Reporting Executive Compensation and First-tier Subcontract Awards

1. Reporting Executive Compensation and First-tier Subcontract Awards NCMA SUNCOAST CHAPTER November 9, 2010

2. Federal Funding Accountability and Transparency Act (FFATA) FAR 4.14 Reporting Executive Compensation and First-Tier Subcontract Awards, Implementation FAR 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards, Clause in Terms & Conditions WHY?

3. FFATA The Federal Funding Accountability and Transparency Act requires information on federal awards be made available to the public via a single, searchable website.

4. FAR Requirements 4.14 Applicability & Procedures 52.204-10 Clause

5. Direct Recipients of USG Funds No Sub-recipients, Subcontractors, Etc. Report Direct Recipients Report on: Self and Sub-recipients, Subcontractors, Etc. WHO?

6. Prime Contractor responsible for notifying subcontractors that reported information is made PUBLIC.

7. End of 1st Month after Award Prime Contractor Report Prime Prime Contractor Report 1st-tier (only) Subcontract WHEN?

8. Reporting Compensation Prime Contractor Reporting on Prime/Self By End of Month Following Award, Annually, 5 Highest-compensated FOR Preceding (whole) Contractor’s “Accounting” Year

9. Reporting Compensation Prime Report of First-tier Subcontractor By End of Month Following Subcontract Award, Annually, 5 Highest-compensated FOR Preceding (whole) Subcontractor’s “Accounting” Year

10. Input: www.fsrs.gov FSRS Contractor Guide (Adobe-PDF Contractor User Guide 1.0, Updated July 8, 2010) Login Basics Profile (of Prime) Contract Worklist FFATA Reports (Viewed Quarterly by USG) Batch Uploads FSRS Contractor Demonstration (Video & Audio Instructions) WHERE?

11. Public (Searchable) Reporting: www.USASpending.gov Sub-award Documents (not all-inclusive) PDF: Presentation on Transparency Act Sub-award and Executive Compensation Reporting PDF: Fact Sheet on the Transparency Act’s Sub-award and Executive Compensation Reporting PDF: Transparency Act - Sub-award reporting and Executive compensation PDF: FSRS Grants Sub-award Overview and Training WHERE?

12. Websites CCR FSRS USA Spending

16. CCR FSRS CCR Information Auto-fills FSRS Delay in Updating FSRS – Verify CCR Renewal to Update FSRS

17. Each Direct-from-USG Award of $25,000 or More Exception: Classified Solicitations & Contracts Exception: Solicitations & Contracts with Individuals Exception: Previous Tax Year Gross (total) Income from ALL SOURCES < $300,000 WHAT?

18. Each Direct-charged (not G&A), 1st-tier Subcontract/Sub-award of $25,000 or More Exception: Solicitations & Contracts with Individuals Exception: Subcontractor Previous Tax Year Gross (total) Income from ALL SOURCES < $300,000 WHAT?

19. Prime Reports in FSRS $25,000 Value in AGGREGATE, with Modifications and Change Orders that Change Previously-reported Data

20. Prime Reports Subcontract Subcontractor DUNS & Subcontractor’s Parent Co. (if any) DUNS, Subcontract Name, Subcontract: Amount, Date, Products and/or Services, Number,

21. Prime Reports Subcontract Subcontractor Physical Address, 9-digit Zip, Congressional District Subcontractor Primary Performance Location 9-digit Zip, Congressional District

22. Prime Reports Subcontract Prime Contract Number, Awarding Agency Name & Code, Funding Agency Name & Code, USG Contracting Office Code, Treasury Account Symbol, and NAICS

23. Phase-in for Subcontracts Award before October 1, 2010 of $20,000,000 or More Award from October 1, 2010 - February 28, 2011 of $550,000 or More Award on or after March 1, 2011 of $25,000 or More

24. Reporting Compensation Required ONLY if – for Most Recent, Completed Fiscal Year – the Entity Received:

25. Reporting Compensation 80% or More of Annual Gross Revenues from USG, AND $25,000,000 or More Annual Gross Revenues from USG

26. Compensation Reporting NOT Required if Accessible to Public via: Reporting Requirements of Securities Exchange Act (SEC Reports), or Internal Revenue Code (Reports for Non-profits and for Pension Plans)

