Subawards, SPA`s risk analysis & October 1st FFATA Changes

GMUN General Meeting
September 2010
Risk Assessment (Handout)
FFATA Purpose
Allow the tax-paying public to understand
where federal dollars are being spent
(including research funding)
Agencies submit data on federal awards
 Institutions report federally-funded subawards
Public receives an
on-line searchable
database displaying
funding received by
a recipient
Awards Subject to FFATA
All federal contracts over $20M (July 8, 2010)
 All federal contracts over $550M (October 1, 2010)
 All federal contracts over $25K (March 1, 2011)
All new grants and cooperative agreements
(October 1, 2010 and thereafter)
 Renewals and continuations are excluded (award must include a
new “Federal Award Id Number- FAIN)
 ARRA awards are excluded
 Awards are expected to include a term and condition invoking
What Must be Reported
and vendor transactions over
Grants and Coop Agreements
over $25K
 Incrementally funded subawards must be reported
with funding awarded reaches $25K
 Each modification thereafter must also be reported
When Must Reporting Occur
By the end of the month following the
month the subaward is fully-executed
E.g. subaward
executed 10/3/10 must be
reported by 11/30/10
Practically, this
means that SPA must obtain
information from subrecipients before the
subaward is executed
Who Reports What Where?
SPA reports into a new government
system called FSRS (FFATA Subaward
Reporting System)
 Data can be entered:
upload via Excel (probably what we will pick)
Agencies will pre-populate awards
or may not be helpful!
What Data Does SPA have to Collect?
Subaward execution month/year
Subrecipient DUNS+4
Subrecipient Name
Subrecipient DBA Name
Subrecipient Address
Subrecipient Congressional District
Subrecipient Parent DUNS
Subaward Amount
Subaward Obligation/Action Date
Subrecipient Primary Place of Performance Address
Subrecipient Primary Place of Performance Congressional District
Subaward Number Assigned by Prime Awardee
Subrecipient Executive Compensation Eligibility
Subrecipient Executive Compensation Prior Reporting
Subrecipient Names and Compensation of 5 Most Highly Compensated Officers (if
required by answers to previous two questions)
Subaward Project Description (award title and description of the purpose of each
funding action, and the overall purpose of the award)
How will SPA Collect This?
Now: Updated version of old FFATA form at
time of subaward issuance
Later: Collect it on FDP Subaward template
Departments need to get involved only if
there is a problem getting data from
Burden: Unknown, but we have more than
800 federally-funded active subawards at this

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