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Trials and Tribulations of FFATA

Debra Brodlie, Johns Hopkins UniversityDennis Paffrath, University of Maryland, Baltimore

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• FFATA – The Requirements• FSRS – System Overview• System Resources• Getting Help• The future of FSRS

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• The Federal Funding Accountability and Transparency Act (FFATA, or the Transparency Act) of 2006 and subsequent 2008 amendments requires: – Information disclosure of entities receiving Federal funding through Federal

awards such as Federal contracts and their sub-contracts, as well as Federal grants and their sub-grants

– Disclosure of executive compensation for certain entities– The establishment of a publicly available, searchable website that contains

information about each Federal award– Agencies to comply with OMB guidance and instructions and assist OMB in

implementation of website

Quick overview of FFATA

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• Prime grant awardees of Federal grants of $25K or more must report associated grant first-tier sub-grants of $25K or more (effective October 1, 2010)

• Prime contract awardees of Federal contracts of $25K or more must report associated contract first-tier sub-contracts of $25K or more (effective March 1, 2011)

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• Sub-award Information Required for FFATA Reporting:– Name of entity receiving award– Amount of award (obligated amount)– Funding agency– 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); and– Total compensation and names of top five executives (prime or sub-awardee), if

applicable

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• Prime awardees must report executive compensation information for prime and/or sub-awardees if in the preceding fiscal year:

(1) The organization received 80% or more of its annual gross revenues in Federal awards and those revenues are greater than $25 million annually, and

(2) The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.

NOTE: Classified information remains exempt from the prime and sub-award reporting requirements

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• Agencies must report prime award information

• Prime awardees must report first-tier sub-award information and executive compensation information

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• Prime contract awardees must register with the Central Contractor Registry (CCR)– Sub-awardees must register with Dun & Bradstreet to get a DUNS number

• Prime contract awardees must respond to the executive compensation questions through CCR

• Agencies must report prime contract award information through the Federal Procurement Data System – Next Generation (FPDS-NG)

• Prime contract awardees must report eligible sub-award information through the FFATA Sub-award Reporting System (FSRS)

• Prime contract awardees must respond to the executive compensation questions about their first-tier sub-awardee through FSRS (if the sub-awardee is NOT already in CCR)

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• Prime grant awardees must register with the Central Contractor Registry (CCR)– Sub-awardees must register with Dun & Bradstreet to get a DUNS number

• Prime grant awardees must respond to the executive compensation questions through CCR

• Agencies must report prime grant award information through their FAADS-PLUS file submissions to USAspending.gov

• Prime grant awardees must report first-tier sub-award information through the FFATA Sub-award Reporting Systems (FSRS)

• Prime grant awardees must respond to the executive compensation questions about their first-tier sub-awardee through FSRS (if the sub-awardee is NOT already in CCR)

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• Prime grant awardees must register with the Central Contractor Registry (CCR)– Sub-awardees must register with Dun & Bradstreet to get a DUNS number

• Prime grant awardees must respond to the executive compensation questions through CCR

• Agencies must report prime grant award information through their FAADS-PLUS file submissions to USAspending.gov

• Prime grant awardees must report first-tier sub-award information through the FFATA Sub-award Reporting Systems (FSRS)

• Prime grant awardees must respond to the executive compensation questions about their first-tier sub-awardee through FSRS (if the sub-awardee is NOT already in CCR)

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• On August 27, 2010, OMB issued guidance to Federal agencies on implementation of the Transparency Act’s executive compensation and sub-award reporting.

FSRS – System overviewWhat Is FSRS?

• FSRS (www.fsrs.gov) is the FFATA Sub-award Reporting System • Collects sub-award information from prime awardees• Uses existing sources to pre-populate prime contract data and sub-contractor data by interfacing with:

• Central Contractor Registration (CCR, www.bpn.gov/ccr)• Dun & Bradstreet (D&B, www.dnb.com)• Contracts: Federal Procurement Data System (FPDS)• Grants: FAADS-PLUS from USAspending.gov

• Supports multiple report submission via XML web services, a .csv “batch” template or an .xml report template• Leverages the Electronic Subcontract Reporting System (eSRS)

– You do not need to re-register if you have an existing account in eSRS 12

The ‘Middleman’• FSRS enables prime awardees to report FFATA-required sub-award and

executive compensation data about their sub-awardee* then provides this data for display on USAspending.gov

*if not registered in CCR

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FSRS Home Page (www.fsrs.gov)

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Where Do I Find System Resources?

FSRS’ Resources Page (https://www.fsrs.gov/resources) contains:• Quick Reference Guides for Contracts and Grants

• Managing Sub-award Reporting in FSRS:• Add an Award to the Awardee Worklist • Delete an Award from the Awardee Worklist • Creating and Submitting a FFATA Sub-award Report in FSRS • Edit a Report from the FFATA Reports List • Review, Access and Retrieve Reports from the FFATA Reports List • Complete a Batch Upload for Sub-award Reporting

• User Guides• Demonstration Videos & Webinar Archives• Technical Documentation

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Trials and Tribulations:• Entering for ARRA• Timing of reporting FFATA data• DUNS number issues, foreign sites• One entry a month per award, coordinating

with various sites• Zip Code plus 4

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Trials and Tribulations:• Lack of Agency submission of award to FSRS• Duplicative reports

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• No reporting required for:• ARRA• Classified work• Subrecipient receipt of federal funds less than

$300,000

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Audits:• Have implemented procedures?• How do you appropriately identify federal

awards subject to FFATA?• How do you appropriately identify

subrecipients subject to FFATA?• Who identifies and who is the reviewer?

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www.fsrs.gov/resources

• FSRS is one of several systems served by the Federal Service Desk (www.fsd.gov) for Tier 1 support

• The FSRS home page has a For Help: Federal Service Desk link directing users to the multi-channel FSD contact center

• FSRS also has system FAQs posted on the home page and again within the site on the Resources Page

Where Can I Find Help?

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• Clicking on the “For Help: Federal Service Desk” link on the home page, or anywhere within the site, takes the user to a splash screen

• The user can either click the logo to be quickly redirected immediately or wait 30 seconds and be sent to the FSD home page at www.fsd.gov

Service Desk

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• Debra Brodlie, JD – Johns Hopkins University dbrodlie@jhsph.edu

• Dennis Paffrath –University of Maryland, Baltimore dpaffrat@umaryland.edu

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