Federal Funding Accountability and
Transparency Act
(FFATA or Transparency Act)
Dennis J Paffrath
Assistant Vice President for Sponsored
Programs Administration
What is it?
• 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.
Why?
• 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 subgrants and sub-contracts.
What Information needs to be entered?
#
Information about prime award/ee Pre-populated by feds if available
1
Federal Award ID No. “FAIN”
9
Principal place of performance address
2
Fed Agency Name
10
CFDA program number and program title
3
Prime Awardee DUNS# (must match CCR)
11
Project Description
4
DUNS plus 4 (if more than one EFT account
for one location)
12
Total Federal Funding Amount
5
Awardee Name (must match CCR)
13
Obligation/Action date of prime award (date
award signed)
6
Awardee “Doing-Business-As” Name (must
match CCR)
14
Sub-award Date
7
Awardee Address (must match CCR)
15
Top 5 highly compensated officials (names
and compensation)
8
Awardee PARENT DUNS No. (must match
CCR)
16
Date of Report Submission (auto-completed
by system)
What Information needs to be entered?
#
Information about sub-award/ee Pre-populated by feds if available
1
Subawardee DUNS number
8
Subaward Obligation/Action Date
2
Subawardee DUNS number +4 (if
more than one EFT account for one
location)
9
CFDA Program Number and Program
Title
3
Subawardee Name (must match CCR) 10
Federal Agency Name
4
Subawardee “Doing-Business-As”
DBA Name (must match CCR)
11
Subawardee Principal Place of
Performance (Zip + Cong. Dist.)
5
Subawardee Address (must match
CCR)
12
Subaward Number assigned by
Prime Awardee
6
Subawardee Parent DUNS Number
(must match CCR)
13
Names and Compensation of 5
Highly Compensated Officers
7
Amount of Subaward
14
Subaward Project Description
(Award Title and description 4000
characters)
What information needs to be entered?
Contract Reporting Elements-prime award
1
ID # from FSRS used when
resubmitting/modifying and existing
report record
11 Contracting Agency ID and Name
2
Contract #
12 Contracting Officer ID and Name
3
IDV Reference
13 Funding Agency ID and Name
4
Subcontract Award Month and Year
14 Treasury Symbol
5
Prime Contractor DUNS #
15 NAICS Code
6
Company Name
16 Date Signed (Prime Contract)
7
Company Address (zip +4)
17 Program Title
8
Prime Contractor Place of
Performance Address (zip+4)
18 Top 10 Compensated Questions for
Prime Contractor
9
Parent DUNS #
19 Subcontractor or Vendor DUNS # and
name
10
Parent Company Name
20 Subcontractor PARENT DUNS#
More information
#
Contract Reporting Elements
21 Subcontractor place of performance
address zip+4
25
Subcontract Funding Agency ID
22 Subcontract Amount
26
Subcontractor Funding Agency ID
and Name
23 Subcontract Date
27
Subcontract overall description
(4000 characters)
24 Subcontractor NAICS Code
28
Subcontractor Top Five
Compensated -2 questions
What Federal awards are subject to the FFATA
subaward reporting requirements?
•
New contracts over $20 million, effective immediately; new contracts with a prime
contract value greater than $550,000, and new contracts with prime contract value
of $25,000 or over; and
•
New grants $25,000 and over. The grants subaward reporting functionality is now
available via www.fsrs.gov.
•
Reporting of Sub-contracts of Federal contracts and sub-grants of Federal grants
where these sub-contracts and sub-grants are $25,000 and over.
DUNS number, needed?
• Yes. In accordance with FFATA all subrecipients domestic or
foreign will be required to have a DUNS number before the
Prime Recipient can execute a subaward or subcontract.
Details on how to register and acquire a DUNS number is
available at http://fedgov.dnb.com/webform.
• While not mandated by FFATA, the University of Maryland,
Baltimore is recommending to all subrecipients that it might
be to their benefit to also register with the Central Contractor
Registry (CCR). Details on how to register are available at
https://www.bpn.gov/ccr/default.aspx.
