EPA Publication Number 202K09001
                           EPA Contract Number EP-W-08-042
         Learner Manual - Module 3
      Federal Funding Accountability and
          Transparency Act (FFATA)
TRIBAL, U.S. TERRITORIES AND
INSULAR AREAS ADMINISTRATIVE
AND FINANCIAL GUIDANCE
MANUAL FOR ASSISTANCE
AGREEMENTS
"A Nation is a stable, historically developed community of people
who share territory, economic life, distinctive culture, and language.
Office of Environmental Justice, U.S. EPA
U.S. Environmental Protection Agency
Updated August 2013

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           Module 3: Federal Funding Accountability and Transparency Act
      This manual  was  originally  developed by  the  U.S.
      Environmental Protection Agency for  Tribal Nations,
      but  content also pertains to U.S. Territories and Insular
      Areas.  Exception: U.S. Territories  and Insular Areas are
      treated as states under Part 31 (and also under Part 35,
      Subpart  A  for PPGs, unlike  Tribes  that are  covered
      under Subpart B).
                                  Contents
MODULE 3: FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA)	3

  OVERVIEW	3
  REPORTING	7
  IDENTIFICATION REQUIREMENTS	9
  THE REPORTING SYSTEM	14
  ATTACHMENT TO MODULES	24
   Answers to Quizdom Actionpoint Questions	24
        EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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               Module 3: Federal Funding Accountability and Transparency Act
          Module 3:  Federal Funding Accountability and Transparency Act (FFATA)
   Tribal, U.S. Territories and
   Insular Areas Administrative
   and  Financial Guidance for
   Assistance Agreements
   Modules:
   Federal Funding
   Accountability and
   Transparency Act (FFATA)
    What is the Federal Funding Accountability

           and Transparency Act (FFATA)?


    •  The Federal Funding Accountability and Transparency Act
      (FFATA) or Transparency Act was signed on September 26. 2006
      and requires information on federal awards (federal financial
      assistance and expenditures) be made available to the public via a
      single, searchable website, which is www.USASpending.gov.

    •  Reporting requirements were phased in at certain dollar levels
      beginning in July 2010. All prime awardees of federal funds are
      now required to be in full compliance with the Federal Funding
      Accountability and Transparency Act (FFATA).
   Module 3:Federal Funding Accountability and
   Transparency Act (FFATA)
   ' Module g: Disadvantaged
   Business Enterprises (DBEs)
   •I'.'iVY,:'.'- JO. A vi~. iiiO; AC:'t'r;:,;^)[,
   Monitoring and Qoseout
                                      Module i: The Grant
                                      Module 3: Federal
                                      Funding
                                      Accountability and
                                      Transparency Act
                                      'FFATA)
                                       Slodofe 4: Grants

                                       Module 5:
                                       Administrative System
                                       Components
   Questions  addressed  in this  module

    What is the Federal Funding Accountability and
     Transparency Act (FFATA)?

    Why was the regulation passed?

    Who does the regulation pertain to?

    What are the reporting requirements?

    Where can I go to access resources and assistance?
                   Overview
What is the Federal Funding Accountability and
Transparency Act (FFATA)?
The Federal Funding Accountability and
Transparency Act (FFATA) was signed on
September 26, 2006.  The intent is to empower
every American with the ability to hold the
government accountable for each spending
decision. The end result is to reduce wasteful
spending in the government. The FFATA
legislation requires information on federal awards
(federal financial assistance and expenditures) be
made available to the public via a single,
searchable website, which is
www.USASpending.gov.
   What is the purpose of FFATA?
     "The intent is to empower
     every American with the
     ability to hold the
     government accountable
     for each spending decision.
     The end result is to reduce
     wasteful spending in the
     government."
                                                                        Transparency and Accountability
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               Module 3: Federal Funding Accountability and Transparency Act
   Federal Agency Responsibilities
   All federal agencies
   are required to
   report accurate
   information to
   USASpending.gov
   no later than 30
   days following the
   award or
   modification of a
   grant.

What are the responsibilities of federal agencies
under FFATA?
All federal agencies are required to report accurate
information to USASpending.gov no later than 30
days following the award or modification of a
grant.
On a bi-monthly basis, EPA submits information
on its assistance awards, including reference data
about prime recipients, to USASpending.gov  in a
government-wide format known as the Federal
Assistance Award Data System (FAADS) Plus.
On a quarterly basis the Agency must provide
assurances to OMB about the timeliness and
quality of its FAADS Plus submissions.
        How is EPA Helping to Reduce Reporting
                   Requirements ?
     On a bi-monthly basis, EPA submits information on its assistance
     awards, including reference data about prime recipients, to
     USASpending.gov (USASpending).

     Information about prime recipients will pre-populate FSRS records
     to the maximum extent possible.
   Definitions

    • Prime Awardee: an entity that directly
     receives Federal financial assistance from an
     agency to implement projects.
    • Prime Contractor: an entity that directly
     receives a procurement contract from a federal
     agency or financial assistance recipient.
   Definitions,  Continued
    • Sub Contractor: An entity that performs work
     for a prime contractor that is not an employee of
     the prime.
    • Sub-recipient or Sub-grantee: an entity that
     is accountable to the Recipient for the use of
     federal funds.
    • Sub Award: an award of financial assistance in
     the form of money, or property in lieu of money,
     made under an award by a recipient to an
     eligible sub-recipient or by a subrecipient to a
     lower tier sub-recipient.
Definitions
The Term subcontractor is also used to describe an
entity that receives a procurement contract from a
recipient or subrecipient.

The term subaward also includes financial
assistance when provided by any legal agreement,
even if the agreement is called a contract, but does
not include procurement of goods and services nor
does it include any form of assistance which is
excluded from the definition "award" in §215.2(e).

