Understanding FFATA Reporting Requirements for Federal Subawards

What is FFATA?

FFATA was passed in 2007. It includes a mandate that entities receiving federal funds that issue subawards of $30,000 or more are required to log information about those subawards and subrecipients with the federal government. Subawards that meet this criterion must be reported in the system promptly.

FFATA was established to meet the need for a centralized database that would allow the public to see where federal funds are being directed. Prior to the introduction of FFATA, there was no single source for taxpayers to track the flow of tax dollars; hence, the desire for this additional layer of government oversight, allowing for accessible disclosure of this information.

Despite mandatory reporting since 2007, the method and system of reporting have evolved over the years.

When Does FFATA Reporting Not Apply?

Where Does My Organization Submit This Information?

Subawards must be logged in SAM.gov. As registration to SAM.gov is mandatory for any entity to submit bids, proposals or quotes for federal contracts, your organization may already have much of the required information and access in place. Once in the system, your organization will upload or input the basic information about both the subrecipient and the subaward issued to that subrecipient.

Where is FFATA Reporting Data Published?

All information from the filing submitted flows to USAspending.gov. This site serves as a hub for tracking the initial issuance of federal awards as well as the trail of subawarded funds exceeding the threshold noted above.

Why FFATA Reporting Compliance Matters

FFATA reporting is included within the scope of the Reporting portion of Part 3.1 – Compliance Requirements under 2 CFR 200. If your organization exceeds the $1 million threshold that triggers the need for an audit in accordance with Uniform Guidance, not complying with the requirements for FFATA reporting can result in a finding in your audit report.

Fortunately, this type of finding is often avoidable when an organization has appropriate internal controls in place to address the risk of untimely or incomplete reporting. These controls should include proper oversight to identify applicable subawards and verify that required reports are submitted by the applicable deadline.

Establishing Controls to Support FFATA Compliance

Just like any other reporting, at a minimum, all submissions should have separate preparers and reviewers. Ideally, two layers of review – one after the filings have been prepared and another after the filings have been submitted – to ensure they’ve officially been logged into the database. Organizations may comply with all other requirements associated with their funding, yet still receive an audit finding due to inadequate review controls over FFATA reporting.

With effective internal controls, your organization can reduce the risk of missed or late FFATA filings, avoid preventable audit findings and support compliance with federal reporting requirements.