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Re: FFATA Information Gathering Process Bob Beattie 15 Jan 2009 10:18 EST

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
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