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
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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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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!
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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.
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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
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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
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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
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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
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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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