Federal Funding Accountability and Transparency Act (FFATA) Handbook 1
Contents Section 1: What is FFATA...2 Section 2: FFATA Effective Date...2 Contracts...3 Grants and Cooperative Agreements...3 Section 3: Policies and Procedures...3 Pre-Award Process...3 Post-Award Process...5 FFATA Data Requirements...6 FFATA Tagging...6 When does the FFATA Report need to be submitted?...6 FFATA Website Reporting Responsibility...7 Section 4: Helping Obtain DUNS Number...7 Section 5: How to Obtain CCR Registration...8 CCR Verification...9 Section 6: Purchasing... 10 Section 1: What is FFATA 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. That site is at http://www.usaspending.gov. Applicable contracts, as of July 8 th, 2010, and applicable grants, as of October 1 st, 2010, will need to report required information at http://www.fsrs.gov. The purpose of this information is to empower every American with the ability to hold the government accountable for each spending decision. The end result is to reduce waste in the government. Section 2: FFATA Effective Date The Office of Management and Budget (OMB) has issued the following guidelines for new contracts or grants on whether or not they will be susceptible to FFATA. 2
Contracts For Federal contracts the phase in period is as follows: Beginning July 8, 2010 September 30, 2010 new contracts greater than $20M will require contractors to report executive compensation (to www.ccr.gov) and sub award information (to www.fsrs.gov; October 1, 2010 February 29, 2011 if the prime contract value is greater than $550K; March 1, 2011 forward if the prime contract value is greater than or equal to $25K. Grants and Cooperative Agreements As of October 1, 2010, all Federal grants of $25,000 and over are subject to the FFATA subaward reporting requirements. Prime awardees will be able to report in FFATA Sub-Award Reporting System (FSRS) beginning October 29, 2010. Section 3: Policies and Procedures Pre-Award Process During the proposal process, Pre-Award will be responsible for sending the required Subcontract Commitment Form to the subrecipients. This form requests the required FFATA information. The status should be noted on the SPS Route Sheet. Specialist Expectations Send the FFATA document to each subrecipient (over $25,000) as applicable prior to submission. When preparing route sheet, mark the appropriate response at the top of the route sheet indicating whether or not the completed forms are included or if FFATA is not applicable to the proposal. After submission, place the file in the basket for the support staff to make file, send COI and enter Cost Share if applicable. If the file comes back from the support staff, follow up as appropriate. If FFATA is applicable and the form has not been returned by all subrecipients, the specialist must follow up with the subrecipient. Contact a minimum of two times to try to get the information. After the second request the specialist should notify the PI of the missing information and ask that the PI contact the subrecipient to follow up. At this time, Specialist should also notify the PI that any missing subrecipient information/ffata document will delay the set up of accounts if the project is funded. If the specialist cannot get the required information, the follow up dates and contacts should be included on the route sheet and noted that the information could not be obtained. Support Staff Expectations 3
Make the file per the normal process. Send COI and enter Cost Share if applicable. Check the route sheet to check the status of the FFATA document(s). If the information is not included, take the file back to the Specialist for follow up. If the proposal is being submitted by the IF area in Hovde, make a copy of the route sheet and any other important information. Return this information to the specialist for follow up. Once the information is received, send to the IF area to be included in original file. DO NOT file the proposal in the drawer until information is obtained or proper documentation on the status has been noted on the route sheet. Pre-Award Specialist Proposal request including subrecipient information comes from PI Pre-Award Specialist Sends Purdue's FFATA form to the subrecipient for completion. SubRecipent Subrecipient fills out necessary information and sends it back to Purdue. If received properly filled out If not received properly filled out Pre-Award Maintains the proposal file until the award is received. Pre-Award Specialist Follows up with subrecipient to obtain completed form a minimum of two times. If subrecipient does not respond, marks the route sheet appropriately aand maintains the file until an award is received. 4
Post-Award Process Post-Award/Contracting Expectations The account manager will complete the cost analysis worksheet and attach the prime agreement, scope of work, budget and FFATA information that was obtained at proposal time. This information will be forwarded to contracting to establish the subaward agreement. If the information required for the FFATA reporting was not obtained at proposal time, contracting will request the information within the subaward agreement. Post Award Request is made for new subaward agreement. Contracting Creates acceptable agreement and forwards it to potential subrecipient unsigned. Subrecipient Subrecipient fills out necessary information, signs it, and sends it back to Purdue. If Properly Filled Out If not properly filled out Contracting Sign off on subaward agreement and forward to appropriate area. Contracting Contracting will forward subaward agreement and FFATA form to appropriate account manager to follow up with subrecipient. 5
