Dear All:

 

Regarding FFATA and CONTRACTS: From the FAR Interim Rule, case 2008-039, July 8, 2010, it is clear that under a contract to the Prime, there are 2 thresholds to consider in determining if you are eligible to report.  There is a threshold for the Prime (where until the end of this month for example, the contract to the Prime must be ≥$20M) and there is the threshold for the subcontract (…The Office of Management and Budget directed that the FAR be amended to initiate subcontract award reporting under the Transparency Act:  ∙ Subcontract reporting would apply only to first-tier subcontracts; ∙ The rule would phase-in the reporting of subcontracts of $25,000 or

more….) FAR page 39415.

 

But I am not as sure about my interpretation of the GRANTS approach after reading through the OMB Memo Aug 27, 2010 Guidance for Grants:    

-pg 6:

“In any new awards as of October 1, 2010, Federal agencies are required to include a new award term that delineates reporting requirements pursuant to the Transparency Act. The interim final term guidance with these standard terms and conditions will be forthcoming in the Federal Register. For those new Federal grants as of October 1, 2010, if the initial award is equal to or over $25,000, reporting of subaward and executive compensation data is required. 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. 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.”  My interpretation is that the $25K is the prime threshold.  And I can’t find a clear reference to a subaward threshold.  Or maybe I missed it.

 

Can anyone let me know specifically if there is a threshold for the subaward like there is with a subcontract (and provide your source)?

 

Thank you and Happy New Year,