Nonprofit Insider ▲
U H Y LLP C e r t i f i e d P u b l i c A c c o u n t a n t s
6851 Oak Hall Lane Suite 300
The Price of Federal Funding:
More Reporting
by Nelly Gizdova, Manager
If you had just
become used to
hearing the term
ARRA without
having a panic
attack, there is now
a new potential
source of anxiety:
FFATA. FFATA, or the Federal
Funding Accountability and Trans-
parency Act, is not new legislation,
per se; it was signed into law on
September 26, 2006, by President
George W. Bush. The reason FFATA
is starting to make headlines again
is that many of its provisions
became effective on October 1, 2010.
FFATA is similar to ARRA (the
American Recovery and Reinvestment
Act) in its intent to make the govern-
ment transparent and accountable
for its spending decisions by using
the newest information technology
resources, but it goes beyond the
ARRA reporting in several aspects.
To begin, the provisions of FFATA
affect all entities that receive federal
awards (direct and first tier sub-
recipients) regardless of the type or
amount of federal funding received,
and are applicable for all new
awards effective October 1, 2010.
The other major difference is that
FFATA reporting is going to be
monthly (not quarterly, as with
UHY LLP brings specialists in nonprofit solutions in accounting and tax.
Columbia, MD 21045 410-423-4800
ARRA). The first reporting was due
November 30, 2010, for the month
ending October 31, 2010. The col-
lected information on federal
awards is then published and acces-
sible through a searchable website:
www.USASpending.gov.
The term federal awards used in
FFATA is quite broad and includes
grants, sub-grants, loans, awards,
cooperative agreements and other
forms of financial assistance as well
as contracts, sub-contracts, purchase
orders, task orders and delivery
orders. ARRA grants, awards that
involve classified information and
benefit payments, and other awards
to individuals who apply for or
receive the awards as natural per-
sons are excluded from reporting
under FFATA. Other transactions
that are presently exempted from
reporting include individual transac-
tions below $25,000 and credit card
transactions before October 1, 2008.
Who is affected?
FFATA affects a spectrum of entities:
for-profit and nonprofit corpora-
tions, associations, partnerships,
limited liability companies, limited
liability partnerships, sole propri-
etorships, any other legal business
entities and states or localities.
Entities with gross income less than
December 2010
Vol. 4 • No. 6
▲
Fax 410-381-5538 www.uhyllp-us.com
$300,000 for the previous tax year
(from any source) are exempted
from reporting.
As well, not-for-profit entities that
do not meet the threshold subjecting
them to the federal Single Audit Act
may still be subject to the provisions
of FFATA.
All recipients of federal awards
(grants and/or contracts) are
required to register in the Central
Contractor Registration system at
https://www.bpn.gov/ccr/. In addition
to that, prior to submitting FFATA
reports, the prime awardees must
register in the new FFATA Sub-
award Reporting System (FSRS) at
http://www.fsrs.gov.
FSRS was created to collect the
required data from the federal
awardees for reportable sub-awards
(grants or contracts greater than
$25,000) and executive compensa-
tion. In a memo to federal agencies,
the Office of Management and
Budget (OMB) clarified that
awardees would be required to sub-
mit data only on first-tier sub-grants
and sub-contracts.
Reporting requirements
All awardees should have imple-
mented the requirement to collect
sub-award data prior to October 1,
2010. Awardees and sub-awardees
(recipients, sub-recipients, contrac-
tors and sub-contractors) should be
prepared to report on applicable
awards (grants, contracts and orders
greater than $25,000), as soon as prac-
continued on page 2
 December 2010
Vol. 4 • No. 6

