Here are the subaward instructions and templates to be used when UAA allows another entity to do a portion of a grant or contract.  All the federal regulations governing the Prime Award are then passed-through to the Subaward. 

Be aware that most subawards (either grants or contracts) will now require FFATA reporting.  The FFATA reporting requirement should be plainly stated in your Notice of Award.  If you do not understand this new Federal initiative, please contact your Grant Coordinator for clarification and assistance.

Detailed steps in creating a subaward agreement: Instructions & Routing Information

Subaward Agreement & Attachment 3A

Subaward Attachment 3B

Subaward Attachment 3B Page 2

Subaward Attachments 4-5

Subaward Attachment 4A for UAA ARRA Subawardees

Example of Attachment 4 - Reporting Requirements

As required under OMB A-133, UAA Procurement completes a risk analysis of the subrecipient prior to issuing the subaward. If a subrecipient is found to be high-risk, the subaward may include the following items:

• Corrective Action Plan
• On-site monitoring
• More detailed invoicing
• Receipt of technical progress reports tied to payments
• More stringent termination language for failure to comply with requirements

The FFATA Sub-award Reporting System (FSRS) will collect data from the Federal prime awardees on sub-awards they make: a prime grant awardee will be required to report on its sub-grants and a prime contract awardee will be required to report on its sub-contracts.

FFATA HRSA FAQ's

Contracts

In accordance with Federal Acquisition Regulation clause 52.204-10 (Reporting Executive Compensation and First-Tier Subcontract Awards), Prime Contractors awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any subcontract greater than $25,000. This reporting requirement will be phased-in (see below):

Phase 1: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $20,000,000, reporting starts now.

Phase 2: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $550,000, reporting starts October 1, 2010.

Phase 3: Reporting subcontracts under federally-awarded contracts and orders valued greater than or equal to $25,000, reporting starts March 1, 2011.

Although the requirement to report sub-awards is being phased-in at certain dollar levels, if you would like to start reporting prior to the start date for your subcontracts, the system is available to you for reporting

Grants

Prime Grant Recipients awarded a new Federal grant greater than or equal to $25,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $25,000. 

In accordance with 2 CFR Chapter 1, Part 170 REPORTING SUB-AWARD AND EXECUTIVE COMPENSATION INFORMATION, Prime Awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $25,000. The reporting requirements are as follows:

1. This requirement is for both mandatory and discretionary grants awarded on or after October 1, 2010.


2. All sub-award information must be reported by the prime awardee.


3. For those new Federal grants as of October 1, 2010, if the initial award is equal to or over $25,000, reporting of sub-award and executive compensation data is required.


4. If the initial award is below $25,000 but subsequent grant modifications result in a total award equal to or over $25,000, the award will be subject to the reporting requirements, as of the date the award exceeds $25,000.


5. If the initial award equals or exceeds $25,000 but funding is subsequently de-obligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.

The Federal Funding Accountability and Transparency Act (FFATA) of 2006 as amended in 2008 requires:

1. Information disclosure of entities receiving Federal funding through Federal awards such as Federal contracts and their sub-contracts and Federal grants and their sub-grantees
2. Disclosure of executive compensation for certain entitites
3. Establishment of an available website available to the public that contains information about each Federal award (USAspending.gov)

A powerpoint presentation regarding Making FFATA Transparent was presented at the NCURA annual meeting.  

An FSRS user guide can be accessed.  It is intended to be helpful to prime award recipients in their utilization of the FSRS Reporting System. Only prime award recipients will use this system.  Sub-recipients will report their information to the prime awardee.  Sub-recipients will not access the FSRS system directly.