Putting Subaward Transparency Requirements to Test in ARRA

Under the Federal Funding Accountability and Transparency Act (FFATA) (P.L. 109-282), federal financial assistance to non-federal entities is to be tracked through the reporting of various data elements by fund recipients. While reporting requirements for primary financial assistance awards were implemented in 2008, specific requirements for the reporting of subawards remained unclear.

With passage of the American Recovery and Reinvestment Act (ARRA) (P.L 111-5), however, two basic requirements for subaward reporting have emerged: subrecipients must obtain a Data Universal Numbering System (DUNS) number and maintain current registration in the Central Contractor Registration (CCR) database. These and any additional future requirements for subaward reporting under ARRA apply to first-tier subrecipients only.

ARRA also instructs subaward reporting to comply with FFATA requirements on subawards. Given the lack of clarity surrounding specific data elements for suabaward reporting under the FFATA, federal agencies have differed in their approaches to subaward requirements under ARRA, to date. Recently proposed requirements for subaward reporting from the Office of Management and Budget (OMB) include additional data elements that should provide clarity on this issue.