A subrecipient or subgrantee is an entity that is a
subrecipient under the standards in OMB Circular
A-133 and is accountable to the recipient for the
use of federal funds. The term subgrantee does not
include vendors who provide commercial goods
and services to the recipient under terms that
provide for a profit. Subrecipients are subject to the
OMB Cost Principles and the federal grant
regulations with regard to financial management
and procurement.

What is a sub-award?
The Office of Management & Budget issued
guidance identifying the requirement to report first-
tier sub-awards on April 6, 2010 and that guidance
may be found at the OMB Open Government site
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               Module 3: Federal Funding Accountability and Transparency Act
at http://www.whitehouse.gov/omb/open. That
guidance defines a sub-award as generally referring
to a monetary award made as a result of a Federal
award to a grant recipient or contractor to a sub-
recipient or sub-contractor respectively.
   What new reporting is required?
                Prime contract awardees of Feders
                 contracts of $25K or more must
                 report associated first-tier sub-
                   contracts of $25K or more.
                 Prime grant awardees of Federal
                ;rants of $25K or more must report
                 associated first-tier sub-grants of
                       $25Kormore.
                   Prime awardees must report
                executive compensation information
                for prime and sub-awardees if they
   What federal grants and contracts are
   subject to FFATA Executive Compensation
   Data Reporting?
    • New federal grants
     awarded on or after
     October i, 2010 in an
     amount equal to or
     greater than $25,000
    • New federal contracts
     awarded on or after
     March i, 2011 in an
     amount equal to or
     greater than $25,000

What federal contracts and grants are subject to
FFATA subaward and executive compensation
reporting requirements?
The subaward/executive compensation reporting
requirements generally apply to "new"
discretionary and mandatory EPA assistance
agreements,  equal to or exceeding $25,000,
awarded on or after October 1, 2010. EPA must
notify affected prime recipients of these
requirements using a standard award term and
condition published by OMB at 2 C.F.R. Part 170
Appendix A. Grants Management Offices (GMOs)
must include the standard term and condition in all
new awards  of $25,000 or more, except for awards
to individuals (i.e., where the recipient receives the
award as a natural person unrelated to any business
or non-profit organization they may own or operate
in their name).
    NOTE: While a new award of less than
 $25,000 is not subject to reporting, EPA may
subsequently add funds to meet or exceed the
     $25,000 threshold. If that occurs, the
reporting requirements apply absent an OMB-
  specified exception and the Agency would
   have to amend the award to include the
   standard OMB award term. If funding is
  deobligated from the agreement to reduce
 the award amount to less than $25,000, the
  reporting requirements continue to apply.
   What grants are NOT subject to the

   Transparency Act's reporting requirements?

    • Cooperative Research and Development Agreements (CRDAs), as
     denned under 15 U.S.C. 37103;
    • Federal awards to individuals who apply for or receive Federal
     awards as natural persons;
    • Federal awards to entities that had a gross income, from all
     sources, of less than $300,000 in the entities' previous tax year;
     and
    • Federal awards, if the required reporting would disclose classified
     information.
What federal contracts and grants are NOT
subject to the Transparency Act's reporting
requirements?
In addition to the award amount threshold, the
following are not subject to the Transparency Act's
reporting requirements:
    •   Grants, whether existing or new as of
        October 1, 2010, that are funded by the
        Recovery Act. Rather, such awards will
        continue to report those awards and
        related subawards through
        FederalReporting. gov;
    •   Transfers of title between Federal
        agencies of Federally owned property;
    •   Federal inter-agency transfers of award
        funds;
    •   Cooperative Research and Development
        Agreements (CRDAs), as defined under
        15 U.S.C. 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
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                Module 3: Federal Funding Accountability and Transparency Act
         $300,000 In the entities' previous tax
         year; and
         Federal awards, if the required reporting
         would disclose classified information.
   What does Executive Compensation
   Data reporting entail?
   Names and
         total
 compensation
    of the five
   most highly -<
 compensated
 officers must
  be reported,
         IF:
The entity in the preceding fiscal year
received 80 percent or more of its annual
gross revenues in Federal awards; AND
$25,000,000 or more in annual gross
revenues from Federal awards; AND
The public does not already have access to
this information under the Securities and
Exchange Act of 1934.
Reminder: What Federal contracts and grants are
subject to the FFATA subaward and executive
compensation reporting requirements?

 • New grants $25,000 and over. The grants subaward
  reporting functionality is available via www.fsrs.gov.

 • Reporting of Sub-contracts of Federal contracts and sub-
  grants of Federal grants where these sub-contracts and
  sub-grants are $25,000 and over.
   Prime recipient executive

   compensation  data
    • The prime recipient
     must include data in
     its SAM registration
     profile (formerly
     CCR) by the end of
     the month following
     the month it receives
     an award, and
     annually thereafter.
   SAM - are you in  compliance?
                                             Why is subaward information being collected?


                                              • The Federal Funding Accountability and Transparency
                                                Act requires OMB to "ensure the existence and
                                                operation of a single searchable website" for Federal
                                                awards.

                                              • The Transparency Act's definitions of "Federal
                                                awards" include not only prime awards for grants,
                                                cooperative agreements, loans, and contracts, but also
                                                sub-grants and sub-contracts.
                                          Why is sub-award information being collected?
                                          The Federal Funding Accountability and
                                          Transparency Act (Transparency Act) requires
                                          OMB to "ensure the existence and operation of a
                                          single searchable website" for Federal awards. The
                                          Transparency Act's definitions of "Federal awards"
                                          include not only prime awards for grants,
                                          cooperative agreements, loans, and contracts, but
                                          also sub-grants and sub-contracts.
         •£M HJ* AWARli MAKAOEUEKT
            The System for Award
            Management (SAM) was
            deployed as a replacement for
            CCR on July 30, 2012.
            SAM is combining 8 federal
            procurement systems & the
            Catalog of Federal Domestic
            Assistance (CFDA) to provide
            one streamlined, more user-
            friendly system.


