FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA)

1
FEDERAL FUNDING ACCOUNTABILITY AND
TRANSPARENCY ACT(FFATA)
2
FFATA

• Requires information disclosure of entities
  receiving Federal funding through Federal awards
  such as Federal contracts and their sub-contracts
  and Federal grants and their sub-grants.
• Requires disclosure of executive compensation for
  certain entities.
• Requires the establishment of a publicly
  available, searchable website that contains
  information about each Federal award.
• Requires agencies to comply with OMB guidance and
  instructions and assist OMB in implementation of
  website.

3
What new reporting is required?

• Prime contract awardees of contracts 25K or more
  must report associated contract subawards.
• Data collection will be phased with all required
  contract subawards reporting by March 2011 (See
  slide 6 for more details.)
• Prime grant awardees of grants 25K or more must
  report associated grant subawards.
• Executive compensation information for awardees.

4
Who is responsible for reporting?

• Federal Agencies must report prime award
  information
• Prime awardees (State of Illinois) must report
  subaward information

5
When does reporting begin?

• Contracts subaward (sub-contracts only) reporting
  requirement will be phased in
• Phase 1 Reporting subawards of prime awards
  valued greater than 20M began in July 2010
• Phase 2 Reporting subawards of prime awards
  valued greater than 550K began October 1, 2010
• Phase 3 Reporting subawards of prime awards
  valued at 25K or more began March 1, 2011
• Grants subaward (sub-grants only) reporting is
  required for all awards made on or after October
  1, 2010 for all prime grant awards 25K or more.

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How do I report?

• Federal Agencies must report prime grant award
  information through the Federal Assistance Award
  Database System Plus format (FAADS)
• Federal Agencies must report prime contract award
  information through the Federal Procurement Data
  System Next Generation (FPDS-NG)
• Prime contract and grant awardees (State of
  Illinois) must report subaward information
  through the FFATA SubAward Reporting Systems
  (FSRS)
• Prime contract and grant awardees must register
  with the Central Contractor Registry (CCR)
• If required, prime contract and grant awardees
  must report executive compensation through CCR

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How long do I have to report?

• All awardees must report by the end of the month
  following the month the award or obligation was
  made
• For example, if an award is made on July 10, 2010
  the awardee would have until August 30, 2010 to
  report the award all awards made during July
  will have until August 30, 2010 to report

8
Reporting Responsibility

• DHS as the prime contractor/grantee is
  responsible for reporting for subaward
  (first-tier subawardee) information such as
  subaward entity information, description/title,
  and date of award.
• New Federal, non-Recovery Act funded grant awards
  with an award date on or after October 1, 2010
  and result first-tier subawards, are subject to
  the reporting requirements under the Transparency
  Act.
• For new federal grants as of October 1, 2010, if
  the initial award is equal to or over 25,000,
  prime awardee (DHS) must report subaward and
  executive compensation, if required.
• If the initial award is below 25,000 but
  subsequent grant modification results in a total
  award equal to or over 25,000, the award is
  subject to the reporting requirements, as of the
  date the award exceeds 25,000.
• If the initial award amounts to or exceeds
  25,000 but funding is subsequently de-obligated
  such that the total award amount falls below
  25,000, the award continues to be subject to the
  reporting requirements of the Transparency Act.

9
ARRA Reporting

• Grant Awards, whether existing or new, as of
  October 1, 2010 that are funded by the Recovery
  Act will continue to report under ARRA reporting
  requirements through FederalReporting.gov.
• Such Grant Awards are not subject to FFATA
  reporting requirements.

10
SUBAWARDS

• For grants, a subaward means a legal instrument
  to provide support for the performance of any
  portion of the substantive project or program for
  which you received the award and that
• The prime recipient awards to an eligible
  sub-recipient or
• Sub-recipient at one tier awards to a
  sub-recipient at the next lower tier

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Subawardee Responsibility

• The prime grant awardee must report all
  information associated with a Federal grant,
  either regarding executive compensation data for
  the prime recipient or subawardees, or any other
  information associated with subawards.
• The subawardee, however has an obligation to
  provide the prime grant awardee all information
  required for such reporting.
• This includes subawardee entity information, DUNS
  number, subawardee parent DUNS number, if
  applicable, and relevant executive compensation
  data, if applicable.
• If the subawardee is registered in the Central
  Contractor Registry (CCR), this information may
  be migrated into FSRS .

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Data Reporting Requirements

• The Transparency Acts section 2(b)(1) requires
• Name of the entity receiving the award
• Amount of the award
• Information on the award including transaction
  type, funding agency, the North American Industry
  Classification System code or Catalog of Federal
  Domestic Assistance number, award title
  descriptive of the purpose of each funding
  action
• Location of the entity receiving the award and
  the primary location of performance under the
  award, including city, State, congressional
  district, and country
• DUNS number of the entity receiving the award and
  the parent entity of the recipient, should the
  entity be owned by another entity

13
Data Reporting Requirements

• Names and total compensation of the five most
  highly compensated officers of the entity if the
  entity in the preceding fiscal year
• Received 80 percent or more of its annual gross
  revenues in Federal awards
• Received 25 million or more in annual gross
  revenues from Federal awards
• The public does not have access to this
  information in periodic reports under
• Section 13(a) or 15(d) of the Securities Exchange
  Act of 1934, or
• Section 6104 of the Internal Revenue Code of
  1986.

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Exemptions from the Act

• Existing or new grants as of October 1, 2010,
  that are funded by the Recovery Act. These
  grants will continue to report those awards and
  related subawards through FederalReporting.gov
• Cooperative Research and Development Agreements
  as defined under 15 USC 3710a
• Federal awards to individuals who apply for or
  receive Federal awards as natural persons (i.e.,
  unrelated to any business or non-profit
  organization he or she may own or operate in his
  or her name)
• Federal awards to entities that had a gross
  income, from all sources, of less than 300,000
  in the entities previous tax year.

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Information Resources

• For more information on FFATA requirements,
  please see the DHS Contracts website
  http//www.dhs.state.il.us/page.aspx?item56761
• To access the FFATA form (IL 444-0949) to be
  completed, please go to http//www.dhs.state.il.u
  s/OneNetLibrary/27897/documents/Forms/IL444-0949.p
  df
• To submit the completed FFATA form, please email
  it to DHS.DHSOCA_at_illinois.gov
• For questions, please contact Steven Shaw at
  Steven.E.Shaw_at_illinois.gov