New FFATA Reporting Requirements Subawards and Executive Compensation

New FFATA Reporting Requirements: Sub-awards and Executive Compensation Doretha Dixon, Grants Policy Analyst Department of Health and Human Services Health Resources and Services Administration Office of Federal Assistance Management Division of Grants Policy

FFATA: A Brief History • The Federal Funding Accountability and Transparency Act (FFATA) of 2006 (Public Law 109 -282) requires that the Office of Management and Budget (OMB) create a searchable, no-cost, publicly accessible website that includes the following information for each Federal award $25, 000 and over: o o o Award recipient’s name Award amount Award information including transaction type, funding agency, title describing purpose, etc. Recipient’s location Recipient’s unique identifier (DUNS number)

FFATA: A Brief History • FFATA was amended by the Government Transparency Act of 2008 (Public Law 110 -252) requiring disclosure of additional information from recipients and information on first-tier sub-recipients on new awards on or after October 1, 2010.

Why? • American taxpayers want to know how their federal tax dollars are being spent! ? • FFATA and its requirements are major steps in improving access to Federal Government information and holding the government accountable for spending decisions. ? ? ?

Who’s Required to Report? • Recipients of non-Recovery Act funded grants, cooperative agreements, and competitive supplements of $25, 000 or more awarded on or after October 1, 2010.

Who’s / What’s Exempt? • Individuals • Entities that had a gross income, from all sources, of under $300, 000 in the previous tax year are exempt from any sub-award reporting • Noncompeting continuation awards, administrative supplements (that do not exceed 25% of the current total authorized award), sole source awards, and awards funded by the Recovery Act

What Should Be Reported? • Information on first-tier sub-awards under grants, cooperative agreements, and supplements of $25, 000 or more (non-Recovery) • Total compensation for each of the recipient’s and sub-recipient’s five most highly compensated executives for the preceding completed fiscal year if. . .

What Should Be Reported? …IF in the preceding fiscal year, the recipient or sub-recipient received— • • More than 80% of its annual gross revenues from the Federal Government; and those revenues are greater than $25 M annually; and The public does not have access to information about the executive compensation through SEC reporting.

What Exactly Do You Mean By… • Sub-award? This term means a legal instrument to provide support for the performance of any portion of the substantive project or program for which you received this award and that you as the recipient award to an eligible sub-recipient. • Executives? They are the officers, managing partners, or any other employees in management positions. • Total Compensation? This is the cash and noncash dollar value earned by the executive during the recipient’s or sub-recipient’s preceding fiscal year and includes the following: salary and bonus; awards of stock, stock options, and stock appreciation rights; earnings for services under non-equity incentive plans; change in pension value, etc. (for more information see 17 CFR 229. 402 (c) (2)).

When? • Sub-award information must be submitted by the end of the month following the month in which the obligation was made (e. g. , report 11/7/10 obligation by 12/31/10). • Compensation information must be submitted by the end of the month following the month in which the obligation was made and annually thereafter during the period of support.

Where? • FSRS (www. fsrs. gov) will enable prime awardees to report FFATA-required subaward and executive compensation data.

Where Else? • Executive compensation for the prime awardee should be reported as part of your profile at the Central Contractor Registry (www. ccr. gov).

FSRS. gov Reporting Availability • On October 29, 2010 the sub-award and executive compensation reporting functionality will be available to prime awardees. • Help desk, user guides, demos, role-based webinars, and FAQs will also be ready at that time.

FSRS. gov FYI • On the deployment date, the FSRS log-in registration page will provide access for “Government” and “Awardees” (instead of “Contractors”). • Click “Awardees” and register using your email address and DUNS number.

FSRS. gov On October 29, 2010, Prime Awardees will be able to register and log-in to FSRS to: • Manage FFATA Reports • Manage Awardee Worklist o o o o o Search for an Award by Federal Award Identifier Number (FAIN) Create New FFATA report Save / Delete Draft FFATA Report Submit New FFATA Report Reopen and Revise Submitted FFATA Report Copy Existing FFATA Report Manage FFATA Report List Flag FAADS+ Data Elements Submit Multiple FFATA Reports o o o Organize Prime Awards Associated with Registered DUNS Search for Award by FAIN Add FAIN to / Remove FAIN from Worklist

FSRS Will Contain Prepopulated Data From… • CCR. gov: Using the DUNS number provided in the award notice, FSRS displays your entity information from CCR. • CFDA. gov: Using the CFDA number provided in the award notice, FSRS displays the CFDA Program Title from CFDA. gov. • USAspending. gov: Federal Agencies report prime grant award notice information to USAspending. gov using a file format known as FAADS PLUS. FSRS then pulls prime award data from USAspending. gov to help you locate the correct award.

Where Will All This Data End Up? • USAspending. gov fulfills FFATA’s requirement to have a single, searchable website for public use! • Please refer to the “What’s new” section to: o sign up for updates. o access reporting docs. o access 9/23/10 FFATA Town-hall webinar and 10/7/10 Prime Grant Awardee Training webinar.

Related Requirements As codified in 2 CFR Part 25: • Recipient must notify potential sub-recipients that no entity may receive a sub-award unless the sub-recipient has provided its Dun and Bradstreet Data Universal Numbering System (DUNS) number to the prime. • Recipient must maintain the currency of their information in the Central Contractor Registration (CCR) until they submit the final Federal Financial Report required under the award or receive the final payment, whichever is later.

Additional Resources • Federal Register Notice: 2 CFR Part 170, Requirements for Federal Funding Accountability and Transparency Act Implementation, http: //edocket. access. gpo. gov/2010/pdf/2010 -22705. pdf • Implementation guidance is available at www. whitehouse. gov/omb/open under “Open Government Directive - Federal Spending Transparency” • www. grants. gov • www. hrsa. gov/grants/ffata. html

Contact Information HRSA Post Awards HRSAPost. Awards@hrsa. gov Be sure to include the 10 -digit grant number (found in box 4 b. of your award letter) in all correspondence. [As of April 2014]