FFATA Reporting for Federal Grants: Transparency and Accountability Requirements
Understand FFATA reporting requirements for federal grant recipients, including what data must be reported, submission timelines, and how to use the FSRS system for compliance.
What Is FFATA and Why Does It Matter?
The Federal Funding Accountability and Transparency Act (FFATA), enacted in 2006 and strengthened by the DATA Act in 2014, requires the federal government to make detailed information about federal spending available to the public. For grant recipients, FFATA creates specific reporting obligations that ensure taxpayers can see who receives federal funds, how much they receive, and what the funds are used for. This information is published on USAspending.gov, the government's primary transparency portal for federal spending data.
FFATA reporting is not just the federal agency's responsibility. Grant recipients, particularly those that issue subawards, have direct reporting obligations under the act. Failure to comply with FFATA reporting requirements can result in compliance findings in your single audit, conditions on your federal awards, and reputational consequences from having incomplete or inaccurate data publicly associated with your organization. For a broader understanding of post-award compliance obligations, see our post-award grant management compliance guide.
Prime Award Reporting: What Federal Agencies Report
For prime awards, which are grants made directly by a federal agency to a recipient, the federal awarding agency is primarily responsible for reporting award data to USAspending.gov. This data includes the recipient's name, address, and DUNS number (now replaced by the Unique Entity Identifier in SAM.gov), the award amount, the CFDA number, the award description, and the place of performance.
While the federal agency handles prime award reporting, the accuracy of the data depends on the information your organization provides during the application and award process. Ensuring that your SAM.gov registration is current and that all organizational information is accurate is essential. Inaccurate data in SAM.gov flows directly into USAspending.gov and becomes part of the public record. Our guide on the federal grant application process covers SAM.gov registration requirements in detail.
Subaward Reporting: Your Direct Obligation
When your organization acts as a pass-through entity and issues subawards of $30,000 or more under a federal grant, you are required to report information about those subawards through the FFATA Subaward Reporting System (FSRS) at FSRS.gov. This is a direct reporting obligation that falls on the prime grant recipient, not on the federal agency or the subrecipient.
What Must Be Reported
For each subaward of $30,000 or more, you must report the following information through FSRS:
- The subrecipient's name, address, and Unique Entity Identifier
- The subaward amount and date
- The subaward's place of performance
- A description of the purpose of the subaward
- The CFDA number associated with the prime award
- The prime award identification number
Reporting Timeline
Subaward reports must be submitted through FSRS by the end of the month following the month in which the subaward was made. For example, if you execute a subaward on March 15, you must report it in FSRS by April 30. This timeline requires that your grants management staff track subaward execution dates and maintain a calendar of reporting deadlines. Missing deadlines is one of the most common FFATA compliance issues, often resulting from a lack of awareness about the requirement or inadequate tracking systems.
Executive Compensation Reporting
FFATA includes a requirement for reporting the total compensation of the five most highly compensated executives of both the prime recipient and first-tier subrecipients, under certain conditions. This requirement applies when the organization:
- Received 80 percent or more of its annual gross revenues from federal contracts, subcontracts, grants, and subgrants in the preceding fiscal year, and
- Received $25 million or more in annual gross revenues from those sources in the preceding fiscal year, and
- The compensation information is not already available through the organization's IRS Form 990 filing or SEC reporting
Most nonprofit organizations will not meet all three of these conditions, but those that do must include executive compensation data in their FSRS reporting. The executive compensation requirement has been a source of confusion and concern for many grantees, but in practice it affects a relatively small number of organizations.
Practical Steps for FFATA Compliance
Building FFATA compliance into your standard operating procedures prevents missed deadlines and ensures accurate reporting. The following steps will help your organization meet its obligations consistently.
Designate a Responsible Individual
Assign specific responsibility for FFATA reporting to a member of your grants management team. This person should have access to FSRS.gov, understand the reporting requirements, and maintain a tracking system for subaward reporting deadlines.
Register for and Maintain Access to FSRS
Your organization must register in FSRS.gov to submit subaward reports. Registration requires your SAM.gov credentials and your federal award identification numbers. Ensure that your FSRS account is active and that login credentials are current before reporting deadlines approach.
Collect Required Data at Subaward Execution
The time to collect FFATA-required data from subrecipients is when the subaward agreement is executed, not when the reporting deadline arrives. Include data collection requirements in your subaward agreements and intake procedures so that all necessary information, including the subrecipient's Unique Entity Identifier and place of performance, is available when you need to file the report.
Verify Data Accuracy
Before submitting reports through FSRS, verify that all data elements are accurate and consistent with your subaward documentation. Inaccurate data becomes part of the public record on USAspending.gov and can trigger questions from federal agencies, auditors, or the public.
FFATA in the Broader Transparency Landscape
FFATA reporting is part of a broader federal push toward spending transparency that has accelerated significantly in recent years. The DATA Act expanded the scope and granularity of federal spending data, and Congress continues to explore ways to improve the quality and accessibility of this information. For grant recipients, this trend means that reporting requirements are likely to expand rather than contract over time.
Organizations that build strong data management and reporting systems now will be well-positioned to adapt to future requirements. This is particularly important for organizations that manage multiple federal awards and issue numerous subawards. Developing a systematic approach to grant submission and reporting, as described in our guide on grant submission and peer review strategies, creates the organizational discipline needed for consistent compliance across all reporting obligations.
Learn more about grant writing strategies at Subthesis.
Stay Ahead of Federal Reporting Requirements
FFATA reporting is one of many compliance obligations that federal grant recipients must manage effectively. Enroll in The Complete Grant Architect course to build a complete understanding of federal grant compliance, from application through closeout, and develop the systems your organization needs to meet every reporting requirement with confidence.
Learn more about grant writing strategies at Subthesis.