Federal Funding Accountability and Transparency Act

(FFATA or Transparency Act)

Dennis J PaffrathAssistant 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 sub-grants 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