OMB Transparency Requirements Go Into Effect

Issue Brief 10-40
October 5, 2010

Summary 

In April 2010, the Office of Management and Budget (OMB) outlined its plans to fully implement Federal Funding Accountability and Transparency Act (FFATA, P.L. 109-282) requirements for recipients of federal grants and contracts. OMB set an October 1, 2010, deadline for prime recipients to comply with the sub-award reporting and compensation data requirements. To assist with the implementation process, OMB issued further guidance, including an awardee reporting architecture, on August 27, 2010. OMB then published final guidance on September 14, 2010, that mandates federal agencies to require prime recipients to maintain an active registration in the Central Contractor Registration (CCR), and both prime and sub-recipients to obtain DUNS numbers.

Unlike the reporting requirements under the American Reinvestment and Recovery Act (ARRA, P.L. 111-5), FFATA requires prime recipients to enter the sub-award data themselves. Prime recipients are now responsible for reporting sub-award and compensation requirements data on a rolling basis, with reporting due at the end of the month following the month the award was made. According to OMB, the new reporting system will be live on October 29, 2010, for registration and use. All awards made during October 2010 must be reported by November 30, 2010.