Title: Federal Funding Accountability and Transparency Act (FFATA or Transparency Act)
1Federal Funding Accountability and Transparency
Act(FFATA or Transparency Act)
- Dennis J Paffrath
- Assistant Vice President for Sponsored Programs
Administration
2What 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.
3Why?
- 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.
4What Information needs to be entered?
Information about prime award/ee Pre-populated by feds if available Information about prime award/ee Pre-populated by feds if available 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)
5What Information needs to be entered?
Information about sub-award/ee Pre-populated by feds if available Information about sub-award/ee Pre-populated by feds if available 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)
6What information needs to be entered?
Contract Reporting Elements-prime award Contract Reporting Elements-prime award 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 (zip4) 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
7More information
Contract Reporting Elements Contract Reporting Elements Contract Reporting Elements
21 Subcontractor place of performance address zip4 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
8What 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.
9DUNS 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.
10How 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
11What is FSRS?
12FSRS.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.
13Other 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
14Worklists 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
15Worklists
16Worklists
- 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.
17FFATA 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
18Sanctions 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?
19UMB Process
- Coeus
- PeopleSoft
- Individual Reports (short term)
- XML (future processes)
20UMB Process-Coeus
21Coeus Organization Table
22UMB 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
Governors office.
23UMB 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
24UMB Process Batch Process
25Questions 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?
26Additional 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?
27Happy 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