            —more later in the Module—
What is required to be reported as part of

the Transparency Act?

 FFATA prescribes specific pieces of information to be reported.


 i. The following data for subawards equal to or greater than $25K is required:
      a. Name of entity receiving award
      b. Amount of award
      c. Funding agency
      d. NAICS code for contracts / CFDA program number for grants
      e. Program source
      (http s ://www. federal rep orting. gov/federal reporting/programSourceCodes.di
      f. Award title descriptive of the purpose of the funding action
      g. Location of the entity (including congressional district)
      h. Place of performance (including congressional district)
      i. Unique identifier of the entity and its parent; and
     j. Total compensation and names of top five executives
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               Module 3: Federal Funding Accountability and Transparency Act
                  Reporting
What is required to be reported as part of the
Transparency Act?
FFATA prescribes specific pieces of information to
be reported:

1. The following data about sub-awards greater
than $25K

    a.  Name of entity receiving award
    b.  Amount of award
    c.  Funding agency
    d.  NAICS code for contracts / CFDA
        program number for grants
    e.  Program source
    f.   Award title descriptive of the purpose of
        the funding action
    g.  Location of the entity (including
        congressional district)
    h.  Place of performance (including
        congressional district)
    i.   Unique identifier of the entity and its
        parent; and
    j.   Total compensation and  names of top five
        executives (same thresholds as for primes)

2. The Total Compensation and Names of the
top five executives if:

    a.  More than 80% of annual gross revenues
        are from the Federal government, and
        those revenues are greater than $25M
        annually, and
    b.  Compensation information is not already
        available through reporting to the SEC.
Classified information is exempt from the prime
and sub-award reporting requirement as are
contracts with individuals.

What does total compensation entail?
2 CFR Part 170 e.5 of the award term in Appendix
A: Total compensation means the cash and noncash
dollar value earned by the executive during the
recipient's or subrecipient's preceding fiscal year
and includes the following (for more information
see 17 CFR 229.402(c)(2)):

   i.    Salary and bonus.

  ii.    Awards of stock, stock options, and stock
        appreciation rights. Use the dollar amount
        recognized for financial  statement
        reporting purposes with respect to the
        fiscal year in accordance with the
        Statement of Financial Accounting
        Standards No. 123 (Revised 2004) (FAS
        123R), Shared Based Payments.
  iii.    Earnings for services under non-equity
        incentive plans. This does not include
        group life, health, hospitalization or
        medical reimbursement plans that do not
        discriminate in favor of executives, and
        are available generally to all salaried
        employees.
  iv.    Change in pension value. This is the
        change in present value of defined benefit
        and actuarial pension plans.
  v.    Above-market earnings on deferred
        compensation which is not tax-qualified.

  vi.    Other compensation, if the aggregate
        value of all such other compensation (e.g.
        severance, termination payments, value of
        life insurance paid on behalf of the
        employee, perquisites or property) for the
        executive exceeds $10,000.
As of October 1, 2010, definitions for data
elements may be found at the data dictionaries
maintained on www.USAspending.gov.
   What is  NAICS?
     North American Industry
     Classification System
     °  Was developed by OMB as the
       standard for use by Federal
       agencies in classifying business
       establishments for collection.
       tabulation, presentation and
       analysis of statistical data
       describing the US economy.
     °  It provides uniformity and
       comparability in the presentation
       of these statistical data.
   What is required to be reported as part of
   the Transparency Act?  Continued:
    2. Prime and Sub-recipients Executive Compensation Data:

      Name and total compensation of the five most highly compensated
      officers if:

        a)  Receives more than 80% of annual gross revenues from the
           federal government, and those revenues are greater than
              annually and
        b) Compensation information is not already available through
          reporting to the Securities and Exchange Commission
          (SEC).

    To access company information at the SEC go to: http://www.sec.gov/answers/execomp.htm
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                Module 3: Federal Funding Accountability and Transparency Act
   How Long Do  I Have To Report?

   Prime awardees must report first-tier subaward
   information by the end of the month/allowing the month
   the award or award's obligation was made

    •  For example, if a subaward is made on August 5 the
      prime awardee would have until September 30 to report
      the subaward

    •  subawards made during August all have until September
      30 to report
How much time does a prime awardee have to
report executive compensation or sub-award
information?
The prime recipient will have until the end of the
month plus one additional month after an award or
sub-award is obligated to fulfill the reporting
requirement. For example, if a  sub-award was
made on March 5,2012 the prime recipient had
until April 30, 2012 to report the sub-award
information.
   How Does Reporting Occur?

    Prime awardees must:
    • Register with the System for Award Management (SAM;
     formerly CCR)
      ° Subawardees must register with Dun & Bradstreet to
       get a DUNS number.
    • Respond to the executive compensation questions
     through SAM
    • Report first-tier subaward information through the
     FFATA Subaward Reporting System (FSRS)
   Are subawardees required to report information
   directly into FSRS in compliance with this
   Guidance and the Transparency Act?

