First: There is not a lot of data to collect, Below I give the specific text of the law regarding Sub-awards. Note the passed dates and the perhaps useless reference to indirect costs. Are any schools planning on increasing their rate based on FFATA costs. The law requires up to 17 data elements for the Sub award (from both Grants and Contracts) the same as for the primary award. Some of these data will come from the Primary Award -- most of (C). New data you will need are (A), (B), (D) & (E). You should know A, B and most of D. If you are using Grants.gov to get sub-award data, then you will know the DUNS number, or easily found in USASpending.gov for other universities. The organizations that will really have problems are state governments, such as Departments of Education that give out sub awards to 100's to 1000's of school districts. "includes for each Federal award— (A) the name of the entity receiving the award; (B) the amount of the award; (C) information on the award including transaction type, funding agency, the North American Industry Classification System code or Catalog of Federal Domestic Assistance number (where applicable), program source, and an award title descriptive of the purpose of each funding action; (D) the location of the entity receiving the award and the primary location of performance under the award, including the city, State, congressional district, and country; (E) a unique identifier of the entity receiving the award and of the parent entity of the recipient, should the entity be owned by another entity; and (F) any other relevant information specified by the Office of Management and Budget." So far OMB has not specified any other relevant data. Second, : the Federal Demonstration Partnership Sub-award committee, under leadership of Michelle Christy, MIT, is developing a national sub-award data site to hold much of the required items. Third: Where is the Sub-award Pilot now. A representative from OMB was supposed to come to FDP to tell us but he got hijacked to a Transition Team meeting. He wrote me the following "In terms of subaward reporting -- We continue to work to develop a process for reporting subaward information to USAspending.gov in accordance with the Transparency Act, but do not now have one in place. Recipients of federal funding who are subject to this requirement will be notified by their awarding agencies once the process and portal have been established and are ready for use. It is currently unclear when this will be, but recipients will be given sufficient notification of the requirements before they are expected to report." To which I replied "What you write is very scary! It sounds like there will be no more pilot, no more user participation. Just another Federal system imposed on grant recipients who will get a 'take it or else' mandate. We will get some warning of what's coming but no opportunity to respond? " But a further reply was somewhat reassuring "I didn't mean to imply that much. Based on the feedback we did recieve we understand the significant burden this could impose if not done well. I simply meant we don't know right now exacly what the next phase will look like, and will work to ensure everyone has some notice of what we are doing before we do it, even if the next phase is another pilot. I currently am hopeful that we will proceed with another, broader pilot, possible tracking all funding for a specific activity, such as the pending economic recovery act. This would allow us to meet some of the objectives the president-elect has discussed recently in his public statements, and would also give better information than our past pilots on the true costs and benefits of subaward reporting." So I guess that is a "stay tuned for further developments from the new Administration. No one is expecting us to be turning in sub- award reports now, but it might well be retroactive, once in place. ----------------------------------- (d) SUBAWARD DATA.— (1) PILOT PROGRAM.— (A) IN GENERAL.—Not later than July 1, 2007, the Director of the Office of Management and Budget shall commence a pilot program to— (i) test the collection and accession of data about subgrants and subcontracts; and (ii) determine how to implement a subaward reporting program across the Federal Government, including— (I) a reporting system under which the entity issuing a subgrant or subcontract is responsible for fulfilling the subaward reporting requirement; and (II) a mechanism for collecting and incorporating agency and public feedback on the design and utility of the website. (B) TERMINATION.—The pilot program under subparagraph (A) shall terminate not later than January 1, 2009. (2) REPORTING OF SUBAWARDS.— (A) IN GENERAL.—Based on the pilot program conducted under paragraph (1), and, except as provided in subparagraph (B), not later than January 1, 2009, the Director of the Office of Management and Budget— (i) shall ensure that data regarding subawards are disclosed in the same manner as data regarding other Federal awards, as required by this Act; and (ii) shall ensure that the method for collecting and distributing data about subawards under clause (i)— (I) minimizes burdens imposed on Federal award recipients and subaward recipients; (II) allows Federal award recipients and subaward recipients to allocate reasonable costs for the collection and reporting of subaward data as indirect costs; Bob ------------------------------ Robert Beattie FDP-eRA Representative, FFATA Sub-award Pilot Project UMich e-Business Point of Contact UMich Grants.gov Liaison Managing Senior Project Representative for Electronic Research Administration Division of Research Development and Administration University of Michigan xxxxxx@umich.edu (734) 936-1283 On Jan 15, 2009, at 8:14 AM, Hamaker, Amanda K wrote: We are currently developing a process for collecting the information from our subcontract recipients to meet the requirements of the Federal Funding Accountability and Transparency Act. We are curious how other Sponsored Programs Offices are approaching this matter. Any information you can share, particularly any forms you may have developed, are greatly appreciated. Thanks! Amanda Amanda Hamaker Senior Account Manager - NSF Sponsored Program Services YONG Hall, Room 716 Purdue University 765-494-4958 xxxxxx@purdue.edu ====================================================================== I nstructions 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") ======================================================================
