(If your answer is "What?", read more.)
A: The FFATA was signed into law on 9/26/2006. It requires that information about federal awards -- contracts and financial assistance -- be made available to the public. YOUR PART as the PRIME is reporting subaward and executive compensation data on your first-tier subawards.
▶️ Prime contract awardees must report first-tier subcontracts awarded that are valued greater than or equal to $30,000. (Reference FAR Clause 52.204-10 Reporting Executive Compensation and First-Tier Sub-Contract Awards)
▶️ Prime grant awardees must report first-tier subgrants awarded under both mandatory and discretionary prime grants that are valued greater than or equal to $30,000*. (Reference 2 CFR Chapter 1 Part 170 Reporting Sub-Award and Executive Compensation Information)
▶️ ▶️ If the initial grant award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements, as of the date the award exceeds $30,000.
▶️ ▶️ If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.
The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor or grant recipient awards any sub-contract or sub-grant greater than or equal to $30,000*. Again, this is a PRIME RESPONSIBILITY. Only the Prime awardee is required (and able) to report sub-award actions in the reporting module.
The data submitted is pulled to USASpending.gov and reflected under the prime award for transparency.
Another IMPORTANT NOTE:
The FFATA Subaward Reporting System (FSRS) is being retired and migrated into the System for Award Management (SAM) in March 2025. GSA states there will be a blackout period before the migration and ample notice will be provided to users. More training and materials to prepare users for the changes are in the works; see separate post for briefing slides.
A list of FAQs can be found at https://www.fsrs.gov/#a-faqs until such time fsrs.gov is decommissioned.
*NOTE: The recent proposed rule under FAR Case 2024-001 recommends an inflationary increase for reporting by prime contract awardees under FAR clause 52.204-10 from $30,000 to $40,000. If unchanged in the final rule, this increase threshold would go into effect on 10/1/2025. The threshold for prime grant recipients in 2 CFR Chapter 1 Part 170 would require change under separate rulemaking.
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