1. 1 F EDERAL F UNDING A CCOUNTABILITY AND T RANSPARENCY A CT R EPORTING R EQUIREMENTS U.S. Department of Education Risk Management Service Guidance for Grantees

2. Federal Funding Accountability and Transparency Act AKA: FFATA Signed into law September 6, 2006; amended in ‘08 Purpose: To empower every American with the ability to hold the government accountable for each spending decision by allowing them to track the awarding of Federal funds Transparency Act Overview www.ffata.org/ffata/ffataact.html

3. New Reporting Requirements 3 Took effect on October 1, 2010 Are located in 2 CFR Part 170 Guidance included with Grant Award Notification (GAN) Awarding agencies reports grantee information Requires grantees to report the following data to the FFATA Subaward Reporting System (FSRS) for posting on USASpending.gov: Grantee Subaward information Compensation of their top five most highly compensated executives

4. Subaward Reporting 4 Grantees are required to report their subawards and compensation of their, and their subawardees’, top executives if they were: Awarded funds by ED on or after October 1, 2010 (“Award Date” is reflected in box #10 of the GAN) Awarded $25,000 or more  initial award  subsequent modification (i.e., grant supplements)

5. 5 Grantees are required to report their, and their subawardees’, Executive Compensation data if: In the previous fiscal year, they received Federal financial assistance and procurement contracts or subcontracts that totaled 80% or more of their annual gross revenue; and $25 million or more in annual gross revenue; and The public does NOT have access to their executive compensation data through reports filed w/SEC & IRS. Executive Compensation Reporting

6. Grantees that meet the previous FY financial and public filing conditions are required to provide the following data on their, and their subawardees’, five most highly compensated executives: Names Total Compensation 6

7. Subaward Reporting 7 If a grantee made subawards, it is a prime awardee and responsible for reporting its subawards, and its subawardees’ executive compensation data. Prime Awardees must: Register with FSRS  During registration, their data will pre-populate from Central Contractor Registration System (CCR) Encourage subawardees to register with CCR  Their data will pre-populate in FSRS Adhere to FSRS reporting requirements and schedule

8. Reporting Schedule 8 FSRS reporting requirement for prime awardees and subawardees began on October 1, 2010. Prime awardees must report their first tier subgrantees data by the end of the following month from when the award was made or obligated. For example… If the award is made on October 15, 2010 then the Prime Awardee must report by November 30, 2010

9. Reporting system (FSRS) Pre-populates prime awardee and subawardee information from the CCR. Prime awardees enter following sub-award information if not pre-populated: – Name of entity receiving award – DBA name (Grants) – Amount of award – Subcontract/Subcontract Number – Funding agency Data Elements

10. – CFDA Number (Grants) –NAICS (Contracts) –Treasury Account Symbol –Award title descriptive – Location of the entity (including congressional district) – Place of performance (including congressional district) – Unique identifier (e.g., DUNS) of the entity and its parent and DUNS +4 (Grants) – Total compensation and names of top five executives Data Elements

11. Reporting Exemptions 10 Grantees are NOT required to report Subaward Data and Executive Compensation Data if they: Are Recovery Act (ARRA) grantees Were awarded their grant prior to October 1, 2010 Received an award less than $25,000 for the entire period of award Had gross income less than $300,000 in the previous tax year Risk disclosing classified information Individuals who apply for, or receive Federal awards as natural persons are exempt from FFATA reporting requirements.

12. Only grantees that receive funds from discretionary and formula programs that require or permit subawarding, where the responsibility for the subaward’s programmatic decision making lies with the subawardee, are required to comply with FFATA subaward reporting requirements. Understanding Subawards 9

13. The following funding instruments are not considered subawards under FFATA if the grantee maintains programmatic decision-making responsibilities under each of these funding instruments:  Contracts  Small purchase agreements  Vendor agreements  Consultant agreements Meeting the Definition 11

14. ED Compliance Policy Program staff must ensure grantee compliance with FFATA reporting requirements by: Ensuring that the appropriate FFATA grant term is included with Grant Award Notifications: Attachment O - Executive Compensation Reporting Will automatically generate in GAPS/G5 for all ED grant programs Attachment P - Subaward Reporting Will automatically generate in GAPS/G5 for only those grant programs that permit or require subawarding Reminding grantees of their reporting requirement during monitoring 12

15. Subgrantee Compliance For their Subgrantees, Prime Grantees should… Inform potential subgrantees of the need to establish and provide the prime grantee with their DUNS number NOT make subaward to an eligible subgrantee without having their DUNS number Review Attachment W of the GAN 19

16. Who?Reports what?How? AgencyPrime award information for awards $25K or more FAADS+ for grants, FPDS-NG for contracts Prime grant awardee Company information Executive compensation Grant subaward information for awards $25K or more CCR CCR or FSRS* FSRS Summary of Duties If executive compensation is not found in CCR it can be supplied through FSRS

17. FFATA.org FSRS.gov FSRS Help Desk: 1-866-606-8220 Central Contractor Registration—ccr.gov USASpending.gov Dun & Bradstreet: 1-8 66–705–5711 or fedgov.dnb.com/webform whitehouse.gov/omb/open Securities and Exchange Act of 1934 Federal Technology Transfer Act of 1986 Resources

18. G5 Hotline: Hours of Operation: 8:00 AM to 6:00 PM, Monday-Friday, EST Toll-Free: 1-888-336-8930 TTY: 1-866-697-2696 Local: 202-401-6238 Email: edcaps.user@ed.govedcaps.user@ed.gov Resources