Federal Funding Accountability and Transparency Act

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Federal Funding Accountability and Transparency Act (FFATA)


Public Law 109-282, the Federal Funding Accountability and Transparency Act of 2006 as amended (FFATA), requires disclosure of all entities and organizations receiving Federal funds through a single publicly accessible website, USASpending.gov . USASpending.gov includes information on each Federal financial assistance award and contract with an obligation value of $25,000 and above, including such information as:

  1. The name of the entity receiving the award
  2. The amount of the award
  3. Information on the award including transaction type, funding agency, etc.
  4. The location of the entity receiving the award
  5. A unique identifier of the entity receiving the award; and
  6. Names and compensation of highly-compensated officers (as applicable)

Assistance Agreement Recipient Responsibilities


Compliance with FFATA is primarily the responsibility of the awarding Federal agency. However, grant and cooperative agreement recipients are responsible for reporting on executive compensation, when applicable, and subrecipient awards equal to or exceeding $30,000 in Federal funding.

Executive compensation and subrecipient reporting requirements generally apply to new discretionary and mandatory EPA funding, equal to or exceeding $30,000, awarded on or after October 1, 2010.

A prime recipient is required to report subawards where the obligations are equal to or exceeds $30,000 in Federal funds into the System for Award Management or SAM.gov. If a subaward is initially funded at less than $30,000, the prime recipient does not have to report the subaward to the System of Award Management (SAM). However, if the prime recipient subsequently provides additional funding to increase the subaward amount to $30,000 or more, the subaward must be reported in SAM.

Subaward reporting is specific to each assistance agreement. For example, if a prime recipient makes a subaward to an organization under one grant for $20,000 and another subaward for less than $15,000 to the same organization for different work under a different grant, the prime recipient would not have to report either subaward to the SAM, even though the cumulative value of the two subawards exceeds $30,000.

Recipients should not subdivide subawards equal to or exceeding $30,000 into smaller subawards in order to circumvent SAM reporting requirements.  All recipients are required to maintain an active SAM registration.

OMB guidance regarding FFATA related requirements is available at 2 CFR Part 170 and further details regarding these requirements are outlined below. 

System for Award Management (SAM) and Unique Entity Identifier Requirements

Unless exempt from the requirements under OMB guidance at 2 CFR Part 25, recipients of EPA assistance agreement funding are required to register with SAM and obtain a Unique Entity Identifier (UEI). Current recipients are required to keep their UEI number and SAM registration up-to-date. Recipients are required to update information in SAM annually at a minimum to remain in compliance with the terms and conditions associated with their award.

The UEI number is a unique twelve-digit identification number that identifies entities doing business with the Federal government and assigned based on an organization’s physical location. Organizations may have more than one UEI number, if there are multiple physical locations connected with that organization. Applicants and recipients can receive a UEI number by registering with SAM which will process the registration application within 5 business days.

Prime Recipient Executive Compensation Reporting


Prime recipients are required to report the names and total compensation of the five most highly compensated officers of their entity as part of their registration profile in SAM if the entity in the preceding fiscal year:

  1. received 80 percent or more of its annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and
  2. received $25,000,000 or more in annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and
  3. the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See FFATA §2(b)(1).

The prime recipient must include the data in its SAM registration profile by the end of the month following the month it receives an award, and annually thereafter.

Subrecipient Reporting Requirements


FFATA requires most recipients of new Federal funds awarded on or after October 1, 2010 report on subawards/subcontracts/consortiums equal to exceeding $30,000. This includes awards that are initially below $30,000 but subsequent grant modifications result in an award equal to or exceeding $30,000.

Recipients are required to report subrecipient information to SAM. This tool can be accessed directly at www.SAM.gov, and will serve as the collection tool for subaward data which will ultimately be distributed for publication and display on USASpending.gov. Grant recipients are required to register with SAM, collect the necessary data from subrecipients, and file subaward reports by the end of the month following the month in which the prime recipient awards any subaward greater than $30,000.

For first-tier subawards involving an obligation of $30,000 or more in Federal funds, EPA recipients must report the following information:

  1. Name of the entity receiving the award subward;
  2. Amount and date of the subaward;
  3. Funding agency;
  4. Assistance Listing number;
  5. Award title descriptive of the purpose of each funding action;
  6. Location of the sub-recipient receiving the award and primary location of performance under the award, including city, state, congressional district, and country;
  7. UEI number of the sub-recipient receiving the award and the parent entity of the sub-recipient, should the entity be owned by another entity.

Prime recipients are also required to report the names and total compensation of the five most highly compensated officers of the subrecipient if the entity in the preceding fiscal year:

  1. received 80 percent or more of its annual gross revenues in federal grants, subawards, contracts, and subcontracts; and
  2. received $25,000,000 or more in annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and
  3. the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See FFATA § 2(b)(1).

To complete the subrecipient reporting requirements, the prime recipient must maintain an active registration in SAM. They must report this information by the end of the month following the month a subaward obligation is made. For example, for a subaward made by a recipient on October 21st, the information must be reported to SAM no later than November 30th.

First-tier subrecipients must have a Unique Entity Identifier (UEI) before receiving a subaward, but do not have to maintain a SAM registration. Prime recipients may not delegate FFATA reporting responsibilities to subrecipients.

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Last updated on April 25, 2025