How will it be collected?
FFATA Sub-award Reporting System (FSRS)
• July 2010, FSRS.gov was launched as the resource for
prime awardees to report FFATA-required contract
sub-award activity and executive compensation.
• October 2010, FSRS.gov expanded to incorporate
FFATA-required grant sub-award and executive
compensation reporting
What is FSRS?
FSRS.gov
• Only prime award recipients submit FFATA
reports in this system.
• Reports can be submitted individually or
through a Batch Upload.
• To ensure consistency between FSRS.gov and
other government systems, the FSRS.gov
system is designed to pull in data from other
feed systems.
Other Feed Systems
• The primary source of data for grants is
FAADS+ - This is the Federal Assistance Award
Data System maintained by the US Bureau of
Census
• The primary source of data for contracts is
FPDS-NG – This is the Federal Procurement
Data System – Next Generation and is
maintained by USA.gov
Worklists within FSRS.gov
• The main navigation that allows prime
awardees to organize their awards for which
they have reporting responsibility. The user
can search for and add awards (both contracts
and grants awarded to their registered DUNS
number).
• Three sections: My Worklist, Contracts Not
Added and Grant Awards Not Added
Worklists
Worklists
• Under “My Worklists” you will create your
individual reports and then have the ability to
review these reports when they are draft and
submitted status.
FFATA reports
• Each report will have a workflow consisting of:
–
–
–
–
–
–
–
Instructions
Enter Contract/Grant #
Contract/Grant Details
Prime Award Details
Sub-awardee Data
Review
Submit report
Sanctions for not complying!
• All of the same sanctions as you might receive for
any other non-compliance with award requirements
and/or guidelines. So….Audit Findings???
• Disallowances of Expenditures for subs not reported
on?
• Breach of contract claims?
• Loss or Revocation of award?
• Significant Non-compliance requiring some sort of
oversight plan by the sponsoring agency?
UMB Process
•
•
•
•
Coeus
PeopleSoft
Individual Reports (short term)
XML (future processes)
UMB Process-Coeus
Coeus Organization Table
UMB Process-PeopleSoft (eUMB)
• Pulls in all data from all electronic systems on
campus
– Coeus (subcontact module)
– eUMB (financials)
• Creates an XML for uploading
• Previously used to create all ARRA reports and
submitted successfully to the State of
Maryland Governor’s office.
UMB Process – Individual Reports
• FSRS.gov
– One FTE within SPA/ORD will pull the report from
Coeus
– Review the data in the report to make sure all of
the data is captured and accurate
– Upload the data manually into each report that is
required
– Provide report completion a monthly basis to
AVP,SPA and VP, Researdch and Development
UMB Process – Batch Process
Questions to ask?
• Will you handle the reporting out of central administration or
require Pis and/or their staff to do the reporting?
• Are you getting additional staff resources to accomplish the
reporting, or are you absorbing the workload with available
staff?
• Is your volume small enough that the manual reporting
mechanism will work for you or will you have to build a
centralized data repositories and batch-feed mechanisms to
allow for the high volume reporting on a monthly basis?
• Are you collecting information about your sub-recipients
necessary to complete the reports?
Additional Questions?
• How will each of our individual solutions affect each other as
we collaborate with each other?
• Do you already separately identify Grants from FAR contracts
in your system?
• Are you prepared to report Vendor data elements on your FAR
contracts?
• Are your vendors and sub-recipients registered in CCR? Do
they have DUNS #s?
• What happens when OMB turns on 2nd and 3rd tier sub
reporting requirements?
Happy News!
• Volume is light now but will increase over time.
• It seems OMB and GSA are willing to listen and
respond
• Auto-fill is a “miracle”
• Very few will have to report “top five compensated”
• Opportunity to team with other institutionals offices
(IT)
• Job Security, Job Security, Job Security