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New Reporting Rules for Direct Recipients of Federal Awards and Contracts

May 02, 2011

Reed W. Risteen, CPA

The Federal Funding Accountability and Transparency Act of 2006 (FFATA) and related 2008 amendments have imposed new federal reporting requirements on non-profit organizations that receive direct federal grants of $25,000 or more. Those federal grant recipients are now required to report information on associated "first tier" subgrants of $25,000 or more. The terms "subrecipient" or "delegate" agency are also commonly used to signify subgrants.

The following information must be reported by the end of the month following the month the subaward was made:

  • Name of entity receiving the subgrant
  • Amount of award
  • Federal funding agency
  • Catalog of Federal Domestic Assistance Number
  • Program source
  • Award title/description of purpose of funding action
  • Location of the subgrantee, including congressional district
  • Place of program performance
  • Unique identifier of the subgrantee and its parent
  • Total compensation and names of top five executives of prime grantee or subgrantee, subject to certain exceptions

The implementation dates of the reporting requirements are phased in based on the size of the prime award as follows:

  • Phase 1 - Prime awards greater than $20M – July 2010
  • Phase 2 - Prime awards greater than $550K – October 1, 2010
  • Phase 3 - Prime awards greater than $25k – March 1, 2011

Although this requirement has been in effect for several months, OMB is encouraging auditors to remind their clients of the requirement.

Resources to assist non-profit organizations in complying with the requirement can be found at USA


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