Reporting requirements for federal awards are defined in OMB Circular A-110. A specific award may require further reporting, such as the positive or negative reporting of potentially patentable inventions or the requirement to report the acquisition of equipment under a particular award. A-110 provides the procedures for reporting financial and program performance and identifies the standard reporting forms for federal awards.
Agreement terms and conditions for federal and nonfederal awards typically specify any additional financial and performance reporting requirements. In recent years some institutions have been warned for failure to submit timely financial reports. Additionally, some federal agencies have withheld future funding from institutions because technical, financial, or patent reports on a past award were not submitted on time.
OMB recognizes that financial reporting can be excessive if not centrally managed. Therefore federal agencies usually follow common financial reporting formats. Federal agencies should not impose upon universities forms or frequencies of reporting that go beyond the requirements of OMB Circular A-110.
The Federal Financial Report (FFR, SF 425 and SF 425a), consolidates the Financial Status Report forms, SF 269 and SF 269A, and the Federal Cash Transactions Reports, SF 272 and SF 272a used previously. These forms replace multiple agency or program-specific forms. In implementing the FFR, OMB consolidated the reporting forms and standardized the reporting periods and due dates. OMB required that each federal agency to transition to the FFR (SF 425) by October 1, 2009 however some agencies did not meet the deadline.
Unlike the standard financial forms imposed on federal agencies by OMB, the performance reporting requirements are flexible. The performance report generally has a brief narrative on project progress in meeting the goals and objectives in the award documents. The performance report contains a comparison of actual accomplishments with those goals and objectives, the findings of principal investigators involved in research, and other data. When appropriate, and when the output of projects can be quantified readily, quantitative data may be related to cost data for computation of unit cost. PI’s/PD’s generally will be expected to provide reasons why established goals were not met and to identify corrective actions. Often the performance reports are coordinated with the submission of the financial status report. A-110 requires federal agencies to obtain at least one performance report annually and may obtain them as often as quarterly. Federal agencies are permitted to waive performance reports altogether. Often this waiver is provided when an application for continued funding satisfies the federal agency needs.
The American Recovery and Reinvestment Act of 2009 (ARRA) added somewhat burdensome quarterly reporting requirements, e.g. job creation and retention, to accomplish transparency and accountability. The Office of Management and Budget has a lead role in implementing ARRA for federal agencies. The federal government has established a Web site as the central repository for agency plans and information about the stimulus funding and spending.
The Federal Funding Accountability and Transparency Act of 2006 (Transparency Act or FFATA) required establishment by January 1, 2008, of a single searchable Web site, USAspending.gov, accessible by the public. Prime award data is available on the website. These data come from the federal agencies and departments that make the awards and are posted by them
Beginning October 1, 2010 (for new awards made on or after October 1), federal agencies were required to collect and report information on subawards as required by FFATA. Currently the reporting requirement extends only to first-tier subawards (subawards to other entities made by the University from direct federal awards) of $25,000 or more. The University is required to report all data elements for subawards.
The General Services Administration manages the reporting system, the FFATA Subaward Reporting System (FSRS) at
http://www.whitehouse.gov/sites/default/files/omb/assets/open_gov/OpenGovernmentDirective_04062010.pdf. The information is then publically available at http://www.usaspending.gov/.
Data items reported for subawards are:
- Name of entity receiving the award
- Amount of the award
- Award information, such as transaction type, federal funding agency, the North American Industry Classification System (NAICS) code for contracts or the Catalog of Federal Domestic Assistance (CFDA) number for grants and cooperative agreements, program source (Treasury Account Symbol), and award title that describes the purpose of the funding
- Location of the entity receiving the award and the primary location of performance under the award, including the city, state, congressional district, and country
- DUNS number of the entity receiving the award (and of the parent entity, when applicable)
- Name and total compensation of the top five executives of the entity (when applicable)
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