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Federal Funding Accountability and Transparency Act (FFATA or Transparency Act)

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Title: Federal Funding Accountability and Transparency Act (FFATA or Transparency Act)


1
Federal Funding Accountability and Transparency
Act(FFATA or Transparency Act)
  • Dennis J Paffrath
  • Assistant Vice President for Sponsored Programs
    Administration

2
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.

3
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 sub-grants and
    sub-contracts.

4
What 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)
5
What 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)
6
What 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
7
More 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
8
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.

9
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.

10
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

11
What is FSRS?
12
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.

13
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

14
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

15
Worklists
16
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.

17
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

18
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?

19
UMB Process
  • Coeus
  • PeopleSoft
  • Individual Reports (short term)
  • XML (future processes)

20
UMB Process-Coeus
21
Coeus Organization Table
22
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
    Governors office.

23
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

24
UMB Process Batch Process
25
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?

26
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?

27
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
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