FFATA – Town Hall Meeting

Kim Linkous, CRADirector of Post Award

Office of Sponsored ProgramsVirginia Tech540-231-9372

linkousk@vt.edu

FFATA Objectives For Open Discussion

FFATA

What and Why

• Federal Funding Accountability and Transparency Act• Provides public information on Federal award spending via one

searchable website (USAspending.gov)

(FFATA or Transparency Act - P.L.109-282, as amended by section 6202(a) of P.L. 110-252Federal Acquisition Regulation clause 52.204-10

Who

• Prime recipients of federal funding with first-tier subawards > $25K– A sub-award is a monetary award, made as a result of a

Federal award to a grant recipient or contractor, to a sub-recipient or sub-contractor

– “a sub-recipient relationship exists when funding from a pass-through entity is provided to perform a portion of the scope of work or objectives of the pass-through entity’s award agreement with the…awarding agency.” (OMB Circular A-133 Compliance Supplement)

Distributing to Public

• Federal government uploads prime award information for Federal awards >$25K

• Prime recipient uploads required elements into FFATA Subaward Reporting System (FSRS)

• Public searches USAspending.gov

Government Prime Recipient Taxpayer

When is FFATA applicable?

• Federal contracts, cooperative agreements and grants with first-tier subawards > $25K

• Subaward originally awarded for < $25K, supplemental increase brings cumulative amount > $25K, begin reporting

• Does NOT include awards made by a first-tier sub-recipient to a lower tier sub-recipient

When is FFATA Not Applicable

• Recovery Act awards• Awards to individuals• Recipients that had a gross income of

$300,000 or less in their previous tax year• Classified information

Required Information• Name of entity receiving

award• Amount of award• Funding agency• NAIC code for

contracts/CFDA program number for grants

• Program source• Award title descriptive of

the purpose of the funding action

• Location of entity (including Congressional district)

• Place of performance (including Congressional district)

• Prime award number and subaward number

• If applicable, total compensation and name of top executives (prime and subawards) if applicable

When is Executive Compensation Required?

• 80% or more annual gross revenues in Federal awards and those revenues are greater than $25 million annually and the public does not have access to information about the compensation of their senior executives of the entity through periodic reports to SEC

Where to report?• Prime awardees will report using the FFATA

Subaward Reporting System (FSRS)• Pre-populates, to the maximum extent

possible, recipient information from existing Federal agency databases, such as the Systems for Award Management (SAM)

• All Federal contractors and prime grant recipients are required to register in SAM

ResponsibilitiesWho What How

Funding Government Agency

• Prime award information for Federal awards $25K or more

• FPDS-NG for contracts• FAADS-PLUS file

submission to USAspending.gov for grants

Prime Awardee • Prime award information• Executive compensation• First-tier subawards of $25K or

more

• SAM• SAM• FSRS

Sub-recipient • Register for DUNS Number• Provide required entity

information, including executive compensation responses to prime awardee

• Dun & Bradstreet

Are there deadlines for FFATA reporting?

• Government must report within 30 days of award

• The prime recipient will have until the end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement

• October 15, 2012 subaward issued, the prime recipient has until November 30, 2012 to report the subaward information

What is SAM?

• Government recently consolidated the following websites– Contractor Registration (CCR)/Federal Agency

Registration (FedReg)– Online Representations and Certifications

Application (ORCA)– Excluded Parties List System (EPLS)

• FSRS is expected to be included in the next phase

Successes and Challenges