FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT
The Federal Funding Accountability and Transparency Act (FFATA or Transparency Act - P.L.109-282, as amended by section 6202(a) of P.L. 110-252) requires the Office of Management and Budget (OMB) to maintain a single, searchable website that contains information on all federal spending awards on the following website www.USAspending.gov.
SIBCR follows all guidance issued by the OMB and the sponsoring agencies from which it receives federal funds. The reports required under the Transparency Act are submitted in accordance with these regulations. Subawards and subcontracts that meet the reporting requirements under FFATA are subject to the same policies and procedures as other SIBCR subawards and subcontracts.
FFATA Overview and Applicability
FFATA mandates subrecipient reporting requirements that apply to newly awarded federal grants and contracts.
- Subrecipient Reporting under Federal Grants: Applies to any newly awarded prime grants greater than or equal to $25,000 with an issue date of October 1, 2010 or later. Subawards that have a cumulative total of $25,000 or more must be reported.
• Excludes vendor agreements
• Excludes American Recovery and Reinvestment Act (ARRA) grants
- Subrecipient Reporting under Federal Contracts: Applies to any newly awarded prime contract in the amount of $30,000 or more with an effective date of October 1, 2015 or later. Subcontracts that have a cumulative total of $30,000 or more must be reported.
• Includes vendor agreements
• Includes American Recovery and Reinvestment Act (ARRA) contracts
Please see the following decision tree that outlines the applicability of reporting grant and contract subaward or vendor agreement data under the Transparency Act.
It is the responsibility of all subrecipients and vendors of federal funds to apply for and maintain a DUNS number. Obtaining a DUNS number is completely free for all entities doing business with the federal government. An SIBCR grants administrator may provide assistance to subrecipients and vendors in obtaining DUNS numbers. For more information and to apply for a DUNS number, please visit http://fedgov.dnb.com/webform.
System for Award Management (SAM) Verification
It is the policy of SIBCR to verify that all subrecipients and vendors of federal funds have an active DUNS number registered with SAM. Subrecipients and vendors must send proof of active registration to SIBCR, if requested. For more information on this requirement and the registration process, please visit https://www.sam.gov/portal/public/SAM.
Vendor tracking for FFATA is only required on federal contracts. Under a federal contract, an SIBCR grants administrator will gather FFATA reporting information on all individual vendor purchases equal to or exceeding $28,000. The threshold is $28,000 (rather than $30,000) to account for potential shipping charges. These procedures apply to, but are not limited to, the following contractual arrangements: purchase order/vendor agreements, consulting agreements, rental or lease agreements, software license agreements and service maintenance contracts.