The Federal Funding Accountability and Transparency Act of 2006 (FFATA) and subsequent 2008 amendments (see section 6202(a)) is setting into motion a required federal award reporting process that is very similar to the reporting required by the Recovery Act. However, FFATA reporting extends to all non-Recovery Act federal awards, including grants and sub-grants; and federal contracts and sub-contracts. The new reporting is required to be made into the FFATA Subaward Reporting System (FSRS), which can be accessed by clicking here.

This new reporting requirement is already effective. Additionally, it is likely that this new reporting requirement will have to be considered as part of your future single audits as we expect the OMB to include related audit procedures in the 2011 Compliance Supplement as part of the compliance requirements related to reporting.

In the meantime, here are some details to consider:

• Beginning October 1, 2010, prime grant awardees (i.e., direct recipients) of federal grants of $25,000 or more must report information on associated “first-tier” sub-grants (amounts passed through to subrecipients) of $25,000 or more. Such information must be reported by the end of the month following the month the subaward or obligation was made. For example, for a subaward made on November 1, 2010, the reporting would be due by December 31, 2010.                                 
• Similarly, prime contract awardees of federal contracts of $25,000 or more must report associated first-tier sub-contracts of $25,000 or more, phasing in as follows:
  • Phase 1: Reporting first-tier sub-contracts of prime awards valued greater than $20 million (July 2010
  • Phase 2: Reporting first-tier sub-contracts of prime awards valued greater than $550,000 (October 1, 2010)
  • Phase 3: Reporting first-tier sub-contracts of prime awards valued at $25,000 or more (March 1, 2011)
•  The following are among the information that needs to be reported:
  • Name of entity receiving award
  • Amount of award (obligated amount)
  • Funding agency
  • NAICS code for contracts/CFDA program number for grants
  • Program source
  • Award title descriptive of the purpose of the funding action
  •  Location of the entity (including congressional district)
  •  Place of performance (including congressional district)
  •  Unique identifier of the entity and its parent; and
  •  Total compensation and names of top five executives (prime or subawardee) – with certain exceptions similar to those provided for Recovery Act reporting.
• The USASpending.gov web site includes a page with a number of related resources accessible by clicking here. The following are several useful links included on that page to assist you in learning more about FFATA and its requirements.
  • Click here to access a series of webinars presented by the General Services Administration.
  • Click here to access a slide presentation that explains more about who reports and how.
  • Click here to access a Question and Answer document titled, Transparency Act – Executive Compensation & Subaward Reporting Information.
  • Click here to access an OMB Memorandum dated August 27, 2010 titled, Open Government Directive – Federal Spending Transparency and Subaward and Compensation Data Reporting.