FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT

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FEDERAL FUNDING
ACCOUNTABILITY AND
TRANSPARENCY ACT
(FFATA)
FFATA
• Requires information disclosure of entities receiving Federal
funding through Federal awards such as Federal contracts and
their sub-contracts and Federal grants and their sub-grants.
• Requires disclosure of executive compensation for certain
entities.
• Requires the establishment of a publicly available, searchable
website that contains information about each Federal award.
• Requires agencies to comply with OMB guidance and
instructions and assist OMB in implementation of website.
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What new reporting is
required?
• Prime contract awardees of contracts $25K or more must
report associated contract subawards.
• Data collection will be phased with all required contract
subawards reporting by March 2011 (See slide 6 for more
details.)
• Prime grant awardees of grants $25K or more must report
associated grant subawards.
• Executive compensation information for awardees.
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Who is responsible for
reporting?
• Federal Agencies must report prime award information
• Prime awardees (State of Illinois) must report subaward
information
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When does reporting begin?
• Contracts subaward (sub-contracts only) reporting
requirement will be phased in:
• Phase 1: Reporting subawards of prime awards valued greater
than $20M began in July 2010
• Phase 2: Reporting subawards of prime awards valued greater
than $550K began October 1, 2010
• Phase 3: Reporting subawards of prime awards valued at $25K or
more began March 1, 2011
• Grants subaward (sub-grants only) reporting is required for all
awards made on or after October 1, 2010 for all prime grant
awards $25K or more.
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How do I report?
• Federal Agencies must report prime grant award information
through the Federal Assistance Award Database System Plus format
(FAADS+)
• Federal Agencies must report prime contract award information
through the Federal Procurement Data System – Next Generation
(FPDS-NG)
• Prime contract and grant awardees (State of Illinois) must report
subaward information through the FFATA SubAward Reporting
Systems (FSRS)
• Prime contract and grant awardees must register with the Central
Contractor Registry (CCR)
• If required, prime contract and grant awardees must report
executive compensation through CCR
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How long do I have to report?
All awardees must report
by the end of the month
following the month the
award or obligation was
made
• For example, if an award is
made on July 10, 2010 the
awardee would have until
August 30, 2010 to report the
award – all awards made
during July will have until
August 30, 2010 to report
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Reporting Responsibility
• DHS as the prime contractor/grantee is responsible for reporting for subaward (firsttier subawardee) information such as subaward entity information, description/title,
and date of award.
• New Federal, non-Recovery Act funded grant awards with an award date on or after
October 1, 2010 and result first-tier subawards, are subject to the reporting
requirements under the Transparency Act.
• For new federal grants as of October 1, 2010, if the initial award is equal to or over
$25,000, prime awardee (DHS) must report subaward and executive compensation, if
required.
• If the initial award is below $25,000 but subsequent grant modification results in a
total award equal to or over $25,000, the award is subject to the reporting
requirements, as of the date the award exceeds $25,000.
• If the initial award amounts to or exceeds $25,000 but funding is subsequently deobligated such that the total award amount falls below $25,000, the award continues
to be subject to the reporting requirements of the Transparency Act.
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ARRA Reporting
• Grant Awards, whether existing or new, as of October 1, 2010
that are funded by the Recovery Act will continue to report
under ARRA reporting requirements through
FederalReporting.gov.
• Such Grant Awards are not subject to FFATA reporting
requirements.
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SUBAWARDS
• For grants, a “subaward” means a legal instrument to provide
support for the performance of any portion of the substantive
project or program for which you received the award and that:
The prime recipient awards to an eligible sub-recipient; or
Sub-recipient at one tier awards to a sub-recipient at the next
lower tier
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Subawardee Responsibility
• The prime grant awardee must report all information
associated with a Federal grant, either regarding executive
compensation data for the prime recipient or subawardees, or
any other information associated with subawards.
• The subawardee, however has an obligation to provide the
prime grant awardee all information required for such
reporting.
• This includes subawardee entity information, DUNS number,
subawardee parent DUNS number, if applicable, and relevant
executive compensation data, if applicable.
• If the subawardee is registered in the Central Contractor
Registry (CCR), this information may be migrated into FSRS .
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Data Reporting Requirements
The Transparency Act’s section 2(b)(1) requires:
• Name of the entity receiving the award;
• Amount of the award;
• Information on the award including transaction type, funding
agency, the North American Industry Classification System
code or Catalog of Federal Domestic Assistance number,
award title descriptive of the purpose of each funding action;
• Location of the entity receiving the award and the primary
location of performance under the award, including city, State,
congressional district, and country;
• DUNS number of the entity receiving the award and the
parent entity of the recipient, should the entity be owned by
another entity;
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Data Reporting Requirements
• 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;
Received $25 million or more in annual gross revenues from
Federal awards;
The public does not have access to this information in periodic
reports under
 Section 13(a) or 15(d) of the Securities Exchange Act of 1934, or
 Section 6104 of the Internal Revenue Code of 1986.
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Exemptions from the Act
• Existing or new grants as of October 1, 2010, that are funded
by the Recovery Act. These grants will continue to report
those awards and related subawards through
FederalReporting.gov
• Cooperative Research and Development Agreements as
defined under 15 USC 3710a;
• Federal awards to individuals who apply for or receive Federal
awards as natural persons (i.e., unrelated to any business or
non-profit organization he or she may own or operate in his or
her name);
• Federal awards to entities that had a gross income, from all
sources, of less than $300,000 in the entities’ previous tax
year.
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Information Resources
• For more information on FFATA requirements, please see the
DHS Contracts website:
http://www.dhs.state.il.us/page.aspx?item=56761
• To access the FFATA form (IL 444-0949) to be completed,
please go to:
http://www.dhs.state.il.us/OneNetLibrary/27897/documents/
Forms/IL444-0949.pdf
• To submit the completed FFATA form, please email it to
[email protected]
• For questions, please contact Steven Shaw at
[email protected]
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