Transcript FFATA Sub Award Report & OMB Guidance on Transparency Act

FFATA SUB AWARD REPORT & OMB GUIDANCE ON TRANSPARENCY ACT
DENISE STINES FRANCIS – [email protected]
FFATA Sub Award Report, Summary of What GAO Found (published March 2010)
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Requirement to include data on sub awards by January 2009 has not been implemented
Data on all grants is not being reported in USASpending.gov
Random sample of awards identified widespread inconsistencies between USASpending.gov
data and records provided by awarding agencies
USASpending.gov site does not yet include all required information
GAO Recommendations
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Develop and implement a specific plan for the collection and reporting of sub award data,
including a timeframe for including sub award data in USASpending.gov
Develop and implement a process to regularly ensure that all federal agencies report required
award information in USASpending.gov
Revise guidance to federal agencies on reporting federal awards to clarify
• the requirement that award titles describe the award’s purpose and
• requirements for validating and documenting agency award data submitted by federal
agencies; and
Include information on the city where work is performed in OMB’s public reporting of the
completeness of agency data submissions
FFATA SUB AWARD REPORT & OMB GUIDANCE ON TRANSPARENCY ACT
DENISE STINES FRANCIS – [email protected]
OMB Open Government Directive – Federal Spending Transparency (April 6, 2010)
Provides Guidance By:
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Establishing an October 1, 2010 deadline for Federal agencies to initiate sub award reporting
(FFATA) and provide a timeline for additional guidance to assist in meeting the goals
established therein
Initiating new requirements for Federal agencies to maintain metrics on the quality and
completeness of Federal spending data provided pursuant to FFATA
Announces the release of the new USASpending.gov website
Sub-award Data Reporting
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All Federal agencies will implement the requirement to collect sub-award data by October 1,
2010
Recipients, sub-recipients, contractors, and sub-contractors should be prepared to report on
applicable grants, contracts, and orders awarded, as soon a practicable after the sub-grant or
sub-contract has been made, but no later than 30 days after that event
The guidance only applies to new grants, new contracts, and new task and delivery orders that
are awarded after October 1, 2010
Sub-award reporting will apply to sub-grants and sub-contracts for the first-tier sub-awards
FFATA SUB AWARD REPORT & OMB GUIDANCE ON TRANSPARENCY ACT
DENISE STINES FRANCIS – [email protected]
Sub-award Data Reporting (continued)
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Sub-awards generally means a monetary award made as a result of an award to a grant
recipient or contractor to a sub-recipient or sub-contractor, respectively. The term includes
first-tier sub-awards, and does not include awards made by a first-tier sub-recipient or subcontractor to a lower tier sub-recipient or sub-contractor
Required data elements include:
• Name of the entity receiving the award
• Amount of the award
• Information on the award including transaction type, funding agency, the North
American Industry Classification System code or Catalog of Federal Domestic Assistance
number (where applicable), program source, and an award title descriptive of the
funding action
• Location of the entity receiving the award and primary location of performance under
the award including city, State, congressional district, and country
• A unique identifier of the entity receiving the award and the parent entity of the
recipient, should the entity be owned by another entity
FFATA SUB AWARD REPORT & OMB GUIDANCE ON TRANSPARENCY ACT
DENISE STINES FRANCIS – [email protected]
Sub-award Data Reporting (continued)
• Names and total compensation of the five most highly compensated officers of the entity
if-i.
the entity in the proceeding fiscal year received --i.
80 percent or more of its annual gross revenues in Federal awards; and
ii. $25,000,000 or more in annual gross revenues from Federal awards
ii. the public does not have access to information about the compensation of the
senior executives of the entity through periodic reports filed under section 13 (a)
or 15 (d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m (a), 78o (d) or
section 6104 of the Internal Revenue Code of 1986;
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Other relevant information specified by the OMB in subsequent guidance or regulation
FFATA SUB AWARD REPORT & OMB GUIDANCE ON TRANSPARENCY ACT
DENISE STINES FRANCIS – [email protected]
Possible Implications and Stakeholder Comments
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With such limited lead time between now and October 1, 2010, how are States to ensure
that their agencies will report in a timely and accurate manner?
Will system-to-system reporting be an option for states to upload sub-award data, and will
beta testing be available before October 1 to ensure that at least several hundred lines of
data can be uploaded at one time?
It seems reasonable to have states and other grantees incorporate the same quarterly
metrics into their systems if feasible, however, proposed deadlines appear overly ambitious
Where is the format for the data quality plan? Is staff available to work on this during the
identified timeframes?
How will stakeholder/grantee feedback be solicited by OMB or others re: the upcoming
implementation---will OMB/Federal agencies poll participants from the sub-award pilot?