New Reporting Rules for Direct Recipients of Federal Awards and Contracts

The Federal Funding Accountability and Transparency Act of 2006 (FFATA), as amended, requires a federal award reporting process that is very similar to the reporting required by the American Recovery and Reinvestment Act (ARRA). FFATA applies to all federal awards, including grants and sub-grants and federal contracts and sub-contracts. The new reporting is required to be made into the FFATA Subaward Reporting System (FSRS).

The reporting timeline for direct (prime) recipients
Prime Contractors awarded a federal contract or order that is subject to Federal Acquisition Regulation clause 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, are required to file a FFATA subaward report by the end of the month following the month in which the Prime Contractor awards any subcontract greater than $25,000. This reporting requirement will be phased-in (see below):

Phase 1: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $20,000,000, reporting starts now

Phase 2: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $550,000, reporting starts Oct. 1, 2010

Phase 3: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $25,000, reporting starts March 1, 2011

Although the requirement to report subawards is being phased-in at certain dollar levels, if you would like to start reporting prior to the start date for your subcontracts, the system is available to you for reporting

Beginning Oct. 1, 2010, prime grant recipients of new federal grants of $25,000 or more must report information on associated “first-tier” sub-grants of $25,000 or more. Such information must be reported by the end of the month following the month the subaward or obligation is made. For example, for a subaward made on December 1, 2010, the reporting would be due by Jan. 31, 2011.

Reported information
The information that needs to be reported includes:

• Name of entity receiving award
• Amount of award (obligated amount)
• Funding agency
• NAICS code for contracts/CFDA program number for grants
• Program source
• Award title descriptive of the purpose of the funding action
• Location of the entity (including congressional district)
• Place of performance (including congressional district)
• Unique identifier of the entity and its parent
• Total compensation and names of top five executives (prime or subawardee) – with certain exceptions similar to those provided for ARRA reporting.

More information about these requirements
The FSRS website provides a number of related resources. Some of these have been provided below for your convenience:

Public Law 109-282 FFATA Legislation

Public Law 110-252 FFATA Legislation

Federal Acquisition Regulation

OMB Guidance on Subaward and Executive Compensation Reporting

For more information, please contact McGladrey & Pullen National Director of Public Sector Services Brian Schebler at 952.921.7761.