FFATA Subaward Reporting for Federal Subawards Over $25,000

BLUF

Prime federal recipients report subawards of $25,000 or more through the SAM.gov FFATA Subaward Reporting System by the end of the month following obligation. The Federal Award Identification Number links each subaward to its prime. Executive compensation reporting applies only when the subrecipient meets the $25M / 80 percent federal revenue test and the data is not already publicly available. Reported data publishes on USAspending.gov.

TL;DR

• Threshold: subaward obligation of $25,000 or more.
• Timing: end of the month following the month of obligation.
• System: SAM.gov FFATA Subaward Reporting System (formerly FSRS.gov).
• Linkage: FAIN ties the subaward to the prime.
• Executive compensation: only if subrecipient had $25M+ in federal awards AND 80%+ of gross revenues from federal AND compensation not already publicly disclosed.
• Publication: USAspending.gov.

Statutory background

The Federal Funding Accountability and Transparency Act (Public Law 109-282) created the mandate for public reporting of federal awards. The Digital Accountability and Transparency Act of 2014 (Public Law 113-101) amended FFATA and standardized federal spending data. Implementing regulations live at 2 CFR Part 170. Between the statutes and the regulation, prime recipients of federal grants, cooperative agreements, and loans are required to report subawards at or above $25,000 so the public can trace federal dollars from Treasury through to the final recipient.

What triggers a report

Each subaward obligation of $25,000 or more triggers a report. Key points:

• The threshold is per obligation action, not a cumulative aggregate of small subawards.
• A modification that raises a previously-below-threshold subaward to $25,000 or more is a reportable action.
• Contractors (as distinct from subrecipients under 2 CFR 200.331) are not reported in the subaward system; federal subcontracts are reported separately.

Timing

Reports are due by the end of the month following the month the subaward was obligated. A subaward obligated March 15 is reported by April 30. A subaward obligated on the last day of the month still uses the end-of-next-month deadline. Late reports do not fall off the obligation; they accumulate until filed.

Where to file: SAM.gov

The FFATA Subaward Reporting System moved from its original home at FSRS.gov to SAM.gov as part of the General Services Administration’s integrated award environment consolidation. Prime recipients log into SAM.gov with their registered account, open the subaward reporting module, locate the FAIN for their prime award, and enter the subaward data.

Data elements

Each subaward report includes:

• Prime award FAIN
• Subrecipient name and Unique Entity Identifier
• Subaward amount and obligation date
• Subaward period of performance
• Place of performance
• Project description
• Subrecipient business types
• Executive compensation data (when the test below applies)

Executive compensation test

Top-five executive compensation is reported only when all three conditions are met for the subrecipient’s preceding fiscal year:

1. The subrecipient received $25 million or more in federal awards, AND
2. 80 percent or more of the subrecipient’s annual gross revenues came from federal awards, AND
3. The compensation information is not already publicly available (through SEC filings, IRS Form 990, or similar public disclosure).

Most nonprofit subrecipients do not meet the first two conditions, and those that do usually have public Form 990 data that satisfies the third exclusion. When the test applies, the prime reports the names and total compensation of the top five executives.

Publication on USAspending.gov

FFATA data flows from SAM.gov into USAspending.gov, which joins subaward data to prime award data under the same FAIN. Missing or misaligned data on USAspending.gov usually traces back to a FAIN mismatch in SAM.gov, a missing subrecipient UEI, or a late subaward report.

Relationship to 2 CFR 200.332

FFATA reporting and 200.332 subrecipient monitoring both apply to the same subaward but serve different purposes. 200.332 is about the PTE’s oversight of the subrecipient: risk assessment, monitoring activities, management decisions. FFATA Part 170 is about public transparency: reporting the subaward to SAM.gov so it publishes on USAspending.gov. A prime meets both obligations or risks findings on both fronts.

Common FFATA reporting errors

• Subaward filed after the end-of-next-month deadline
• FAIN mismatch so the subaward does not link to the prime on USAspending.gov
• Subrecipient UEI missing or expired
• Reporting contractors (goods and services suppliers) as subrecipients
• Executive compensation missing when the 25M/80% test applies

What GrantPipe Does Here

GrantPipe tracks every federal subaward with its FAIN, obligation date, UEI, and FFATA reporting deadline, and keeps 200.332 monitoring activities on the same record so both the public-transparency and pass-through-entity obligations are visible at once. Start a trial.

DEFINITION

FFATA

Federal Funding Accountability and Transparency Act (Public Law 109-282), which established the requirement for public reporting of federal awards and subawards.

DEFINITION

DATA Act

Digital Accountability and Transparency Act of 2014, which amended FFATA to standardize federal spending data and expand publication through USAspending.gov.

DEFINITION

FSRS

Federal Funding Accountability and Transparency Act Subaward Reporting System. Originally at FSRS.gov, now integrated into SAM.gov.

DEFINITION

FAIN

Federal Award Identification Number, the unique identifier for a prime federal award. Required to tie each FFATA subaward report to its prime.

DEFINITION

USAspending.gov

The public website that publishes federal spending data, including prime awards and FFATA-reported subawards.