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Office of Contracts Management (OCM)

FFATA Reporting

VUMC Compliance with the Federal Funding Accountability and Transparency Act (FFATA)



General Information

The Federal Funding Accountability and Transparency Act (FFATA) was signed on September 26, 2006, and is intended to empower individual Americans with the ability to hold the government accountable for each spending decision. The FFATA legislation requires information on federal awards be made available to the public via a single, searchable website. Federal awards include grants, subgrants, loans, awards, cooperative agreements and other forms of financial assistance as well as contracts, subcontracts, purchase orders, task orders, and delivery orders. At this time, transactions below $25,000 are not included, though this may well change going forward. Currently the FFATA.org search includes information on federal spending for contracts and grants.

Means of Reporting

The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees (i.e. prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded and prime grant awardees will report against sub-grants awarded. The sub-award information entered in FSRS will then be displayed on www.USASpending.gov associated with the prime award furthering Federal spending transparency.

Timeline

Reporting is required by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $25,000 or in which the prime contractor awards any sub-contract greater than $25,000. The latter amount is cumulative in that for example if it is a three year award for $10,000 each year, the reporting would become mandatory after the 3rd year of the award.

What does this Mean for VUMC?

On a monthly basis, VUMC checks the fsrs.gov website and cross references with our own records. Since the current regulations provide for a tiered schedule of reporting decreasing amounts of awards as time goes on, we have taken the over-reporting approach and are basically reporting everything that we know will be included from now until March 1, 2011, the last date mentioned in the tier schedule.

Changes that have been made to allow for reporting on the government website include additions to the language in the Letter of Intent, upfront requests for necessary information from our sub-contractees, and changes in PEER and Coeus. Revisions in the FDP template have been made as well. These alterations will allow us to make the monthly reporting a fairly straight-forward two-step process. Departments will not need to make any substantive changes in their procedures. Another main change is that we must now have the DUNS number for every sub-awardee. The Executive Compensation requirement of FFATA is addressed by our requirement that every subawardee is registered in the federal Central Contractor Registration (CCR) system which tracks this information and well as the inclusion of this information on the amended FDP template.

For FFATA compliance purposes, VUMC will be tracking all outgoing subcontracts (whether originating from a Federal grant OR Federal contract). To enter information in Coeus correctly, it is important to understand the terms. When a sponsor makes an award to Vanderbilt, and Vanderbilt issues a Subcontract to another institution, that institution is called the organization in Coeus and PEER. This is also called an outgoing subcontract.

What does this mean for Subcontractees?

In accordance with U.S. regulations, including FFATA, it is necessary that potential subcontractees take the following two actions prior to VUMC submitting funding for a proposal: 1) Obtain a DUNS number, and 2) Register in the Central Contractor Registration (CCR) system.