FFATA

What is FFATA?

FFATA is the Federal Funding Accountability and Transparency Act (FFATA) of September 2006.   Under phase one, the Federal agencies uploaded their grants and contracts to a Federal website, www.USAspending.gov allowing the public to track how the money is spent.  In phase two, which started July 8, 2010, prime awardees, like Emory, began uploading first-tier subcontracts to www.fsrs.gov.   As a third step, the government reviews the information in fsrs.gov and uploads it into USAspending.gov to provide further transparency in how Federal money is spent.

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What qualifies as a first-tier subcontract?

A subaward from either a grant or a contract is a subcontract; however, the definitions differ for FFATA.   A subaward or subgrant from a grant is “a legal instrument to provide support for the performance of any portion of the substantive project or program.”   Subcontracts are broader.  A subaward or subcontract from a Federal contract is “awarded by the subcontractor to furnish supplies or services for performance of a prime contract” but excludes long-term supplier agreements.   Under the second definition, suppliers, like an equipment manufacturer, as well as colleges and universities, are subcontractors.   Each definition had different phase in rules.  However, after March 1, 2011 each subcontract of $25,000 or more is reportable whether from a grant or a contract.

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What information does Emory upload?

FOR GRANTS:

  • The first-tier subcontractor’s DUNS or DUNS + 4-number
  • The subaward number
  • The subaward amount
  • The subaward obligation/action (effective) date
  • The subaward project description (up to 4000 characters)
  • The subaward principal place of performance (POP) including city, state, country, zip code + 4, and congressional district

FOR CONTRACTS:

  • The first-tier subcontractor’s DUNS number
  • The subcontract number
  • The subcontract program or project title (up to 225 characters)
  • The subcontract amount
  • The subcontract date
  • The subcontract description, overall purpose, and expected outcomes (up to 4000 characters)
  • The subcontract principal place of performance (POP) including city, state, country, zip code + 4
  • If there is a task order for the contract, Emory must indicate if the report is for a task order or not and provide the delivery/order number or other number assigned by the Federal agency.

FOR MODIFICATIONS:
Any changes to the above information by the end of the following month

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When does Emory report?

Emory is required to report any applicable first-tier subaward or subcontract activity by the end of the month following the month that the subaward or subcontract was obligated.

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Whate is an applicable first-tier subaward or subcontract?

FOR GRANTS:
Only Federal grants with a new Federal award identification number (FAIN) as of October 1, 2010 are subject to FFATA.  Continuing or renewals of grants awarded in prior years with new obligations beginning October 1, 2010 do not constitute a “new” grant subject to FFATA.  In addition, Federal grant subawards awarded on or after October 1, 2010 qualify as applicable first-tier subawards when they meet the following threshold requirements:

  • The initial subaward is $25,000 or more.
  • The initial subaward is below $25,000 but subsequent grant modifications increase the total subaward to $25,000 or more.
  • The initial subaward is $25,000 or more but funding was de-obligated such that the total subaward is now less than $25,000.   This subaward is still subject to the reporting requirements.

FOR CONTRACTS:
Any Federal contract subcontract that is $25,000 or more under an applicable Federal contract, as defined below, qualifies as an applicable first-tier subcontract.
The Federal contract phase-in amounts are as follows:

  • From July 8, 2010 to September 30, 2010, the Federal contract must equal or exceed $20,000,000
  • From October 1, 2010 to February 28, 2011, the Federal contract must equal or exceed $550,000
  • After March 1, 2011, the Federal contract must equal or exceed $25,000

FEDERAL AWARD TYPES NOT SUBJECT TO FFATA:

  • Cooperative research and development agreements (CRDAs) pursuant to the Federal Technology Transfer Act of 1986
  • Federal grants funded in whole or part with American Recovery and Reinvestment Act (ARRA) funds
  • ARRA funded Federal contracts not specifically subjected to FFATA by the contracting officer

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