    A. Yes
    B. No
How are applicants informed of FFATA
requirements?

Two clauses in Section VI of announcements:
1. Applicants must ensure that they have the necessary
   processes and systems in place to comply with the
   subaward and executive total compensation reporting
   requirements established under OMB guidance at 2
   CFR Part 170 unless they qualify for an exception from
   the requirements, should they be selected for funding.
Funding Announcements,  Continued
2. System for Award Management (SAM) and Data
  Universal Numbering System (DUNS) Requirements

   Unless exempt from these requirements under OMB guidance at 2 CFR
   Part 25 (e.g., individuals), applicants must:

     I.  Be registered in SAM prior to submitting an application or proposal
       under this announcement.


       during which it has an active Federal award or an application or proposal
       under consideration by an agency, and

     II.  Provide its DUNS number in each application or proposal it submits to the
      e note: SAM and DUNS will be
                              e detail later in the Module
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              Module 3: Federal Funding Accountability and Transparency Act
Note:  Please note that while the DUNS/SAM
clause requires that applicants be registered
 in SAM and have a  DUNS number at time of
 proposal submission, applicants who fail to
     do so will not be rejected from the
competition. Rather, as provided in the OMB
  guidance, the effect of noncompliance is
   measured at the  time of award and the
Agency may not make an award to an entity
     if they have not complied with the
 SAM/DUNS requirements. In such cases, the
 Agency may determine that the applicant is
 not qualified  to receive an award and may
use that determination as a basis to make an
        award to another applicant.
What exemptions are therefrom the SAM and
DUNS requirements?
Exemptions listed in 2 CFR Part 25.110:
(b) Exemptions for individuals. None of the
requirements in this part apply to an individual
who applies for or receives Federal financial
assistance as a natural person (i.e., unrelated to
any business or non-profit organization he or she
may own or operate in his or her name).
(c) Exemptions for Federal agencies. The
requirement in this part to maintain a current
registration in SAM does not apply to an agency of
the Federal Government that receives an award
from another agency.

(d) Other exemptions. (1) Under a condition
identified in paragraph (d)(2) of this section, an
agency may exempt an entity from an applicable
requirement to obtain a DUNS number, register in
SAM, or both.

(i) In that case, the agency must use a generic
DUNS  number in data it reports to
USASpending.gov if reporting for a prime award
to the entity is required by the Federal Funding
Accountability and Transparency Act (Pub. L.
109-282, hereafter cited as "Transparency Act").
(ii) Agency use of a generic DUNS should be used
rarely for prime award reporting because it
prevents prime awardees from being able to fulfill
the subward or executive compensation reporting
required by the Transparency Act.

(2) The conditions under which an agency may
exempt an entity are—

(i) For any entity, if the agency determines that it
must protect information about the entity from
disclosure, to avoid compromising classified
information or national security or jeopardizing the
personal safety of the entity's clients.
(ii) For a foreign entity applying for or receiving an
award or subaward for a project or program
performed outside the United States valued at less
than $25,000,  if the agency deems it to be
impractical for the entity to comply with the
requirement(s).
   How Are Recipients Notified of
   FFATA Requirements?
   FFATA requirements
   will be listed in the
   Terms and Conditions
   of the grant award.
   Read carefully!
How are recipients notified of the FFATA
requirements?
FFATA requirements will be listed in the Terms
and Conditions of the grant award. Read carefully!
                                Identification Requirements
How are recipients notified of the System for Award Management and Universal Identifier requirements?
System for Award Management and Universal Identifier requirements will be listed in the Terms and
Conditions of the grant award.

I. System for Award Management and Universal Identifier Requirements.

    A. Requirement for System for Award Management (SAM). Unless you are exempted from this
       requirement under 2 CFR 25.110, you as the recipient must maintain the currency of your information
       in SAM until you submit the final financial report required under this award or receive the final
       payment, whichever is later.  This requires that you review and update the information at least annually
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              Module 3: Federal Funding Accountability and Transparency Act
        after the initial registration, and more frequently if required by changes in your information or another
        award term.

    B.  Requirement for Data Universal Numbering System (DUNS) numbers. If you are authorized to make
        subawards under this award, you:

        1.   Must notify potential subrecipients that no entity (see definition in paragraph C of this award term)
            may receive a subaward from you unless the entity has provided its DUNS number to you.

        2.   May not make a subaward to an entity unless the entity has provided its DUNS number to you.

    C.  Definitions. For purposes of this award term:

        1.   System for Award Management (SAM) means the Federal repository into which an entity must
            provide information required for the conduct of business as a recipient. Additional information
            about registration procedures may be found at the SAM Internet site (currently at
            http://www.sam.gov).

        2.   Data Universal Numbering System (DUNS) number means the nine-digit number established and
            assigned by Dun and Bradstreet,  Inc. (D&B) to uniquely identify business entities. A DUNS
            number may be obtained from D&B by telephone (currently 866-705-5711) or the Internet
            (currently at http://fedgov.dnb.com/webform).

        3.   Entity, as it is used in this award term, means all of the following, as defined at 2 CFR part 25,
            subpart C:

            a.   A Governmental organization, which is a State, local government, or Indian tribe;
            b.   A foreign public entity;
            c.   A domestic or foreign nonprofit organization;
            d.   A domestic or foreign for-profit organization; and
            e.   A Federal agency, but only as a subrecipient under an award or subaward to a non-Federal
                entity.

        4.   Subaward:

            a.   This term means a legal instrument to provide support for the performance of any portion of
                the substantive project or program for which you received this award and that you as the
                recipient award to an eligible subrecipient.

            b.   The term does not include your procurement of property and services needed to carry out the
                project or program (for further explanation, see Sec. --.210 of the attachment to OMB Circular
                A-133, "Audits of States, Local Governments, and Non-Profit Organizations").

            c.   A subaward may be provided through any legal agreement, including an agreement that you
                consider a contract.
        5.   Subrecipient means an entity that:
            a.   Receives a subaward from you under this award; and
            b.   Is accountable to you for the use of the Federal funds provided by the subaward.
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   What is a DUNS Number?
    The Data Universal Numbering System or DUNS
    Number is a means of identifying business entities
    on a location-specific basis. Assigned and
    maintained solely by Dun and Bradstreet, this
    unique nine-digit identification number has been
    assigned to over 100 million businesses
    worldwide.

