountability and Transparency Act (Transparency Act) requires OMB to “ensure the existence and operation of a single searchable website” for Federal awards. The Transparency Act’s definition of “Federal awards” included not only prime awards for grants, cooperative agreements, loans, and contracts, but also included sub-grants and sub-contracts. The guidance issued today will begin the process by which we will be able to further implement the Transparency Act and enhance the transparency of federal spending.

Q. Federal agencies already report prime award(ee) information to www.USAspending.gov.. Are there new reporting requirements for Federal agencies under FFATA?

A. No. There are no new Federal agency reporting requirements, beyond those already required by the Office of Management and Budget (OMB) Memorandum M-09-19 for grant making agencies. OMB M-09-19 strongly encourages Federal agencies to ensure the accuracy and data quality of the prime award information they report. For Federal agencies awarding contracts, the reporting requirements are governed by the Federal Acquisition Regulation (FAR) Subpart 4.14–Reporting Executive Compensation and First-Tier Subcontract Awards.

Q. Who will be required to report executive compensation and sub-award information associated with these Federal contracts and grants?

A. A prime grant awardee will be required to report its sub-grants and a prime contract awardee will be required to report its sub-contracts.

Q. Who is considered a Prime Awardee?

A. Both Prime Contractors and Grants Recipients are considered “Prime Awardees” when registering in FSRS.

Q. How will these prime awardees report this information?

A. Prime awardees will report using the FFATA Sub-award Reporting System (FSRS). The tool will pre-populate, to the maximum extent possible, recipient information from existing Federal agency databases, such as the System for Award Management (SAM), to reduce the burden associated with this new FFATA reporting. All Federal contractors and prime grant recipients are required to register in SAM.

User guides, FAQs, and an on-line demonstration are currently available at the FSRS website (www.fsrs.gov) for the contract sub-award reporting capability. Grant sub-award reporting user guides, FAQs, and an on-line demonstration will be incorporated into FSRS on October 29, 2010.

OMB is planning to issue additional guidance to agencies to provide more instructions for financial assistance reporting requirements.

Q. How much time does a prime awardee have to report executive compensation or sub-award information?

A. The prime recipient will have until the end of the month plus one additional month after an award or sub-award is obligated to fulfill the reporting requirement. For example, if a sub-award was made on October 15, 2010, the prime recipient has until November 30, 2010 to report the sub-award information.

Q. For ARRA-funded Federal contracts and/or grants covered under this FFATA sub-award reporting requirement, will reporting be required to both FederalReporting.gov and FSRS?

A. For ARRA-funded Federal contracts that are subject to FFATA reporting, the prime recipient will be required to report the ARRA-funded Federal contracts to both FederalReporting.gov and FSRS if the contract so requires.

For ARRA-funded Federal grants that are subject to FFATA reporting, the prime recipient will not be required to report the ARRA-funded Federal grants to both FederalReporting.gov and FSRS. ARRA-funded grants will continue to be reported to FedReporting.gov only and non-ARRA funded grants will be reported to FSRS only.

Q. What guidance or other documents implement these FFATA reporting requirements?

A. The Office of Management & Budget has issued guidance related to Open Government and Transparency to include an April 6, 2010 memo requiring the reporting of first-tier sub-awards. The guidance may be found at the OMB Open Government site at http://www.whitehouse.gov/omb/open.

The Office of Management & Budget issued guidance containing specific instructions on the sub-award reporting on August 27, 2010. The guidance may be found at the OMB Open Government site at http://www.whitehouse.gov/omb/open.

On July 8, 2010, an interim FAR Rule with request for comments was published that contains information on the FFATA reporting requirements for Federal contracts. Comments were due by September 7, 2010.

PRA information collections regarding sub-award and executive compensation reporting requirements for grants and SAM registration for prime grantees was published on July 23, 2010.

Q. What SAM information can the awardee change in their profile? Will the user also have to make these changes in SAM as well?

A. The awardee cannot change any SAM information within FSRS. They will need to make the changes in SAM, then the data in FSRS will update based on the SAM feed.

Q. What if the Recipient location/project place of performance is outside of the United States? Do the required address fields, including Zip Code+4 field, turn off or otherwise accommodate data entry for non-domestic addresses?

A. FSRS is able to accept foreign recipient locations and/or project place of performance. When completing an editable location field, the prime awardee selects “Non-US” from the State drop down menu. When Non-US is selected for State, then a non-United States country must be selected and the zip code field and the Congressional District become optional.

Q. Will there be any language support for Foreign Grantees?

A. No. Foreign language support is not part of the system requirements.

Q. You said data was coming over from FPDS for contracts and from USAspending for grants. Which FPDS dollar value field is being used to determine the proper reporting threshold for contracts, and which dollar value field from the FAADS Plus reporting format are being used to determine the proper reporting threshold for Grants?

A. FSRS uses the “Award Amount” (formerly “Total Dollars Obligated”) field value from FPDS to determine if prime contract data meets the FFATA reporting threshold. FSRS uses an aggregated award amount calculated by Federal Award Identifier Number (FAIN) in USAspending represented as the Total Fed Funding Amount (Sum of Federal funding amount of base and all modifications).

Q. Under compensation, if the organization is a state entity or university, who do they enter into the system as the top five executives?

A. The Transparency Act requires a prime awardee to provide, for their DUNS number and the DUNS number of their sub-awardee(s), the names and total compensation of the five most highly compensated officers of the entity if the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $25,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See FFATA § 2(b)(1).

Q. Does the system automatically update or do you need to exit the system to see…

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