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 ------- 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 Last Updated April 2013 Page 2 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 3 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 4 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last U pdated April 2013 Page 5 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 6 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 7 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 8 of 25 ------- 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 EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last Updated April 2013 Page 9 of 25 ------- 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. EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements Last U pdated April 2013 Page 10 of 25 ------- Module 3: Federal Funding Accountability and Transparency Act 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 1-866-705-5711Free 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 Last Updated April 2013 Page 11 of 25 ------- 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 ------- 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 Last U pdated April 2013 Page 13 of 25 ------- 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 ------- 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 ------- 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 Last U pdated April 2013 Page 16 of 25 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 Page 25 of 25 ------- |