      Do you know if your organization has a DUNS number?
How do we get the Data Universal Numbering
System (DUNS) number?
The Dun and Bradstreet (D&B) Data Universal
Numbering System (DUNS) number is an
application requirement from the Office of
Management and Budget (OMB). Assistance
agreement applicants must have a DUNS number.
You can get a DUNS number in two ways:
    By calling the toll-free DUNS number request
        line at  1-866-705-5711.
    Online at http://www.dnb.com/
        http://fedgov.dnb.com/webform/displayH
        omePage.do.

A DUNS number will be issued in one business
day at no cost.
                                                          The DUNS Number
          Request a Dun and Bradstreet
  Data Universal Numbering System (DUNS) number
             1-866-705-5711—Free
         http://fedgov.dnb.com/webform
When issuing subawards under prime federal
awards received by the Tribal Nation, will the
subrecipient be required to obtain a  DUNS
Number?
 Yes. In accordance with FFATA, all subrecipients are
 required to have a DUNS number before the Tribal Nation
 can execute a subaward or subcontract.
 Make sure you keep track of your DUNS number expiration date!
   Why does an organization have to provide a
   DUNS number?

    The federal government's Office of Management & Budget has
    adopted the use of DUNS numbers as a way to keep track of how
    federal grant money is awarded and dispersed.
          ^
            «s>

                                                          V
                                                          The DUNS number must be registered annually
                                                          Overlooking this requirement to update your
                                                          registration may cause delays in future funding for
                                                          your organization!
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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                Module 3: Federal Funding Accountability and Transparency Act
What is the System for Award Management
(SAM)?
The System for Award Management (SAM) is the
official, on-line registrant database for the U.S.
Federal Government.  SAM Collects, validates,
stores and disseminates data in support of agency
acquisition and award missions.

Unless exempt from these requirements under
OMB guidance at 2 CFR Part 25 (e.g., individuals),
applicants must:
1. Be registered in SAM prior to submitting an
application or proposal under this announcement.
SAM information can be found at
https://www.sam.gov.
2. Maintain an active SAM registration with
current information at all times during which it has
an active Federal award or an application or
proposal under consideration by an agency.
                                                              What is the System for Award Management (SAM)?
                                                                  The System for Award Management (SAM) is a
                                                               Federal Government owned and operated free website
                                                                 that consolidates the capabilities of CCR/FedReg,
                                                                              ORCA, and EPLS.
                                                                         SAM was deployed July 30, 2O12.
                                                                 Future phases of SAM will add the capabilities of other
                                                               systems used in Federal procurement and awards processes.
                                                              Who is required to register in SAM?

                                                               Anyone (sole proprietors, corporations, partnerships and
                                                               governmental organizations) desiring to do business with
                                                               the federal government must register in SAM.

                                                               Exception: SAM registration is not required for individuals
                                                               seeking grants.
                                                                  Do you know if your organization is registered in SAM?
The Migration from CCR to SAM


 What do I need to do?

 •  I am already registered with CCR: You need to create an
   account with SAM. You will need to know the email address and
   username from your CCR account in order to migrate your existing
   information and permissions into your new SAM account.

 •  My CCR registration is incomplete: Any information entered
   into CCR will be moved to SAM. You can complete the registration
   there.

 •  I am not yet registered with CCR: Go to SAM and create your
   account there; CCR is no longer active.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
                                  Page 12 of 25

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                Module 3: Federal Funding Accountability and Transparency Act
   How does an organization create an

   account in SAM?

   NEW users:
   Step i: Access the SAM online registration at www.satn.gov. Click on
   "Register New Entity" from the left side navigation pane. You must
   have a Data Universal Numbering System (DUNS) number
   in order to begin the registration process.

   Step 2:  Complete and submit the online registration. If you already
   have the necessary information on hand, the online registration
   takes approximately 30 minutes to complete, depending upon the size
   and complexity of your business or organization.
     Encourage the organizations you are working with to become registered through SAM!
Online SAM Help
        SSAM
         How long does it take to get a
           SAM application processed?
    New registrations can take an
    average of 3-5 business days to
    process in SAM.
SAM does notify customers (usually electronically) when
they need to renew their registration. However, if your
Points of Contact (POC's) change, the reminder email may
go to someone who is no longer in your organization. To
change the Point of Contact, you need to contact the
Federal Service Desk directly.
     What does it cost to register in SAM?
How long does it take to get a SAM
application processed?
    Because SAM is a federally mandated and funded
    program, there is no cost to registrants for registering in
    SAM.
A.  Within 24 hours
B.  Two days
C.  One week
D.  Six months
E.  3-5 days
            EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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             Module 3: Federal Funding Accountability and Transparency Act
                                                     Now let's review the FFATA
                                                           reDOrtine Drocess:
                                                             www.FSRS.sov
   IT IS YOUR RESPONSIBILITY
       Is there someone within your
      organization delegated with the
    responsibility to acquire/maintain:
       SAM
    registration
    and updated
    information
   DUNS
registration
and updated
information
  FFATA
compliance
                                                  What is the FSRS?
                                                              torn Transparency Act Subawanl
                                                              Ruportlnx Syttlcm (FSRS)
                                                                      •
                                                         The Reporting System
                                                What is FSRS?
                                                The FFATA Subaward Reporting System (FSRS)
                                                is the reporting tool Federal prime awardees (i.e.
                                                prime contractors and prime grant 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, thereby furthering
                                                Federal spending transparency.
         EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                               Page 14 of 25

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                  Module 3: Federal Funding Accountability and Transparency Act
    Introduction/Background
     The Federal Funding Accountability and Transparency Act (FFATA)
     necessitates a system to allow prime grant/contract recipients to be
     able to report on subaward activity and executive compensation.

