Complying with FFATA Reporting Requirements
Many organizations receive grants that are a significant portion of their funding sources and are subject to governance under the Uniform Guidance. If expenditures of such funds equal or exceed $750,000 in any given year, then the organization must undergo a single audit under Government Auditing Standards. Loans obtained under the Paycheck Protection Program (PPP) and refunds resulting from the Employee Retention Tax Credit (ERTC) are not subject to a Single Audit.
The purpose of Uniform Guidance (Single Audit) requirements is to assure the federal government that the funds are being used appropriately by the recipients.
Guidance on reporting requirements of this type of government funding spells out how certain activities should be tracked and reported. Failure to abide by the guidance can jeopardize funding, so it’s a good idea to revisit your organization’s documentation and ensure it’s up to date.
FFATA reporting is required when Prime Awardees (an organization that receives money directly from the federal government) make first-tier subawards or subcontracts of $30,000 or more. Each subaward or subcontract that meets the following criteria will need to be reported:
- First-tier subawards for FFATA reporting purposes are considered awards made by a prime awardee pass-through entity to a subrecipient, with the intent that the subrecipient is to carry out part of the federal award. It does not include payments to contractors or beneficiaries.
- First-tier subcontracts for FFATA reporting purposes are considered subcontracts awarded by a prime awardee contractor in order to acquire goods or services for the performance of the prime contract, but it does not include the contractor’s supplier agreements with vendors.
Reporting should be completed no later than the end of the month after the month that the obligation was entered into. Submissions for subawards should be completed at fsrs.gov, and you must have a login.gov account to use the system. Be sure to use the same email address for both the login.gov and fsrs.gov sites.
Reporting requirements involve both information about yourself and your subrecipients; however, it is reported in different places.
- Total compensation of recipient (prime awardee) executives:
- You must report the total compensation for each of your five most highly compensated executives for the previous fiscal year if the following criteria are met:
- In the previous fiscal year, you received 80 percent or more of your annual gross revenues from federal contracts OR aid subject to the Transparency Act, and that amount totaled to $30,000,000 or more in annual gross revenues from federal contracts or aid.
- The public does not have access to information about the compensation of executives through other reporting filed under the Securities Exchange Act or the Internal Revenue Code.
- The U.S. Security and Exchange Commission has information about how to access this data at https://www.sec.gov/answers/execomp.htm.
- This information must be reported as part of your registration profile at the System for Award Management (SAM).
- The same executive compensation rules apply to all first-tier subrecipients you award grants to. However, it will be reported at gov (not sam.gov). In addition to data about executive compensation, the following information will need to be reported for all subawards:
- DUNS Number of the Entity
- Name of Entity
- Address of Entity (including congressional district)
- Amount of Subaward
- Funding Agency
- NAICS Code for Contracts / Assistance Listing Number for Grants
- Program Source
- Date of Obligation/Action
- Project Description
- Principal Place of Performance (including congressional district)
- Subaward Number (i.e., the entity’s unique identifier)
Reporting should be completed based on the entire value of the subaward. For example, if you award an entity a $35,000 grant but disburse the funds in two even payments, you will only report once on the entire $35,000 award amount.
How will it affect your single audit?
If the reporting compliance requirement is marked as a “Y” within the Part 2 Matrix for your major program and you made first-tier subawards or subcontracts greater than $30,000 during the period under audit, then FFATA reporting will be subject to testing.
Keep in mind that you’ll need to ensure you’re looking at the correct year’s Compliance Supplement, as the Part two Matrix can change from year to year.
- Recovery Act-funded grants or cooperative agreements do not require FFATA reporting.
- Although FFATA reporting is applicable for Coronavirus State and Local Fiscal Recovery Funds, the Treasury is completing all required reporting on behalf of the recipients. Therefore, it will not be subject to audit. In addition, the subaward reporting threshold was increased from $30,000 to $50,000 for this program.
- If, in the previous tax year, your gross income from all sources was under $300,000, then you are not required to report the subawards and the executive compensation of any subrecipient.
- Classified information should not be reported.
- The following are not considered subrecipients and would not need to be reported:
- A vendor, dealer, distributor, merchant, or other seller of goods or services that are purchased for use within the program.
- Beneficiaries of programs.
- Awards or subawards to individuals (i.e., not on behalf of any business or nonprofit organization that they own or operate)
If you have questions about your organization’s compliance and reporting, contact an Adams Brown advisor.