FFATA Data Requirements The following data is required from subrecipients for all grants, contracts, and vendor purchases on contracts that meet the FFATA requirements: 1) Name of entity receiving award a. Amount of award b. Funding agency c. NAICS code for contracts / CFDA program number for grants d. Program source e. Award title descriptive of the purpose of the funding action f. Location of the entity (including congressional district) g. Place of performance (including congressional district) h. CCR Registration i. Unique identifier of the entity and its parent (DUNS); and 2) Total compensation and names of top five executives (same threshold for prime) a. If a. More than 80% of annual gross revenues from the Federal government, and those revenues are greater than $25M annually and b. Compensation information is not already available through reporting to the SEC. Classified information is EXEMPT from the prime and sub-award reporting requirement as are contracts with individuals. FFATA Tagging When a new contract is being established by SPS it is required to type FFATA in the Internal Reference Tab on GM Grant in SAP. This is important so proper monitoring of vendor purchases is achieved. When does the FFATA Report need to be submitted? The month following the full execution of a subaward, subaward modification, or vendor payment. For Grants and Cooperative Agreements: Subawards that have a cumulative total of $25,000 or more must be reported. For Contracts: Subawards that have a cumulative total of $25,000 or more and/or individual vendor purchases of $25,000 or more must be reported. Subrecipients are not required to report FFATA if they reported less than $300,000.00 in gross income in the previous tax year. In addition, exemptions to the FFATA reporting requirements may occur and it is up to each 6
area to understand their sponsor s requirements. If an exemption occurs the account manager is to put in zeros in lieu of the DUNS number. FFATA Website Reporting Responsibility Grants and Cooperative Agreements It is the duty of SPS Post Award to properly submit and update the required FFATA information to the FSRS website. When an eligible FFATA award is received, the account manager is responsible for entering the information on the FSRS website. At that time, it becomes the account manager s responsibility to enter the information properly and get information from the subrecipient as needed. Contracts When a new subaward is issued it is the duty of SPS Post Award to properly submit and update the required FFATA information to the FSRS website. At that time, it becomes the account manager s responsibility to enter the information properly and get information from the subrecipient as needed. When a vendor form for a purchase over $25,000 is received, it is the responsibility of the account manager to enter the information online. The vendor form is then to be placed with the award documents and notated for quick reference. FFATA Reporting Process for ARRA Awards Any grants or cooperative agreements that have been funded through stimulus money are not required to report on the FSRS website. Any contracts that have been funded with stimulus money ARE required to report both through FederalReporting.gov and the FSRS website. Section 4: Helping Obtain DUNS Number It is the responsibility of all sub-award/vendor recipients to apply for and maintain a DUNS number. Obtaining a DUNS Number is completely free for all entities doing business with the Federal Government. Because of this, it is important to identify the agency/vendor as a federal grant applicant/recipient. Please use the following information to help guide any prospective sub-award recipient. All U.S. Locations U.S. and U.S Virgin Islands: 866-705-5711 Federal Contractors Option 3 Grantees Option 4 Loan Recipients Option 5 Alaska and Puerto Rico: 800-234-3867 Option 2 and then Option 1 International Locations Use online webform http://fedgov.dnb.com/webform Or use the online webform http://fedgov.dnb.com/webform 7
The following information is needed when applying for a DUNS Number Legal Company Name Headquarters Name/Address Tradestyle, Doing Business As, or other name by which your organization is commonly recognized. Physical Address, City, State, and Zip Code Mailing Address o If different from either Headquarters Address or Physical Address Telephone Number Contract Name and Title Number of Employees Once that information is gathered you may apply for a DUNS number. It takes 1-2 days to receive the DUNS number if the application is done online, if it is done over the phone it can be provided immediately. Section 5: How to Obtain CCR Registration Domestic Subrecipients The following information is required in order to obtain CCR registration for Domestic Subrecipients. 1) DUNS number 2) Tax Identification Number (TIN) and Taxpayer Name used in Federal Tax Matters a. Social Security number is an allowable TIN number 3) Statistical Information about your business 4) Electronic Funds Transfer (EFT) Information for payment of invoices Once the information is gathered, direct the Vendor/Subrecipient to go to SAM.gov and register. If assistance is needed in registering, please contact the appropriate Post Award account manager for help. For a step by step guide on how to register for domestic subrecipients/vendors please visit SAM.gov. International Registrants The following is required in order to obtain a CCR number for foreign institutions. 1) DUNS Numbers 2) NCAGE code a. http://www.dlis.dla.mil/forms/form_ac135.asp 3) TIN and EFT information not required 8