     •  FFATA Subaward Reporting System - FSRS.gov
     *  July 2010, "FSRS.gov" launched as the resource for Prime Awardees to report on
       FFATA-required Contract sub-contract activity and executive compensation
     *  October 2010 "FSRS.gov" expanded to incorporate FFATA-required Grant
       subaward and executive compensation reporting
     *  Prime Awardees are those recipients of the grant/contract awards.
     Note: Sub-co
     Aiuardees)
              itractors/awardees do not report through the system (only Prin
                     https ://www .fsrs .gov/
  Reporting Timeline for Grant Recipients, continued


 • For those new Federal grants as of October 1. 2O1O. if the
   initial award is equal to or greater than $25,000, reporting of
   subaward and executive compensation data is required.

 • If the initial award is below $25,000 but subsequent grant
   modifications result in a total award equal to or over $25,000,
   the award will be subject to the reporting requirements, as of the
   date the award exceeds $25,000.

 • If the initial award equals 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 and this
   Guidance.
    Who is required to  file a  FFATA
    report  in  FSRS?
    The EFATA Subaward Reporting
    System (FSRS) will collect data
    from Federal prime awardees on
    subawards they make:
    • A prime grant awardee is
      required to report on its sub-
      grants, and
    • A prime contract awardee is
      required to report on its sub
      contracts.
Reporting Timeline for Prime Contractors

 In accordance with Federal Acquisition Regulation clause
 52.204-10 (Reporting Executive Compensation and First-
 Tier Sub-contract Awards), Prime Contractors awarded a
 federal contract or order are required to file a FFATA
 subaward report by the end of the month following the
 month in which the prime contractor awards any sub-
 contract greater than $25,000.

 The reporting timeline was phased-in. Starting March 1,
 2011, reporting on all sub-contracts greater than $25,000
 became mandatory.
     Reporting Timeline for Grant Recipients

     In accordance with 2 CFR Chapter l, Part 170 REPORTING subaward
     AND EXECUTIVE COMPENSATION INFORMATION, Prime
     Awardees awarded a federal grant are required to file a FFATA
     subaward report 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. The reporting requirements are as follows:

     •  This requirement is for both discretionary and non-discretionary
       grants awarded on or after October l, 2010.

     •  All subaward information must be reported by the prime awardee.
If an award recipient receives a grant from a federal
agency that is equal to or greater than $25,000, and
meets the other threshold criteria, the prime awardee
must report its own executive compensation data by:
A.  The end of the month following the month the award
    or obligation was made
B.  Within six months from the date of the award
C.  Within twelve months from the date of the award
D.  By the end of the grant project
E.  None of the above
             EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                                          Page 15 of 25

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              Module 3: Federal Funding Accountability and Transparency Act
   If an award recipient issues a subaward or subcontract to
   another organization, is it required to report executive
   compensation data of the subrecipient?

   A. Yes, regardless of the amount awarded
   B. No
   C. Yes, if the award amount equals or exceeds $25,000
   D. It depends on the Terms and Conditions of the award
   E. All of the above
        recipients to electronically report their
        sub-award activity.
        July 2010, launched "FSRS.gov" to serve
        as the resource for prime awardees to
        report on FFATA-required contract sub-
        award activity and executive
        compensation.
        October 2010, "FSRS.gov" expanded to
        incorporate FFATA-required grant sub-
        award and executive compensation
        reporting.
                                                         FSRS Awardee Login  Page
   FSRS System Overview

The FSRS System Overview
The Federal Funding Accountability and
Transparency Act (FFATA) necessitated a system
to allow prime grant award and prime contract
recipients to report sub-award activity and
executive compensation.

    •   The FFATA Sub-award Reporting
        System - FSRS.gov - is the system that
        allows grant award and contract award
How do new users set up an account?
New Users:

Users point their browser to
https://www.FSRS.gov. Note: users do not need to
re-register if they have an existing Electronic
Subcontracting Reporting System (eSRS)
Contractor user account (www.esrs.gov).
    1.  The awardee clicks on the "Awardees"
        link within the "Log-In" or "Register
        Now" box
    2.  To register, the user clicks the "Register"
        button under the "new awardees: register"
        section.

    3.  The registrant completes the two step
        process that opens (forms capture
        registration data).

Note: Throughout the system a red asterisk (*)
designates that the field is required.
    4.  The user enters their organization's
        DUNS Identification Number and clicks
        the "Next" button.

    5.  Some form data may already be populated
        on the form from SAM.gov.  This is based
        on the DUNS entered in step one.
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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               Module 3: Federal Funding Accountability and Transparency Act
    6.   Users must complete all required fields
        (indicated with a red asterisk) and click
        the "submit" button.
    7.   After submitting this form, a confirmation
        email is sent to the email address provided
        during the registration. The confirmation
        email presents instructions on how to
        finalize the registration process. An
        account is only activated after the user
        follows the instructions presented in the
        email that is sent to them.
    8.   After a user has confirmed their
        registration, as outlined in the email that
        they received, the user can return to the
        Log-In page (see Existing Users, page 14
        of the FSRS Users Guide -
        https://www.fsrs.gov/documents/FSRS Award
        ee_User_Guide.pdf). They can then enter
        their e-mail address and password (e-mail
        address will be the user "login ID"), and
        click the "Login" button, to login to
        FSRS.

