The Federal Funding Accountability and Transparency Act (FFATA)
The Grant Award Notification (GAN) Letter and New FFATA Reporting Requirements
The 2011 SAHE GAN and New SAHE FFATA Reporting Requirements
FFATA Resources from Collaborative Members
Q and A on SAHE GAN and FFATA Reporting Requirements
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. Federal awards include grants, subgrants, loans, awards, cooperative agreements and other forms of financial assistance as well as contracts, subcontracts, purchase orders, task orders, and delivery orders.
The legislation requires reporting from any and all entities (prime awardees) that have received Federal grants over $25,000 after October 1, 2010. The legislation also requires that prime awardees report information about all sub-awardees to whom they have granted Federal funds after October 1, 2010.
The text of the legislation can be found here.
More information on FFATA can be found through the Federal FFATA Portal: http://ffata.org/ffata/ffataact.html
Each year, the Department of Education sends a Grant Award Notification (GAN) letter to all of its Prime Awardees. Since the SAHE grant administrators (who constitute the Collaborative) receive the funds for Title II, Part A, Subpart 3 of ESEA/NCLB, they are considered Prime Awardees.
The 2011 GAN letter to Prime Awardees included many additional attachments and enclosures, compared to GAN letters of the past. These attachments and enclosures generally pertained to additional reporting requirements as laid out in the Federal Funding Accountability and Transparency Act of 2006 (FFATA), which came into effect for all Federal funds granted after October 1, 2010.
The GAN attachments included information about what was to be reported and when, but the Department has received many questions about this. Since then, various Federal government websites have added pages to help prime awardees better navigate the new FFATA reporting requirements.
A few helpful sites are listed below.
Overview of FFATA reporting from the National Institutes of Health:
Q and A from the US Department of Education on FFATA reporting:
Guidance for awardees on using the Federal Sub-awardee Reporting System (FSRS) to report data required through FFATA:
The 2011 SAHE GANs were specific to each state; however, they followed a similar format across all states. A sample from Washington is available below, including all attachments and enclosures:
The 2011 SAHE GANs contained Attachments A, C, F, N, O, P, S, U, V, and W; and Enclosures E4 and E5.
Below you will find brief descriptions of each of these attachments, as well as statements about whether the attachment is applicable to SAHEs, their accounting departments, or neither.
Attachment A (Requesting Funds Using the G-5 Module) deals with the mechanics of obtaining payments from the US Department of Education. It is interesting to note the last two sentences on page 2: “This method of identifying expenditures, at the time of drawdown, and the capability to make adjustments on-line eliminates the need for the submission of the Federal Cash Transactions Report Form 272. Therefore, no additional financial reporting will be required unless required by a specific program.”
Attachment C (An Overview of Single Audit Requirements of States, Local Governments, and Non-Profit Organizations) tells us which version of Circular A-133 is most current. It also outlines which entities are subject to single audit requirements and tells where to report audit results (audit clearinghouse.) SAHEs may wish to inform subrecipients about single audit requirements in some boilerplate language in their contract template and RFP.
Attachment F (Request for Approval of Program Income) describes where to look for guidance if a project is generating income from sources other than its SAHE grants. It lists available options for handling such income, and gives the US Department of Education an opportunity to disallow options. This attachment could be relevant for SAHEs. For example, it would probably be relevant if an ITQ grant paid an IHE to develop a course, which the IHE subsequently allowed project participants to enroll in for free, and simultaneously allowed non-participants to enroll in for a fee. Timing would probably be a factor in this example.
Attachment N (Trafficking in Persons) gives the US Department of Education a means for quickly shutting down programs connected with trafficking in persons. It is hard to conceive of a circumstance where that would happen with our projects. The last sentence on the page provides a nice summary.
Attachments O (Reporting Prime Awardee Executive Compensation Data) and P (Reporting Subaward Data and Executive Compensation Data for Subrecipients) deal with reporting executive compensation and subaward amounts. These are the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements David Downey spoke about during the 8:45-9:30 Wednesday June 29 session at the US Department of Education’s annual Title II meeting. FFATA reporting is relevant and new for SAHES. It is worth noting that reporting is due “by the end of the month following the month in which the award is made.”
Attachment S (Special Conditions for Disclosing Federal Funding in Public Announcements) outlines information that grantees are required to give “when issuing statements, press releases, requests for proposals, bid solicitations, and other documents describing projects or programs funded in whole or in part with Federal money.”
Attachment U (Prohibition of Text Messaging and Emailing While Driving During Official Federal Grant Business) outlines a common sense rule. You may want to send your project directors an email about this or include it in your contract or RFP boilerplate language.
Attachment V (Registration of Data Universal Numbering System (DUNS) Number and Taxpayer Identification Number (TIN) in the Central Contractor Registration (CCR)) describes DUNS and TIN numbers and explains that the you need to file a TIN with the CCR because the Department of Treasury will replace the Federal Reserve as disburser of payments. This is relevant for SAHEs, but SAHE accounting departments should handle it. It is probably wise to make your accounting department aware.
Attachment W (Central Contractor Registration and Universal Identifier Requirements) outlines several federal requirements, including a requirement that SAHEs need to review and update CCR information at least annually (or “if required by changes in your information or another award term”). Also, SAHEs must notify subrecipients that no “entity” can receive a grant from you unless they have provided their DUNS number to you. This is probably best accomplished with some RFP text. Also, SAHEs may not make subawards to entities from whom they have not obtained DUNS numbers.
Enclosure E4 - Memorandum (Department of Education Cash Management Policies for Grants and cooperative Agreements) “reminds” us about cash management requirements and puts us on guard that “The Department expects that recipients will ensure that subrecipients are also aware of these policies by forwarding a copy of this memorandum to them.” The document also provides a laundry list of requirements.
Enclosure E5 - Recipients of ED Grants and Cooperative Agreements Frequently Asked Questions (FAQ) lists questions and answers regarding the Cash Management Improvement Act of 1990.
Collaborative members have contributed the following resources to help other SAHE grant administrators navigate their FFATA reporting responsibilities.
Virginia uses the following form to collect data from their sub-awardees:
VA sub-awardee data form
Washington shares the following sample report generated by the FSRS system, including information on the prime awardee (the WA SAHE) and one of their subawardees (project/grant):
WA sample report
Collaborative members have been asking questions of Libby Witt of the US Department of Education, and of our collaborative contact in Washington state, individually on issues related to their GANs and the FFATA reporting requirements for state agencies of higher education (SAHEs). SHEEO staff have compiled the questions and responses below so they may serve as a resource for all.
- Enclosures Definitions and FFATA Presentation
- Executive Compensation Exception
- Fiscal Years included in Reporting Requirements
- FSRS Reporting for Subawardees
- Parent Institutions and DUNS Numbers
- Prime Awardee Reporting Prohibited Without Sub-Awardee Information
- Reporting Multi-Year Subawards
- Website for FFATA Reporting