Federal Funding Accountability and Transparency Act

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Federal Funding Accountability and Transparency Act (FFATA)


Public Law 109-282, the Federal Funding Accountability and Transparency Act of 2006 as amended (FFATA), requires disclosure of all entities and organizations receiving federal funds through a single publicly accessible website, USASpending.gov. USASpending.gov includes information on each federal financial assistance award and contract over $25,000, including such information as:

  1. The name of the entity receiving the award
  2. The amount of the award
  3. Information on the award including transaction type, funding agency, etc.
  4. The location of the entity receiving the award
  5. A unique identifier of the entity receiving the award; and
  6. Names and compensation of highly-compensated officers (as applicable)

Assistance Agreement Recipient Responsibilities


Compliance with FFATA is primarily the responsibility of the awarding federal agency. However, grant and cooperative agreement recipients are responsible for reporting on executive compensation, when applicable, and subrecipient awards over $25,000.

Executive compensation and subrecipient reporting requirements generally apply to new discretionary and mandatory EPA funding, equal to or exceeding $25,000, awarded on or after October 1, 2010.

A prime recipient is required to report subawards where the obligations are equal to or greater than $25,000 in federal funds. If a subaward is initially funded at less than $25,000, the prime recipient does not have to report the subward to the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS). However, if the prime recipient subsequently provides additional funding to increase the subaward amount to $25,000 or more, the subaward must be reported in the FSRS.

Subaward reporting is specific to each assistance agreement. For example, if a prime recipient makes a subaward to an organization under one grant for $20,000 and another subward for less than $15,000 to the same organization for different work under a different grant, the prime recipient would not have to report either subaward to the FSRS, even though the cumulative value of the two subawards exceeds $25,000.

Prime recipients should not subdivide subawards equal to or greater than $25,000 into smaller subawards in order to circumvent FSRS reporting requirements.  All recipients are required to maintain an active System for Award Management (SAM) registration and Data Universal Numbering System (DUNS) number for the place of performance.

OMB guidance regarding FFATA related requirements is available at 2 CFR Part 170 and further details regarding these requirements are outlined below. FSRS also has a very extensive list of frequently asked questions that provide guidance to many different recipient situations.

System for Award Management (SAM) and Data Universal Numbering System (DUNS) Requirements


Unless exempt from the requirements under OMB guidance at 2 CFR Part 25, recipients of EPA assistance agreement funding are required to obtain and maintain a DUNS number from Dun & Bradstreet and register in SAM. Current recipients are required to keep their DUNS number and SAM registration up-to-date. Recipients are required to update information in SAM annually at a minimum to remain in compliance with the terms and conditions associated with their award.

The DUNS number is a unique nine digit identification number, used to identify the physical location of assistance agreement activities. Organizations may have more than one DUNS number, if there are multiple places of performance. Applicants and recipients can receive a DUNS number, at no cost, by calling the dedicated toll-free DUNS number request line at 1-866-705-5711, or visiting the Dun & Bradstreet (D&B) website 

Prime Recipient Executive Compensation Reporting


Prime recipients are required to report the names and total compensation of the five most highly compensated officers of their entity as part of their registration profile in SAM if the entity in the preceding fiscal year:

  1. received 80 percent or more of its annual gross revenues in Federal grants, subawards, contracts, and subcontracts; and
  2. received $25,000,000 or more in annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and
  3. had gross income, from all sources, of $300,000 or more; and
  4. the public does not have access to this information about the compensation of the senior executives of the entity 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. See FFATA §2(b)(1).

The prime recipient must include the data in its SAM registration profile by the end of the month following the month it receives an award, and annually thereafter.

Subrecipient Reporting Requirements


FFATA requires most recipients of new Federal funds awarded on or after October 1, 2010 to report on subawards/subcontracts/consortiums equal to or greater than $25,000. This includes awards that are initially below $25,000 but subsequent grant modifications result in an award equal to or greater than $25,000.

Recipients are required to report subrecipient information to the FFATA Subaward Reporting System (FSRS). This tool can be accessed directly at www.fsrs.gov, and will serve as the collection tool for subaward data which will ultimately be distributed for publication and display on USASpending.gov. Grantees are required to register with FSRS, collect the necessary data from subawardees, and file subaward reports by the end of the month following the month in which the prime grantee awards any subaward greater than $25,000.

For first-tier subawards involving an obligation of $25,000 or more in federal funds, prime EPA recipients must report the following information:

  1. Name of the entity receiving the award;
  2. Amount and date of the award;
  3. Funding agency;
  4. Catalog of Federal Domestic Assistance (CFDA) number;
  5. Award title descriptive of the purpose of each funding action;
  6. Location of the sub-recipient receiving the award and primary location of performance under the award, including city, state, congressional district, and country;
  7. DUNS number of the sub-recipient receiving the award and the parent entity of the sub-recipient, should the entity be owned by another entity.

Prime recipients are also required to report the names and total compensation of the five most highly compensated officers of the subrecipient if the entity in the preceding fiscal year:

  1. received 80 percent or more of its annual gross revenues in federal grants, subawards, contracts, and subcontracts; and
  2. received $25,000,000 or more in annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and
  3. had gross income, from all sources, of $300,000 or more; and
  4. the public does not have access to this information about the compensation of the senior executives of the entity 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. See FFATA § 2(b)(1).

To complete the subrecipient reporting requirements, the prime recipient must maintain an active registration in SAM. They must report this information by the end of the month following the month a subaward obligation is made. For example, for a subaward made by a prime recipient on October 21st, the information must be reported to FSRS no later than November 30th.

First-tier subrecipients must have a DUNS number before receiving a subaward, but do not have to maintain a SAM registration. In order for the prime recipient to successfully enter in subrecipient information, the subrecipient must have a zip code plus four associated with their DUNS number and P.O. Box addresses are not acceptable. Prime recipients may not delegate FSRS reporting responsibilities to subrecipients.

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Last updated on July 24, 2024