Terms of Use Agreement

    1.   All users are required to agree to the
        Terms of Use for FSRS.
    2.   Use the side scroll bar resource to review
        the terms and conditions in their entirety.
    3.   A user can click "OK" to move forward or
        "Log-Off to exit.
   FSRS Awardee Home Page
Home Page Features

    1.   The Navigation bar at the top of the
        screen allows users to move through the
        system. This bar is available on every
        screen throughout the system. Please read
        "Section 2.2 Navigation Overview" of the
        FSRS Users Guide for more information.
        https://www.fsrs.gov/documents/FSRS  Award
        ee User Guide.pdf)
    2.   The "Alerts" section shows messages that
        require a user's attention.

    3.   "Announcements" are created by FSRS
        administrators.

    4.   The quicklink buttons on the left hand
        side of the screen allow users to quickly
        create a new FFATA Report, or to link an
        award to their work list. Please see the
        corresponding sections of the FSRS Users
        Guide for more information.  (See link
        above)

Creating a Profile
    1.   If a user clicks on "Profile" in the top
        navigation menu bar, they can review
        their core contact information on this
        screen.

    2.   To edit profile information, the user
        should click the "Edit" button. After
        making desired changes, the user should
        click the "submit" button to enter the
        changes.

    3.   To change a password, users click on the
        "Password" tab near the top of the page.
        Users may enter a new password on that
        page. The user should click "save
        password" when done. For security
        purposes, passwords must meet the
        following criteria:

        a.  Must be between 10 and 14
            characters
        b.  Must contain 2 of each of the
            following: lower case letter, upper
            case letter, number, special character
                                                           In FSRS,  PrimeAwardees Can.
   Manage FFATA Reports
     - Search for an Award
     - Create New FFATA Subaward Report
     - Save Draft FFATA Subaward Report
     - Delete Draft FFATA Subaward Report
     - Submit New FFATA Subaward Report
     - Reopen and Revise Submitted FFATA Subaward Report
     - Copy Existing FFATA Subaward Report
     - Manage FFATA Subaward Report List
     - Submit Multiple FFATA Subaward Reports

   Manage Awardee Worklist
     - Organize Prime Awards Associated with Registered DUNS
     - Search for Prime Award
     - Add Prime Award to / Remove Prime Award from Worklist
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                         Page 17 of 25

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              Module 3: Federal Funding Accountability and Transparency Act
Overview of the Worklist
    1.   The Worklist main navigation allows the
        prime awardee to manage and review the
        awards for which they have reporting
        responsibility.
    2.   The user can search for and add awards
        (both contracts and grants awarded to
        their registered DUNS number) to their
        worklist from contracts reported in the
        Federal Procurement Data System - Next
        Generation (FPDS-NG) and grants
        reported through the Agency's Federal
        Assistance Award Data System
        (FAADS+) submissions to USAspending.
    3.   From the worklist they can create new
        FFATA sub-award reports against those
        prime awards.

    4.   Users can view unassigned prime
        contracts and/or grants awarded to their
        registered DUNS number and add them to
        their worklist.

    5.   This navigation provides a way to review
        an award and all associated reports for
        that award (view existing reports).
   Create New FFATA Subaward Report
     • / .
              j\ aterti
   Step 1 - Instructions
Step 2 - Enter Contract / Award # (1 of 3)
      pSI
Step 2 - Enter Contract / Award # (2 of 3)
                                                       Step 2 - Enter Contract / Award # (3 of 3)
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last U pdated April 2013                                                                    Page 18 of 25

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             Module 3: Federal Funding Accountability and Transparency Act
   Step 3 - Grant Award Details
Step 4 - Prime Award Details (3 of 5)
                                     =-- <§>
   Step 4 - Prime Award Details (1 of 5)
Step 4 - Prime Award Details (4 of 5)
                                                 Then answer 17
                                                                              .,1 , .. -; | •..,
   Step 4 - Prime Award Details (2 of 5)
Step 4 - Prime Award Details (5 of 5)
         EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last U pdated April 2013                                                               Page 19 of 25

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             Module 3: Federal Funding Accountability and Transparency Act
   Step 5 - Subawardee Data (1  of 3)
Step 6 - Review
                                      --- <§)
   Step 5 - Subawardee Data (2 of 3)
Step 7 - Submit Report
                                                        .^—

   Step 5 - Subawardee Data (3 of 3)
   -
    -;'
    •r-
What is the FFATA Subaward Reporting
System (FSRS)?

A. A government contractor
B. An optional reporting tool
C. The reporting tool Federal prime awardees use
   to capture and report subaward and executive
   compensation data regarding their first-tier
   subawards to meet reporting requirements
D. None of the above
E. All of the above
         EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                 Page 20 of 25

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                Module 3: Federal Funding Accountability and Transparency Act
                                                                 3.   There is also a navigational link for the
                                                                     FSD (help desk) contained in the lower
                                                                     navigational bar that is presented when a
                                                                     user is logged into the system.
                                                                 4.   Clicking the FSD link opens a transition
                                                                     page introducing the Federal Service Desk
                                                                     (FSD) where users can secure assistance.

                                                                 5.   The link to access the FSD is presented on
                                                                     this screen (FSD.gov).