The Price of Federal • Award title Award Database System (FAADS),

Funding: More Reporting
continued from page 1
ticable after the sub-award, or a sub-
sequent change to the sub-award, has
been made, but no more than 30 days
after that event. The prime awardee
has a responsibility to inform the sub-
awardees at the time of the award of
all reportable data elements and to
monitor the completion of those
requirements on a monthly basis. It is
the sub-awardees’ responsibility to
report to the prime awardee all infor-
mation required by FSRS.
The reporting requirements are
phased in for federal contracts and
sub-contracts and are effective as
follows:
• For contracts greater than or equal
to $20,000,000, reporting started
July 1, 2010,
• For contracts greater than or equal
to $550,000, reporting started
October 1, 2010, and
• For contracts greater than or equal
to $25,000, reporting starts March
1, 2011.
There is no phase-in of the reporting
requirements for federal grants and
sub-grants.
Sub-award reporting
The sub-award information report-
ed in FSRS is very similar to what is
being reported under ARRA at
http://www.FederalReporting.gov:
• Name of entity receiving award
• Amount of award
• Funding agency
• NAICS code for contracts/CFDA
program number for grants
• Program source
the Federal Procurement Data
• Location of the entity (including
System (FPDS) and the Central
congressional district)
Contractor Registration System
• Place of performance (including (CCR) to ensure quality data and
congressional district) minimize unintended data entry
errors by sub-recipients. The federal
• Unique identifier of the entity and agency making the award will pre-
its parent (if owned by another populate the prime award recipient
entity) information by reporting it in FAADS
for grant awards and in FPDS for
Compensation and names of top
contract awards. FSRS interfaces with
five executives (prime and/or sub-
the above three systems (FAADS,
awardee), limited to entities that
FPDS and CCR) to make the informa-
have met all three of the following
requirements: tion available to the general public in
USASpending.gov.
• More than 80% of annual gross
FSRS takes an “awardee-centric”
revenues are funded by the
approach, allowing the prime
Federal government,
awardees to manage and report
• Annual gross revenues are against multiple contracts and/or
greater than $25 million in the grants awarded to their registered
previous fiscal year, and DUNS number. The awardees can
sort and filter their worklist by type,
• Compensation information is not i.e. contract or grant, by awarding
already available through report- agency and by other filter terms.
ing to the SEC or some other Awardees will be able to see, by
public source (IRS Form 990). award number, the FFATA sub-award
For ARRA-funded contracts subject reports filed against that particular
to FFATA reporting, the prime recipi- contract and/or grant.
ent will be required to report the con- Now, even though FSRS reporting is
tracts to both FederalReporting.gov and not specifically addressed in the lat-
FSRS, if required by the contract. est A-133 audit guide, OMB consid-
ers this to be required reporting and,
However, for ARRA-funded grants
as such, the awardees’ timeliness
subject to FFATA reporting, the
and accuracy of FSRS reporting will
prime recipient will not be required
be audited, and any non-compliance
to report the grants to both
will result in a finding.
FederalReporting.gov and FSRS.
Summing things up, sub-recipient
ARRA-funded grants will continue
monitoring and reporting and timeli-
to be reported to FederalReporting.gov
only and all non-ARRA funded fed- ness of the reporting are expected to
eral grants will be reported to FSRS. be the major issues in the FFATA
implementation process.
Making things a little easier •••
Some prime and sub-award informa- Please contact Nelly Gizdova, 410-
tion will be pre-populated in FSRS 423-4800 or ngizdova@uhy-us.com
with data from the Federal Assistance for more information.

The statements contained herein are provided for informational purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties under any federal,
state, local or other tax statutes or regulations, and do not resolve any tax issues in your favor. Furthermore, such statements are not presented or intended as, and should not be taken
or assumed to constitute legal advice of any nature, for which advice it is recommended that you consult your own legal counselors or professionals.
UHY Advisors, Inc., provides tax and business consulting services through wholly owned subsidiary entities that operate under the name of “UHY Advisors.” UHY Advisors, Inc.,
and its subsidiary entities offer services from offices across the United States. UHY Advisors, Inc., and its subsidiary entities are not licensed CPA firms. UHY LLP is a licensed independent
CPA firm that performs attest services. UHY Advisors, Inc., and UHY LLP are independent U.S. members of Urbach Hacker Young International Limited.