Let me maybe clear up a bit of this. The FAR Councils PILOTED (are piloting) reporting of subcontracts on awards of $500,000,000 with subcontracts of $1,000,000 or more (the Federal Register notice of this pilot appeared on Sept. 6, 2007 - 72FR51306). They used this approach to minimize the impact of the pilot program on contractors. When fully implemented, agencies (and their prime contractors) will be dealing with awards of $25,000+. FFATA, itself, sets this parameter but the threshold level for subaward reporting is not crystal clear. Thus, the discussion of levels or tiers, etc., that continues with grant pilot development. FFATA requires posting of prime awards (by the agencies) of individual transactions of $25,000 or more. The $25K threshold appears in the definition of "Federal award." The discussion of the pilot program uses "Federal award" without further definition. Thus, the assumption that subawards (subgrants, subcontracts, etc.) will meet the same definition = greater than $25,000. As Theresa' article notes, you can go online right now and find your award data at www.USAspending.gov. I join Bob in urging institutions to participate in the pilot. It is the way in which you can help create a system that will work for you. Carol -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Bob Beattie Sent: Friday, May 09, 2008 11:38 AM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Defend yourselves against FFATA subaward system. (long) The $500,000 only applies to current plans for reporting sub contracts. FFATA includes Federal financial assistance and expenditures that include grants, contracts, subgrants, subcontracts, loans, awards, cooperative agreements, purchase orders, task orders, delivery orders, and other forms of financial assistance; (B) does not include individual transactions below $25,000; and (C) before October 1, 2008, does not include credit card transactions. SO FFATA subgrants would include those made from all awards greater than $25,000 Bob On May 9, 2008, at 11:28 AM, Bloomberg, Robert wrote: Just to verify: FFATA applies only to awards greater than $500,000,000? -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf Of Bob Beattie Sent: Friday, May 09, 2008 11:15 AM To: xxxxxx@hrinet.org Subject: [RESADM-L] Defend yourselves against FFATA subaward system. (long) Hope that subject got your attention:) The subject can just as well be, "Participate in the FFATA Subgrant Pilot to make it better." First some background info, then a short rant, then a suggestion. As I have talked to people recently at various regional SRA and NCURA meetings, I have found that very few are aware of the Federal Funding and Accounting Tranparency Act (FFATA) implications. http://ftp.fas.org/sgp/congress/2006/ffata-house.html You can get some background info here, but some is out of date. www.ncura.edu/content/news/newsletter/docs/news_septoct07.pdf the Wikipedia link is http://en.wikipedia.org/wiki/ Federal_Funding_Accountability_and_Transparency_Act_of_2006 The President says "(FFATA) will allow Americans to log onto the Internet just to see how your money is being spent. This bill will increase accountability and reduce incentives for wasteful spending." Actually anyone with internet access can log in, not just Americans. The program will prevent wasteful spending by making Universities (and others) report on where there subaward (subgrants and subcontracts) go? The sponsors of this legislation use phrases like "will empower everyone with access to the Internet to begin reviewing the Federal grants and other forms of taxpayer assistance to look for waste, fraud, abuse or just to simply know who, in their community, or in other communities they are aware of, are receiving these grants. This legislation will also help to ensure that Federal laws are adhered to by those receiving taxpayer funds." And "Prevent pork barrel legislation." Of course, given the actual data that are to be reported, there is no way to find waste or prevent fraudulent spending, nor cut down on ear marks. The legislation just requires that universities add another compliance task to their already underfunded set of compliance mandates. Agencies, like the State Department who hid spending money to support prostitution in India (which sparked the legislation) will probably just not report such projects, anyway. We, already law- abiding, colleges and universities, will devote much time and effort to fully comply. In the proverbial nutshell, by Jan. 1. 2009, we will have 30 days to report into a yet to be developed internet site all subawards that we make. The legislation requires some 10 data elements to be reported. We might want to resist adding anymore. A very crucial aspect that is not yet determined is how many tiers down do we need to keep track of the awards -- just to the first subgrantee, or to any that are made by that entity, and beyond. There was supposed to be a pilot project to test this process beginning in July, 2007. It is now slated for June 23 - August 23, 2008. Quite a short span to work on such an important project. So I suggest that as many colleges and universities as possible try to get involved. This is going to be quite a bit of work for us once the real project starts so we need to have input. Those who worked on the subcontract pilot seem to have made things easy for themselves. "This rule applies to contracts with values equal to or greater than $500 million awarded and performed in the United States, and requires the awardees to report all first tier subcontract awards exceeding $1 million." How many of you will be reporting any subcontracts given those conditions? The same for grants? What can you do. First get the most up-to-date information. Participate in a teleconference on May 14, 2-4pm eastern time. Please send an email to: xxxxxx@aol.com by May 9 (later might be ok), confirming that you will participate by Conference Call TELECONFERENCE: 1-877-985-0932, Participant Code: 895294 Then volunteer to join the pilot, even if you expect to award no real subawards during that time. Learn what they will want us to do, and then tell them what YOU want to do. Perhaps we can all post some comments here as the program develops. I hope SRA and NCURA will have a session on their national convention programs on FFATA. We need to get involved in this before it exceeds the legislative requirements. You all know the federal motto -- "as long as we need to gather some data, why not get some more while we are at it." I hope we can all work together to mitigate the consequences of a generally good idea that may end up hurting us more than being helpful. Bob ps. I have been trying to keep track of this project, if I have gotten something wrong, please let me know, thanks. Also, opinions stated here are mine and not necessarily those of any organizations I am affiliated with. ------------------------------ Robert Beattie UMich e-Business Point of Contact UMich Grants.gov Liaison Managing Project Representative for Electronic Research Administration Division of Research Development and Administration University of Michigan xxxxxx@umich.edu (734) 936-1283 Editor, eRA Corner, NCURA Magazine ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
