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FFATA – Town Hall Meeting. Kim Linkous, CRA Director of Post Award Office of Sponsored Programs Virginia Tech 540-231-9372 linkousk@vt.edu. FFATA Objectives For Open Discussion. FFATA. What and Why. Federal Funding Accountability and Transparency Act
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FFATA – Town Hall Meeting Kim Linkous, CRA Director of Post Award Office of Sponsored Programs Virginia Tech 540-231-9372 linkousk@vt.edu
What and Why • Federal Funding Accountability and Transparency Act • Provides public information on Federal award spending via one searchable website (USAspending.gov) (FFATA or Transparency Act - P.L.109-282, as amended by section 6202(a) of P.L. 110-252 Federal Acquisition Regulation clause 52.204-10
Who • Prime recipients of federal funding with first-tier subawards > $25K • 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)
Distributing to Public • Federal government uploads prime award information for Federal awards >$25K • Prime recipient uploads required elements into FFATA Subaward Reporting System (FSRS) • Public searches USAspending.gov
When is FFATA applicable? • Federal contracts, cooperative agreements and grants with first-tier subawards > $25K • Subaward originally awarded for < $25K, supplemental increase brings cumulative amount > $25K, begin reporting • Does NOT include awards made by a first-tier sub-recipient to a lower tier sub-recipient
When is FFATA Not Applicable • Recovery Act awards • Awards to individuals • Recipients that had a gross income of $300,000 or less in their previous tax year • Classified information
Required Information • Name of entity receiving award • Amount of award • Funding agency • NAIC code for contracts/CFDA program number for grants • Program source • Award title descriptive of the purpose of the funding action • Location of entity (including Congressional district) • Place of performance (including Congressional district) • Prime award number and subaward number • If applicable, total compensation and name of top executives (prime and subawards) if applicable
When is Executive Compensation Required? • 80% or more annual gross revenues in Federal awards andthose revenues are greater than $25 million annually and the public does not have access to information about the compensation of their senior executives of the entity through periodic reports to SEC
Where to report? • Prime awardees will report using the FFATA Subaward Reporting System (FSRS) • Pre-populates, to the maximum extent possible, recipient information from existing Federal agency databases, such as the Systems for Award Management (SAM) • All Federal contractors and prime grant recipients are required to register in SAM
Are there deadlines for FFATA reporting? • Government must report within 30 days of award • The prime recipient will have until the end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement • October 15, 2012 subaward issued, the prime recipient has until November 30, 2012 to report the subaward information
What is SAM? • Government recently consolidated the following websites • Contractor Registration (CCR)/Federal Agency Registration (FedReg) • Online Representations and Certifications Application (ORCA) • Excluded Parties List System (EPLS) • FSRS is expected to be included in the next phase