28. FAR Subpart 52.204-10

29. FAR Subpart 52.204-10

30. FAR Subpart 52.204-10

31. FAR Subpart 52.204-10

32. Compensation ReportingPrime and/or Subcontractor When? By End of 1st Month After Award Annually, Thereafter, and When Reported Data Changes

33. Compensation ReportingPrime and/or Subcontractor What? Total Compensation of Each of 5 Most-highly Compensated Executives

34. Definitions TOTAL COMPENSATION = Cash & Noncash Value

35. Definitions Salary Bonus Stock, Stock Options, & Related Pension & Deferred Comp Change in Present Value of Benefit/Plan Above-market Earnings on Deferred Comp Other with Aggregate > $10,000

36. Definitions Does NOT Include Group Insurance or Reimbursement Plans Available to ALL Salaried Employees With no favoritism toward executives. Life, Health, Hospitalization, or Medical

37. Input Website (http://www.fsrs.gov) Register, and Click Hyperlink in Received Email to Verify Only One DUNS for Each Email Address More than One Email Address Allowed for One DUNS Returning Contractor Email and Password Enter Prime Contract HOW?

38. Enter Each Applicable Subcontract, Separately Add Each (Applicable) New Subcontract Batch Upload Reports from Excel Edit Data (Including Award Date) for Change Orders Delete Each Closed Subcontract HOW?

39. Verify CCR Current and Accurate Register on FSRS Create Profile on FSRS Add Contract/Grant to Worklist HOW?

40. eSRS

43. Step 2 of 2 Pre-filled Info from CCR Contact Information WITH EMAIL ADDRESS

44. Step 3 of 2 Click “Link” in Email and Confirm Registration

46. “Worklist” Tab My Worklist – Search for Already Added Contracts Not Added Grant Awards Not Added

47. “Contracts Not Added” Tab Award ID, Agency, DUNS “Add To Worklist”

48. Worklist “Contracts Not Added” Tab: Awards in USG System with User DUNS – NOT on “My Worklist” Tab

49. Worklist Allows Prime Awardee to Manage & Review Awards for Which User has Reporting Responsibility Contracts and Grants Awarded to User’s DUNS Starting Point to create New Sub-award Reports Against Prime Awards

50. “Create/Review Reports” Tab All Drafts Submitted Re-opened

51. “All” Tab Click “Create New Report” Steps 1 - 7

52. Add Prime or Subcontract

53. Click Create New Report Complete Steps 1 - 6 Click “View Printable Report” or “Save PDF” Button Complete Step 7 Click “Add To Worklist” HOW?

55. Step “3” Verify Award Number, Agency, $ Certification that PRIME Submits Click “Save & Continue”

56. Step “4” Info “Is the information correct?” Radio Button: Yes No If “No” – Flag & “Please explain:”

57. Step “4” “USPS.com” Link to Get Zip Code “Congressional District:” Automatically Added

58. Step “4” “Name” and “Amount” of Prime Award SAME AS CCR

59. Step “5” Click “Add Subawardee”

60. Step “5” “Subawardee DUNS:” REQUIRED Click “Fetch Info for DUNS”

61. Step “5” Subawardee Executive Compensation Certification Required? Radio Button: Yes No

62. Step “5” “Subaward Project Description:” GAO Guidelines Public Information

63. GAO Guidelines General Purpose of Award & Amendments Percentage Complete Outcomes (Planned & Achieved) Scope (Metrics)

64. Reports Can Delete Draft Report of Subcontract under a Prime Cannot Delete Submitted Report

65. Reports DRT = Draft SUB = Submitted RPN = Reopened (for correction)

66. Excerpt from Guide

68. Step “6” Keep Printed Copy of DATED Report for Audit Support Cannot SAVE Report from Review or Submission Pages

69. Updates Add New Awards Edit Data for Amendments, Modifications, and Change Orders Delete Each Closed Award

70. Questions?

71. Test Question #1 Your company received a prime contract of $19,999,999 on October 15, 2010. A direct subcontract of $600,000 is awarded to an individual on October 25 to perform technical consulting under this prime contract.

72. Test Question #2 Your company received a prime contract of $2,500,000 on October 15, 2010. A direct subcontract of $560,000 was awarded to a supplier that earned $30,000,000 in gross revenues, which was 90% of their total gross revenues, from U.S. Government prime and subcontracts.

73. Test Question #3 Your company received a prime contract of $540,000 on October 15, 2010. There were no modifications. A direct subcontract of $26,000, under this prime contract, is awarded to a supplier on March 15, 2011.