Federal Funding Accountability and Transparency Act

Federal Funding Accountability and Transparency Act Training Overview OMB

Purpose • FFATA seeks to create a single searchable website (USASpending.gov) that provides the public with greater access to Federal spending information • Federal spending transparency will increase and wasteful government spending will be reduced • Provide data about grants, contracts, loans, awards, cooperative agreements, and other forms of Federal financial assistance

FFATA Timeline • Enacted in 2006, federal agencies begin reporting contractor and grant award information but a slow rollout was planned for additional data • Feb. 2009 - ARRA Federal Stimulus enacted which requires extensive detailed transparency reports • Oct 2009 – First round of quarterly ARRA 1512 reports must be submitted • April 2010 – Federal OMB announces new reporting requirements • Oct 1st, 2010 – Additional FFATA transparency requirements go into effect

Reporting Requirements • Prime awardees of new Federal contracts and grants over $25,000 awarded on or after October 1, 2010 must report under FFATA • Does not include continuing or renewals of grants awarded in prior fiscal years with new obligations beginning October 1, 2010. • Prime awardees must report first-tier sub-awards over $25,000 • Prime awardees may also have to report executive compensation at the prime and sub-award levels

Definition of Sub-Awards for FFATA Reporting • A sub-award is a monetary award, made as a result of a Federal award to a grant recipient or contractor, to a sub-recipient or sub-contractor • “a sub-recipient relationship exists when funding from a pass-through entity is provided to perform a portion of the scope of work or objectives of the pass-through entity’s award agreement with the…awarding agency.” (OMB Circular A-133 Compliance Supplement) • State agency to state agency awards are not considered sub-awards when determining reporting requirements

Executive Compensation Criteria • if the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards • and$25,000,000 or more in annual gross revenues from Federal awards • andthe public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986

Implementation • Delaware will be using a decentralized reporting structure • Each Agency will be responsible for reporting on their applicable grants and contracts • OMB will offer guidance but will not be providing the same level of oversight and data quality monitoring as was done with the Federal Stimulus reporting

KK 002 New Appropriation Questionnaire • OMB has added a check box to this questionnaire asking if the program will have sub recipients • This is meant to help us better provide FFATA assistance by being aware of those programs that may need to file reports

Reporting Timeline • Sub awards must be reported by months end following the month in which they were awarded • Example: Sub-award date of April 1st. Report must be submitted by May 31st. • Example: Sub-award date of May 31st. Report must be submitted by June 30th.

1512 “Light” • FFATA uses many of the same data elements as the 1512 Stimulus reports, but the reporting requirements are not as extensive • There are no spending data fields • Prime section of report is pre-populated • Prime Awardees need only report when a sub award is granted or they meet the executive compensation criteria • There is no continuous reporting

Registrations Needed to Report • Prime awardees must have an active DUNS number registration http://fedgov.dnb.com/webform • Prime awardees must have an active registration in the Central Contractor Registration (CCR) https://www.bpn.gov/ccr/default.aspx • Sub awardees must have an active DUNS number registration • It is recommended that sub awardees be registered in the CCR

Reporting System • Reports are entered through a web based reporting system, the Federal Funding Accountability and Transparency Subaward Reporting System, known as FSRS https://www.fsrs.gov • Registering in FSF requires an active DUNS number • Registrations are linked to a DUNS number and an email address which serves as the username

Major Drawback toReporting System • Multiple users may have the same DUNS number • Each username (email address) can only be linked to one DUNS number • The agencies with multiple DUNS in the same division may need to create dummy emails to use as usernames • Dummy emails may be used as a username if an agency wishes to maintain one username per DUNS

Sub Award Data Elements • Sub-awardee DUNS Number – Required • Sub- awardee DUNS Number +4 • Sub-awardee Name - Required • Sub-awardee DBA name • Sub-awardee Address - Required • Sub-awardee Parent DUNS – only required if applicable

Sub Award Data Elements • Sub Award Amount -Required • Sub Award Date - Required • Sub-awardee Principal Place of Performance - Required • Sub Award Number – Required • Sub-awardee Highly Compensated Officers – only required if meets executive compensation criteria • Sub Award Description - Required

Scenarios • I received an award on 9/1/10. - No Report Needed • I received an ARRA award on 2/1/11 for $100,000 and expect to have two subrecipient awards for $50,000 each. – No Report Needed • I received second year grant funding of $150,000 on 3/15/11 and plan to make two subawards for $30,000 each. – No Report Needed • I received an award on 3/15/11 for $20,000. - No Report Needed

Scenarios • I received an award on 3/15/11 for $30,000 but do not plan to make subawards. – No Report Needed • I received an award on 3/15/11 for $150,000 and have made two subawards for $15,000 each. – No Report Needed • I received an award on 3/15/11 for $150,000 and have made two subawards for $30,000 each and one subaward for $20,000. – Will Require Report • I received an award on 3/15/11 for $150,000 but did not expect to have subrecipients. On 6/1/11 I find out that there will be a subaward for $30,000. - Will Require Report

Does the award fall under new FFATA guidelines? Is the award new as of Oct 1, 2010? YES Was the award granted by ARRA? NO YES NO Was the award previously under $25,000 but is now $25,000 or more? No steps required under new FFATA reporting. *other guidelines may still apply (i.e. original FFATA, ARRA) NO YES YES Was the award applied for/received by an individual as a natural person (not related to any business/organization) Follow steps for new FFATA reporting. YES Did the award go to an entity that had a gross income, from all sources, less than $300,000? NO NO YES Was a subaward of $25,000 or more granted? Is the award $25,000 or more? NO YES NO

Does the prime awardee have an active registration for the DUNS # under which the grant/contract was made? New FFATA reporting • *Exec compensation data required for prime awardee/sub-awardeeif ALL of the following are true: • In the previous fiscal year entity received 80% or more of gross revenues in Federal awards . • Entity received $25,000,000 or more in annual gross revenues from Federal awards. • The public does not have access to this information. Have sub awardee complete necessary registration, (required to receive award). NO YES Is the prime awardee actively registered in the Central Contractor Registration (CCR)? NO Register sub-award and sub-recipient, including all information that is not already pre-populated. CCR may include giving report on top 5 executives’ compensation. Check table* to see if prime-awardee/sub-awardee qualify. YES Did prime-awardee register sub -award/awardee in FFATA Subaward Reporting System (FSRS)? NO Registration complete. Information will be updated to USASpending.com automatically. YES

Federal Funding Accountability and Transparency Act