Jump to content


Photo

Reporting subcontract awards and compensation - why does anyone do it?


  • Please log in to reply
22 replies to this topic

#21 contractor100

contractor100

    Bronze Member

  • Members
  • PipPipPip
  • 116 posts
  • Location:bethesda maryland

Posted 12 March 2012 - 01:57 PM

Carl, I notice that your correspondent at the help desk says: "...so you will then add the subaward to the system." Perhaps he is actually referring to a subgrant, as he says "subaward" not "subcontract"?

#22 contractor100

contractor100

    Bronze Member

  • Members
  • PipPipPip
  • 116 posts
  • Location:bethesda maryland

Posted 12 March 2012 - 02:33 PM

Sorry, that was wrong, I see "subaward" means both subcontract and subgrant.

#23 contractor100

contractor100

    Bronze Member

  • Members
  • PipPipPip
  • 116 posts
  • Location:bethesda maryland

Posted 12 March 2012 - 04:32 PM

Quote

Who is required to file a FFATA report in FSRS?
The FFATA Sub-award Reporting System (FSRS) will collect data from Federal prime awardees on sub-awards they make: a prime grant awardee will be required to report on its sub-grants and a prime contract awardee will be required to report on its sub-contracts.

CONTRACTS
In accordance with Federal Acquisition Regulation clause 52.204-10 (Reporting Executive Compensation and First-Tier Sub-contract Awards), Prime Contractors awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any sub-contract greater than $25,000. This reporting requirement will be phased-in (see below):

Phase 1: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $20,000,000, reporting started July 8, 2010.

Phase 2: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $550,000, reporting started October 1, 2010.

Phase 3: Reporting sub-contracts under federally-awarded contracts and orders valued greater than or equal to $25,000, reporting starts March 1, 2011.

Although the requirement to report sub-awards is being phased-in at certain dollar levels, if you would like to start reporting prior to the start date for your sub-contracts, the system is available to you for reporting.

GRANTS
In accordance with 2 CFR Chapter 1, Part 170 REPORTING SUB-AWARD AND EXECUTIVE COMPENSATION INFORMATION, Prime Awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $25,000. The reporting requirements are as follows:
  • This requirement is for both mandatory and discretionary grants awarded on or after October 1, 2010.
  • All sub-award information must be reported by the prime awardee.
  • For those new Federal grants as of October 1, 2010, if the initial award is equal to or over $25,000, reporting of sub-award and executive compensation data is required.
  • If the initial award is below $25,000 but subsequent grant modifications result in a total award equal to or over $25,000, the award will be subject to the reporting requirements, as of the date the award exceeds $25,000.
  • If the initial award equals or exceeds $25,000 but funding is subsequently de-obligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.
I believe the material quoted from the website, see above, refers to the initial grant from the agency, not the subgrant. It is not clearly written, but here this is from the OMB guidance.

For those new Federal grants as of October 1, 2010, if the initial award is equal to or over
$25,000, reporting of subaward and executive compensation data is required. If the initial award is below $25,000 but subsequent grant modifications result in a total award equal to or over
$25,000, the award will be subject to the reporting requirements, as of the date the award exceeds $25,000. If the initial award equals or exceeds $25,000 but funding is subsequently de- obligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.

The statute says" Federal awards" must be reported and the definition of Federal awards excludes "individual transactions" below $25K. See below. So, the exclusion should be identical for the federal contract or grant and the subaward issued below it?
If so:

1. What if a contract is awarded below $25K and subsequently increased by mod to greater than $25K? Does 52.204-10 have to be added by mod, or does it kick in automatically if a mod increases the value of the K? I cannot tell from the FAR
2. If no to above question, why does OMB stipulate that the statute applies for grants that get new money?
3. Shouldn't subcontracts/grants be treated exactly the same as contracts/grants?

(2) F

EDERAL AWARD.—The term ‘‘Federal award’’—
(A) means Federal financial assistance and expenditures
that—
(i) include grants, subgrants, loans, awards,
cooperative agreements, and other forms of financial
assistance;
(ii) include contracts, subcontracts, purchase
orders, task orders, and delivery orders;
(B) does not include individual transactions below
$25,000; and
© before October 1, 2008, does not include credit
card transactions.




0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users