Law Enforcing Financial Openness and Sovereign Spending Review
The Federal Funding Accountability and Transparency Act (FFATA) mandates detailed reporting of executive compensation and subrecipient awards for entities receiving federal funds. Here's a comprehensive guide to the process and requirements relating to FFATA reporting, specifically addressing the System for Award Management (SAM) registration and Unique Entity Identifier (UEI) obligations.
### 1. FFATA Reporting Requirements for Executive Compensation and Subrecipient Awards
Entities receiving federal funds over $25,000 must disclose information about subawards and executive compensation. The required data reported includes award details, location, UEI, compensation of top 5 executives, and more.
### 2. Unique Entity Identifier (UEI) and SAM Registration
All organizations, regardless of their country of origin, must obtain a UEI to be eligible for federal awards and subawards. This UEI is used for tracking purposes in FFATA reporting. The UEI replaces the DUNS number and is issued by SAM.gov. Subrecipients are required to obtain a UEI, though it may not be necessary at the time of application but is mandatory before an award is processed or subawarded.
Organizations must have an active registration on SAM.gov to receive federal awards. The registration process must be maintained active during the proposal review, award period, and for the entire duration of the performance period of the award. SAM.gov registration includes providing the UEI and other organizational details essential for FFATA compliance and federal transparency.
### 3. Compliance and Reporting Systems
Recipients of federal funds must report subaward information and executive compensation through the FFATA Subaward Reporting System, ensuring transparency and compliance regarding the distribution of federal funds. Agencies such as state authorities or entities like Missouri Environmental Improvement and Energy Resources Authority (EIERA) emphasize adherence to FFATA through policies requiring accurate and complete reporting aligned with 2 CFR 200, including sections on financial reporting, cost principles, and post-award requirements.
### Summary Table of Key Requirements
| Requirement | Details | |---------------------------------|-----------------------------------------------------------------------------------------| | Threshold for Reporting | Federal awards over $25,000 | | Data Required | Award details, location, UEI, compensation of top 5 executives | | UEI Requirement | Mandatory for all recipients and subrecipients before processing awards | | SAM Registration | Active SAM registration required for the entire award period | | Reporting Platform | FFATA Subaward Reporting System | | Regulatory Basis | FFATA (Public Law 109-282), 2 CFR Part 200 (Uniform Guidance) |
### Important Notes
- The process of obtaining or renewing SAM.gov registration/UEI can take 4-8 weeks; early registration is strongly advised. - The Single Audit Act requires subrecipients expending $750,000 or more in federal awards to audit their federal assistance and complements FFATA reporting requirements. - Entities may be exempt from executive compensation reporting if specified under rules, but generally, reporting is required for transparency purposes.
This comprehensive framework ensures accountability for federal funds by linking awards to transparent entity identification and by disclosing executive compensation for recipients of significant federal funding. The use of SAM and the UEI system standardizes this process nationwide.
- The subrecipient reporting requirements must be completed by the end of the month following the month a subaward obligation is made. - Recipients are required to update information in SAM annually to remain in compliance with the terms and conditions associated with their award. - The public does not have access to this information about their senior executives through periodic reports filed under specific sections of the Securities Exchange Act of 1934 or the Internal Revenue Code of 1986. - Prime recipients are required to report the names and total compensation of the five most highly compensated officers if they meet certain criteria. - For first-tier subawards involving an obligation of $30,000 or more in Federal funds, recipients must report the following information: Name of the entity, amount and date of the subaward, funding agency, Assistance Listing number, Award title, location, UEI number, and the parent entity if the sub-recipient is owned by another entity. - USASpending.gov includes information on Federal financial assistance awards and contracts with an obligation value of $25,000 and above. - Prime recipients are required to report subawards where the obligations are equal to or exceed $30,000 in Federal funds into the System for Award Management (SAM).
- In the process of receiving federal funds, businesses must adhere to financial transparency regulations and submit data related to subawards, executive compensation, locations, UEIs, and more, as mandated by the Federal Funding Accountability and Transparency Act (FFATA).
- To be eligible for federal awards and subawards, organizations must obtain a Unique Entity Identifier (UEI) issued by SAM.gov, which is used for tracking purposes in FFATA reporting. Furthermore, all entities, regardless of their country of origin, must maintain an active registration on SAM.gov for the duration of the award period.
