The Federal Funding Accountability and Transparency Act (FFATA) Requirements for Subcontracts
The Federal Funding Accountability and Transparency Act (FFATA) makes information on federal expenditures of taxpayer dollars more accessible to the public. FFATA requires prime recipients of federal awards to report on their subawards via a public website. Subawards include subcontracts, subgrants and other instruments awarding funds to third party recipients. For simplicity, subawards are referred to as “subcontracts” hereafter.
Reporting and Registration Requirements
- UTC must report on subcontracts of $25,000 or more which are awarded from UTC’s federal contracts, grants, and cooperative agreements. If a subcontract that was originally less than $25,000 is increased to $25,000 or more, FFATA reporting requirements come into effect at the time of the increase.
- FFATA requires subcontractors to have a Dun & Bradstreet (DUNS) number.
- UTC requires subcontractors to register in the federal Central Contractor Registration (CCR). The FFATA reporting website uses data from DUNS and CCR, streamlining the process.
The following are excluded from FFATA reporting requirements:
- Grants funded with Federal Stimulus money (Note: some Stimulus contracts may require FFATA reporting)
- Awards that would disclose classified information if reported
- Awards to individuals if the award is unrelated to any business or non-profit organization which the individual owns or operates in his or her own name
Project Director/Principal Investigator Responsibilities
- Send the Subcontractor a FFATA Data Collection Form, which also informs the Subcontractor of the requirement to register in CCR and obtain a DUNS number. The information form, CCR and DUNS registration must be completed before UTC enters into the subcontract.
- Include the following wording in relevant subcontracts: This contract is subject to the Federal Funding Accountability and Transparency Act (FFATA), which requires reporting of certain information about subcontracts made under the University’s prime award. Subcontractor will provide required FFATA information promptly upon request of University. Subcontractor certifies that it has obtained a Dun and Bradstreet (DUNS) number, is registered in the Central Contractor Registration (CCR), and will maintain its CCR registration during the term of this contract.
Office of Partnerships and Sponsored Programs Responsibilities
- Provide guidance and assistance concerning subcontracts and FFATA during proposal development.
Office of Research Integrity Responsibilities
- Review the completed FFATA Data Collection Form and forward to Business & Financial Affairs for entry into the FFATA reporting website.
Business & Financial Affairs Responsibilities
- Review FFATA responsibilities and procedures with project director during restricted account orientation.
- Enter information on the FFATA reporting website by the end of the next month after a subcontract is obligated. For example, if a subcontract is entered into on October 15, 2010, UTC has until November 30, 2010 to report the sub-award information.
- Review and process subcontracts and obtain authorized UTC signature.