CCR Verification Revised: December 2012 It is the policy of Purdue University to verify that all vendors and subrecipients have an active CCR account. The best way to verify registration and status is through the SAM.gov. Please note that vendors may opt out of displaying their registration on the CCR website. In these cases you must follow up with the subrecipient/vendor to confirm they are registered. 9
Section 6: Purchasing Vendor tracking for FFATA is only required on Federal Contracts A) SRM Vendor Information FFATA SRM Report Form link under construction 1. Purchasing, in conjunction with the appropriate Account Manager will be gathering information on all individual vendor purchases exceeding $23,000. The procedures outlined in this document must be followed when it is possible that a payment made to a vendor (as defined in the relevant Federal reporting guidelines) from a FFATA grant that will exceed $23,000. This will ensure that the data is obtained from vendors as required in the FFATA reporting guidelines. These procedures will apply to the following contractual arrangements: Purchase Orders through SRM Purchase orders - $23,000 order amount will be the threshold for requesting vendor information, in order to compensate for potential shipping charges. What to Do Who How To Do It Review all requests for orders with FFATA requirements to determine if they meet the criteria for this process. Business office staff with SRM Requestor or SRM $2500 Approver role Flag the Order in SRM as FFATA. Business office staff with SRM Requestor or SRM $2500 Approver role For all orders funded from FFATA Contracts, identify any requests totaling $23,000 and go to the next step. Flag the order as being funded from FFATA Award XXXXXX, where XXXXXX is the six-digit grant number assigned by Sponsored Program Services. Enter FFATA Award XXXXX in (2) places: the Internal Notes field of the Shopping Cart on the first line item and somewhere in the Shopping Cart Name. If SRM Requestor, submit the shopping cart for approval. If SRM $2500 Approver, approve the shopping cart. 10
Review shopping carts in SRM Workbench over $23,000 and flag as FFATA if needed. Business Office Staff with SRM $50,000 Approver role Revised: December 2012 Search for orders in SRM Workbench totaling $23,000 or more. If FFATA is in the name, verify that the award is subject to FFATA and that the correct grant number is in the shopping cart name and Internal Note field. Then follow the usual procedure for review and approval of the order. If FFATA Award XXXXXX is not in the name, review funding source and identify any orders NOT yet flagged. Enter FFATA Award XXXXXX in (2) places: the Internal Notes field of the Shopping Cart on the first line item and somewhere in the Shopping Cart Name. Also enter the explanation for the change in the Notes for Approval, since the shopping will be routed back through the previous approvers. Then follow the usual procedure for review and approval of the order. Notify Vendor of additional data requirements for FFATA and this order Submit required data to Purdue Forward Vendor information to SPS and issue purchase order Receive and post data from Vendors Purchasing Staff Vendor Purchasing Staff SPS Account Manager On all orders over $23,000, check for FFATA Award XXXXXX in either the shopping cart name or in the Internal Note field. Follow the Purchasing internal process regarding FFATA funded purchases for communicating data requirements and contractual obligations to the Vendor. Complete the required information on the template supplied and return to Purchasing at Purdue in order for a purchase order to be issues on a FFATA award. Upon receipt of vendor information, forward to the appropriate account manager. Issue purchase order to the vendor. Upon receipt of the completed template of required information from vendors, enter information on the FFATA webpage. B) Direct Invoice Voucher (DIV) Vendor Information FFATA DIV Report Form link under construction Invoice Vouchers should not be processed until completed FFATA Form is received and approved by Sponsored Programs 1. The business office responsibility will be to gather all FFATA required information before payment is made with a DIV. The procedures outlined in this document must be followed when it is possible that a payment made to a vendor from a FFATA contract that will exceed $25,000. This will ensure that the data is obtained from vendors as required in the FFATA reporting guidelines. These procedures will apply to the following contractual arrangements: Consulting agreements Rental or lease agreements Software licensing agreements Service/Maintenance Contracts 11
Payments Processed with DIV Revised: December 2012 What to Do Who How To Do It Review reimbursement Business Office Staff Verify account to determine if the contract has FFATA regulations. requests to verify if funding source is Confirm FFATA Report Form has been received, if not, forward report to vendor. subject to FFATA If reimbursement request is subject to FFATA and the amount of the reimbursement is greater than or equal to $25,000, continue to the next step. Review, audit, and Central Performs necessary audit and approval of documents. approve documents. Disbursements Call Business Office to pick up held check. Desk Mail Out Payment Business Office Staff Ensure the FFATA Report Form has been returned to the business office. If not hold check until the form is received. Track FFATA Report Form SPS Account Manager SPS will monitor whether or not the business office has forwarded the report to SPS. 12