FHWA releases new Q&A on funding, accountability
Q-9: What are the thresholds for FFATA reporting?
A-9: For new federal grants or cooperative agreements on or after October 1, 2010, if the initial award is $25,000 or more, reporting of subaward information is required. If the initial award is below $25,000 but subsequent award modifications result in a total award of $25,000 or more, the award is subject to the reporting requirements, as of the date the award exceeds $25,000. If the initial award is $25,000 or more, but funding is subsequently deobligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act.
Each action that obligates $25,000 or more in Federal funds must be reported.
If a single action obligates funding from multiple programs, the data submitted for that action would include the CFDA number for the program that is the predominant source of the Federal funding.
Q-10: Does it matter which phase of work is being obligated?
A-10: The criteria for reporting does not take into consideration the phase of a project, but rather depends on the dollar threshold, and only encompasses new awards provided on or after October 1, 2010, or amendments thereto.
Q-11: What constitutes a subaward? Is it both state-administered and locally administered project agreements, and just the latter category?
A-11: A subaward is administered by a subrecipient, who is accountable to the prime recipient for use of the federal funds under the award. As described in Sec. 11.210 of the attachment to OMB Circular A-133, this accountability would include responsibility for programmatic decision making, adherence to applicable Federal program compliance requirements, and uses Federal funds to carry out the federal program. As such, any LPA project, carried out by the state DOT on behalf of an LPA where the state DOT is actively rendering decisions and in control of the project, and not simply serving as a resource to the LPA, would not be classified as subaward for purposes of the Transparency Act.
Q-12: How will the federal agency reporting process work?
A-12: FHWA will report prime award information in the Federal Assistance Awards Data System (FAADS PLUS). This will be accomplished through existing processes and systems and will not require modifications to FMIS or other financial management systems. Information reported by FHWA will be used to pre-populate the new FFATA Subaward Reporting System (FSRS).
Q-13: How will prime recipients report this information?
A-13: Prime recipients will use the FSRS. The tool will pre-populate, to the maximum extent possible, recipient information from existing processes and systems, including the Central Contractor Registration System (CCR) to reduce the burden associated with this new FFATA reporting. All Federal contractors and prime grant recipients are required to register in CCR.
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