Federal Funding Accountability and Transparency Act (FFATA) Update for FTA Grantees –Supplemental Guidance Posted on 1/26/13:
FTA grant recipients that use funds to purchase vehicles off-of a state-wide contract and then provide the vehicles to sub-recipients have a subaward relationship with these subrecipeints and should submit a subaward report for each subrecipient that is receiving vehicles from the statewide purchase. Grant recipients should enter the cost of the vehicles being transferred to the subrecipient as a proxy for the subaward amount in their subaward report.
Recipients that are awarded grants directly from FTA and use these funds to purchases vehicles off of a state-wide contract for their own use do not have a subaward relationship with another organization and do not need to submit FFATA subaward reports.
Federal Funding Accountability and Transparency Act (FFATA) Update for FTA Grantees – Originally Posted 11/1/2011:
All direct recipients of FTA grants and cooperative agreements over $25,000 awarded after October 1, 2010 are subject to the requirement to report sub-award information to http://www.fsrs.gov/ by the end of the month after the month in which they make any sub-award under the grant. The reporting requirement does not include vendor (third party contract) data at this time, though OMB is expected to issue revised guidance to include vendors in the near future. The requirement also does not pertain to grants originally made prior to October 1, 2010 but amended after 10/1/2010 to add additional funds.
The following information is provided for use by FTA recipients and regional staff:
- Direct recipients must register on-line to use the http://www.fsrs.gov/ reporting site. To register, the recipient must have a valid DUNS number and must be registered in the Central Contractor Registry (CCR) and must renew their CCR registration annually Recipients can go to http://www.ccr.gov to register their organization, renew their registration, or check on their registration status.
- Direct recipients should also check their recipient profile in TEAM to ensure that their DUNS number and address is consistent with the information in the CCR. If there is a mismatch between the profile information in TEAM and in the CCR, the recipient should contact their FTA regional office to request a TEAM vendor form and submit the completed form to their regional office so that changes can be made in TEAM.
- Subrecipients must also have DUNS, but are not required to register in CCR.
- Once registered, the direct recipient will be able to search in FSRS for the awards all Federal agencies have reported to USASpending for that recipient’s DUNS number and select an award for which to report sub-award information. If the award is not immediately available in the list in the system, check back later, because the award data is uploaded from USASpending after it is reported by the Federal agencies.
- The Department of Transportation submits a file of all awards made the previous month on the 5th day of each month. FTA recipients will not be able to view and report on sub-awards until the information is downloaded to FSRS from USASpending, shortly after the 5th day of each month. The new reporting requirement does not apply to awards made before October 1, 2010, so FTA awards made before Fiscal Year 2011 will not appear in FSRS.
- The direct recipient must report the information about each first tier sub-award over $25,000 (funds passed through to other public agencies or private non-profit organizations) by the end of the month following the month the direct recipient makes any sub-award or obligation (not the month after FTA awarded the direct grant). For example if FTA awarded the grant in November, and the prime recipient did not sign subrecipient agreements until February, the FTA grantee would have until March 31 to report the sub-award into FSRS.
- OMB’s current requirement for reporting Sub-awards under grants does not include third party contracts (vendors).
- Once the grantee submits an initial report, the grantee can revise it later to add additional sub-awards as they are made, or to change data previously submitted to reflect adjustments in sub-awards.
- If the grantee does not make any sub-awards out of the FTA grant, the grantee should not file a sub-award report. If the grantee uses all of the grant money directly, no report will be required for that award. [Note: 3rd party contracts/vendors are not included as of November 2011 but OMB guidance may change to include them.]
- No report is required until the month after the grantee makes a sub-award. For example, if a State DOT received a Section 5311 grant in November and listed 16 sub-recipients in the program of projects but does not consider the sub-awards to be made until each subrecipient signs a letter of agreement, the State would not have to report any sub-awards in December, but would report them by the end of the month after the sub-recipient signs the agreement. On the other hand, if the State DOT has a standing agreement with subrecipients and considers the sub-awards to be made at the time of the FTA grant award, the report would be due in FSRS by the end of the month after FTA obligated the grant to the DOT. If the State allowed subrecipients to use pre-award authority, the deadline would be based on the date of the FTA obligation, since FSRS cannot accept sub-award reports before the Federal obligation is recorded in the system.
- FSRS pre-populates prime grant award information from the TEAM data FTA provides for DOT’s feed to USASpending, and from DUNS and CCR. If the grantee observes any errors in the pre-populated data, the system allows the reporter to flag the error. If an FTA grantee flags erroneous information, FTA will follow up with the grantee to ensure that the grantee’s data in TEAM, DUNS and CCR are consistent and necessary corrections are made in the appropriate systems.
- The required data elements in FSRS for each first tier sub-award over $25,000 :
- Name of entity receiving sub-award
- DBA Name
- DUNS of the entity and its parent and DUNS+4
- Amount of Sub-Award
- Sub-award Number (Note: assigned by recipient)
- CFDA Number (Note: The same CFDA associated with the FTA award)
- Place of performance (including Congressional district)
- Total compensation and names of top five executives, if required (Note: Not typically required, with thresholds of $25 M and 80% of total revenue coming from Federal funds)
- Award title descriptive of the purpose of the funding action
- Location of the entity (Including Congressional district)
- The amount that is to be reported for each subrecipient is the amount of the total sub-award, not payments to date. Payment/drawdown information is not included in the data fields requested.
- After the recipient reports the sub-award data in FSRS, the information will be published with the original direct award information on http://www.usaspending.gov/
- Information and training materials about FFATA sub-award reporting and FSRS are posted on www.USASpending.Gov/news. To receive new information on changes and updates to USASpending.gov as soon as it becomes available, subscribe by visiting http://www.usaspending.gov/ and adding your email address under the “What’s New” Section.
- User manuals and data dictionaries are available on http://www.fsrs.gov/
- Grantees should direct technical questions about the reporting website to the FSRS help desk. FTA regional staff are available to help with FTA grant award information and requirements.