                                                                 6.   Users are automatically re-directed to the
                                                                     FSD 30 seconds after navigating to the
                                                                     transition page.
                 "^
        */*
\             •
 Hete js available!
                                                                          Service Desk (1  of 4)
                                                                  ^ 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
            Where Can  I Find Help?
        FSRS is one of several systems
        served by the Federal Service
        Desk (www.fsd.gov) for Tier i
        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


        Resources Page
                                                                          Service Desk (2  of 4)
 The Help Desk
     1.   Users can access the Federal Service Desk
         (FSD) directly from within the system.
         FSD is the help desk organization that
         provides help desk support for FSRS.gov.

    2.   A link to the FSD is presented on the
         home page.
                                                           >•  There are multiple ways to find
                                                             information within the FSD site; th
                                                             easiest is the Answer Center
                                                                or narrow the s
                                                                         search terms in the bo:
                                                                         arch by system
                                                             FSRS feeds the Answer Center with
                                                             new questions and updated
                                                             information continually
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                               Page 21 of 25

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             Module 3: Federal Funding Accountability and Transparency Act
           Service Desk (3  of 4)
Frequently Asked Questions (FAQ)
           Service Desk (4 of 4)
           FFATA in  a  nutshell
                                       PRIME
                                       Grant or
                                       Contract
                                       >S 25,000
                          $25,000,000 c
                                         Public doesn't
                                          already have
                                                                       Public doesn't
                                                                       already have
                                                                       access to data
                                                                       hroueh the SEC
         EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                 Page 22 of 25

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                Module 3: Federal Funding Accountability and Transparency Act
                                                                    Questions?  Contact:
     • Make sure to identify who is responsible
       for coordinating FFATA requirements:
       -  DUNS number
       °  SAM Registration
       -  FSRS Database

Check to make sure you are in compliance!
      Laurice Jones
 U.S. Environmental Protection
         Agency
Office of Grants and Debarment
1200 Pennsylvania Avenue, N.W.
     Mail Code: sgosR
   Washington, DC 20460
      202-564-0223
   Jones. laurice(g)epa.gov
     Elizabeth January
      Program Analyst
  U.S. Environmental Protection
         Agency
     11 Technology Drive
      Mail Code: EQA
   N. Chelmsford, MA 01863
       617-918-8655
January. elizabetlitS1 epamail.epa.gov
     OR YOUR GRANT SPECIALIST!
                                                            Forms available for download at httD://www.eDa.gov/ogd/forms/forms.htm
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013                                                                               Page 23 of 25

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                                                                Attachment to Module 3
                                                        Answers to Quizdom Actionpoint Questions
23
                          Question (bold font indicates correct answer'
         Are subawardees required to report information directly into FSRS in
         compliance with this Guidance and the Transparency Act?
              A.   Yes
              B.   No
No. The prime awardee must report all information associated with a Federal grant, either
regarding executive compensation data for prime awardees or subawardees, or any other
information associated with subawards.

The subawardee, however, has an obligation to provide to the prime grant awardee all
information required for such reporting. This includes subawardee entity information, subawardee
DUNS number, subawardee Parent DUNS number, if applicable, and relevant executive
compensation data, if applicable. If the subawardee is registered in SAM, this information may be
migrated into FSRS to facilitate the prime awardee's reporting, as required under this guidance.
46
         How long does it take to get a SAM application processed?
              A.   Within 24 hours
              B.   Two days
              C.   One week
              D.   Six Months
              E.   3-5 days
New registrations can take an average of 3-5 business days to process in SAM. This timeframe may
be longer if the information you provide is flagged for manual validation. If you notice your
registration has had a "Submitted" status for longer than 10 business days, and you have not
otherwise been contacted to correct or update information, please contact the Federal Service
Desk at 866-606-8220 or https://www.fsd.gov.
59
         If an award recipient receives a grant from a federal agency that is equal to
         or greater than $25,000, and meets the other threshold criteria, the prime
         awardee must report its own executive compensation data by:
              A.  The end of the month following the month the award or
                  obligation was made
              B.  Within six months from the date of the award
              C.  Within twelve months from the date of the award
              D.  By the end of the grant project
              E.  None of the above
Prime awardees who meet threshold criteria must report executive compensation data by the end
of the month following the month the award or obligation was made. For example, if a Federal
agency awards a grant to a prime awarded on October 1, the prime awarded must report
executive compensation data by November 30.

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                                   Module 3: Federal Funding Accountability and Transparency Act (FFATA)
62
         If an award recipient issues a subaward or subcontract to another
         organization, is it required to report executive compensation data of the
         subrecipient?
              A.   Yes, regardless of the amount awarded
              B.   No
              C.   Yes, if the award amount equals or exceeds $25,000
              D.   It depends on the Terms and Conditions of the award
              E.   All of the above
                                             Yes, if the award amount equals or exceeds $25,000 the reporting of executive compensation of
                                             the subrecipient is required.

                                             Note:
                                             If the initial award is below $25,000 but subsequent grant modifications result in a total award
                                             equal to or over $25,000, the award will be subject to reporting requirements, as of the date the
                                             award exceeds $25,000

                                             If the initial award equals 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 of this Guidance.
86
         What is the FFATA Subaward Reporting System (FSRS)?
              A.   A government contractor
              B.   An optional reporting tool
              C.   The reporting tool Federal prime awardees use to capture and
                  report subaward and executive compensation data regarding
                  their first-tier subawards to meet reporting requirements
              D.   None of the above
              E.   All of the above
                                             The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees (i.e.
                                             prime contractor and prime grant recipients) use to capture and report subaward and executive
                                             compensation data regarding their first-tier subawards to meet FFATA reporting requirements.
                                             Prime contract awardees will report against subcontracts awarded and prime grant awardees will
                                             report against subgrants awarded. The subaward information entered in FSRS will then be
                                             displayed on www.USASpending.gov associated with the prime award furthering Federal spending
                                             transparency.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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