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Re: Defend yourselves against FFATA subaward system. (long) Bloomberg, Robert 09 May 2008 15:12 EST

This clarifies a lot, but, just out of curiosity, does it seem at all odd that FFATA applies to awards over $25,000, but reporting of subcontracts applies, or will apply, only to awards of $500,000,000 with subs over $1,000,000?

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf
Of Carol Blum
Sent: Friday, May 09, 2008 3:25 PM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Defend yourselves against FFATA subaward system.
(long)

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

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 Instructions on how to use the RESADM-L Mailing List, including
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