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Nonprofit Insider

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December 2010 Vol. 4 • No. 6

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
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The Price of Federal Funding: More Reporting
by Nelly Gizdova, Manager

$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 Subaward 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 compensation. In a memo to federal agencies, the Office of Management and Budget (OMB) clarified that awardees would be required to submit data only on first-tier sub-grants and sub-contracts.

f 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 Transparency 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 government 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 subrecipients) 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

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ARRA). The first reporting was due November 30, 2010, for the month ending October 31, 2010. The collected information on federal awards is then published and accessible 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 persons are excluded from reporting under FFATA. Other transactions that are presently exempted from reporting include individual transactions below $25,000 and credit card transactions before October 1, 2008.

Reporting requirements
All awardees should have implemented the requirement to collect sub-award data prior to October 1, 2010. Awardees and sub-awardees (recipients, sub-recipients, contractors and sub-contractors) should be prepared to report on applicable awards (grants, contracts and orders greater than $25,000), as soon as praccontinued on page 2

Who is affected?
FFATA affects a spectrum of entities: for-profit and nonprofit corporations, associations, partnerships, limited liability companies, limited liability partnerships, sole proprietorships, any other legal business entities and states or localities. Entities with gross income less than

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December 2010 Vol. 4 • No. 6

The Price of Federal Funding: More Reporting
continued from page 1

• Award title • Location of the entity (including congressional district) • Place of performance (including congressional district) • Unique identifier of the entity and its parent (if owned by another entity) Compensation and names of top five executives (prime and/or subawardee), limited to entities that have met all three of the following requirements: • More than 80% of annual gross revenues are funded by the Federal government, • Annual gross revenues are greater than $25 million in the previous fiscal year, and • Compensation information is not already available through reporting to the SEC or some other public source (IRS Form 990). For ARRA-funded contracts subject to FFATA reporting, the prime recipient will be required to report the contracts to both FederalReporting.gov and FSRS, if required by the contract. However, for ARRA-funded grants subject to FFATA reporting, the prime recipient will not be required to report the grants to both FederalReporting.gov and FSRS. ARRA-funded grants will continue to be reported to FederalReporting.gov only and all non-ARRA funded federal grants will be reported to FSRS.

ticable after the sub-award, or a subsequent 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 subawardees 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 information 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.

Award Database System (FAADS), the Federal Procurement Data System (FPDS) and the Central Contractor Registration System (CCR) to ensure quality data and minimize unintended data entry errors by sub-recipients. The federal agency making the award will prepopulate the prime award recipient information by reporting it in FAADS for grant awards and in FPDS for contract awards. FSRS interfaces with the above three systems (FAADS, FPDS and CCR) to make the information available to the general public in USASpending.gov. FSRS takes an “awardee-centric” approach, allowing the prime awardees to manage and report against multiple contracts and/or grants awarded to their registered DUNS number. The awardees can sort and filter their worklist by type, i.e. contract or grant, by awarding agency and by other filter terms. Awardees will be able to see, by award number, the FFATA sub-award reports filed against that particular contract and/or grant. Now, even though FSRS reporting is not specifically addressed in the latest A-133 audit guide, OMB considers this to be required reporting and, as such, the awardees’ timeliness and accuracy of FSRS reporting will be audited, and any non-compliance will result in a finding. Summing things up, sub-recipient monitoring and reporting and timeliness of the reporting are expected to be the major issues in the FFATA implementation process. ••• Please contact Nelly Gizdova, 410423-4800 or ngizdova@uhy-us.com for more information.

Sub-award reporting
The sub-award information reported 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

Making things a little easier
Some prime and sub-award information will be pre-populated in FSRS with data from the Federal Assistance

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.