The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime 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 associated with the prime award furthering Federal spending transparency.

REPORTING TIMELINE FOR PRIME CONTRACTORS

Prime Contractors awarded a Federal contract or order that is subject to Federal Acquisition Regulation clause 52.204-10 (Reporting Executive Compensation and First-Tier Subcontract Awards) are required to file a FFATA subaward report by the end of the month following
the month in which the prime contractor awards any subcontract greater than $30,000. This reporting requirement will be phased-in (see below):

  • Phase 1: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $20,000,000, reporting starts now.

  • Phase 2: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $550,000, reporting starts October 1, 2010.

  • Phase 3: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $25,000, reporting starts March 1, 2011.

  • Phase 4: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $30,000, reporting starts October 1, 2015.


Although the requirement to report subawards is being phased-in at certain dollar levels, if you would like to start reporting prior to the start date for your subcontracts, the system is available to you for reporting.

REPORTING TIMELINE FOR PRIME GRANT RECIPIENTS

Prime Grant Recipients awarded a new Federal grant greater than or equal to $25,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $25,000.


EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
MEMORANDUM FOR SENIOR ACCOUNTABLE OFFICIALS
FROM: Jeffrey D. Zients
Deputy Director for Management

SUBJECT: Open Government Directive – Federal Spending Transparency and Subaward and Compensation Data Reporting

Increasing transparency and improving access to Federal Government information, particularly information on Federal spending, is a primary objective of Open Government. To that end, this Memorandum provides Federal agencies with guidance on reporting subaward and compensation data for Federal contracts and grants. As required by the Federal Funding Accountability and Transparency Act 1(“Transparency Act” or “FFATA”) and subsequent OMB guidance, information on the first-tier subawards related to Federal contracts and grants and the executive compensation of awardees must be made publicly available. This memorandum and accompanying documents provide agencies with guidance to implement these reporting requirements.

Federal agencies must continue efforts to increase the availability of public information related to Federal spending and to improve the data quality of information so reported. To provide the public access to information on Federal spending, this Guidance directs agencies to:

• Require prime awardee reporting of first -tier subawards associated with new Federal contracts and grants as of October 1, 2010 (Appendix A);
• Require prime awardee reporting of executive compensation for new Federal contracts and grants as of October 1, 2010, as set forth in FFATA;
• Ensure alignment of agency systems ’ and processes to meet these reporting requirements (Appendix B, Awardee Reporting Architecture); and
• Participate in the development of a long-term architecture to facilitate the availability of other Federal spending information (e.g., loans, other assistance).

The Guidance and Awardee Reporting Architecture contained in this Memorandum leverage existing information and processes to enhance data quality and data integrity, both of which are necessary to provide complete public access to Federal spending information. The Awardee
Reporting Architecture delineates how existing systems, platforms, business processes,
1P.L. 109-282, as amended by section 6202(a) of P.L. 110-252 (see 31 U.S.C. 6101 note).
August 27, 2010