Grants and Funding

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Frequently Asked Questions
FFATA DUNS, SAM, Executive Compensation, and Subaward Reporting for NIH Grants
Last Revised: July 31, 2012

  A. General

  1. Who must report on subaward and executive compensation information?
  2. If I receive a New NIH award in FY2011, will I need to report subaward and executive compensation information in FY2012 once the Type 5 award is issued?
  3. How can I tell if my award is subject to the Transparency Act subaward reporting requirements?
  4. Does receiving a no-cost extension after October 1, 2010 invoke the reporting requirement if my grant was otherwise exempt?
  5. How should a grantee report on awards that are initially under $25,000 but subsequently receive additional funds that bring the total award over $25,000? What about awards that are initially over $25,000 but are subsequently reduced to less than $25,000.
  6. When must grantees report?
  7. Where do grantees report?
  8. What information are grantees required to report?
  9. I’m already filing annual progress reports and periodic financial reports with NIH. Does my institution have to file with FSRS too?
  10. How can I get more information on the NIH FFATA requirements?

  B. System for Award Management (formerly CCR), and DUNS Requirements

  1. Is a Dun & Bradstreet Data Universal Numbering System (DUNS) Number required for Federal agencies receiving federal grant funds?
  2. Must a subrecipient organization have a DUNS number for a subaward less than $25,000?
  3. Must a grantee institution have an active System for Award Management (SAM), formerly Central Contractor Registration (CCR) registration at the time they apply for an award?
  4. What happens if, for example, my institution applies for an award on October 30 and their SAM registration expires on November 2?
  5. Are foreign organizations required to obtain a DUNS number and register in SAM?
  6. Does FFATA also require subrecipients to register in the eRA Commons?

  C. Subaward and Executive Compensation Data

  1. What is a FAIN?
  2. I have a subcontract on my award with a vendor. Does my institution need to report this under the subaward reporting requirements?
  3. Are foreign grantees required to report executive compensation data under FFATA?
  4. Where do we report executive compensation?
  5. Whom do I contact at NIH if the agency-provided data in FSRS or USASpending appears incorrect?
  6. How should a grantee report on subawards that are expected to exceed $25,000 over the duration of the subaward, but for which the initial obligation is less than $25,000.
  7. My University has a large number of grants from NIH but I don’t see any of them listed in www.FSRS.gov. Is there a problem with the system?
  8. How long after my award is issued will it appear in FSRS.gov for reporting?
  9. What should I do if my award is not available in FSRS.gov for reporting?
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  A. General

  1. Who must report on subaward and executive compensation information?
    Recipients of NIH grants and cooperative agreement awards must report executive compensation and subaward information only when they receive New NIH (Type 1) awards issued on or after October 1, 2010, as well as all subsequent award actions to any such NIH grant and cooperative award; e.g., a Type 5 or Type 7 award issued subsequent to an applicable Type 1 award.  A New award can be identified by the “1” appearing as the first digit in the award number (e.g., 1R01CA987654).
  2. If I receive a New NIH award in FY2011, will I need to report subaward and executive compensation information in FY2012 once the Type 5 award is issued?
    In most cases the answer is yes.  For any New (Type 1) awards issued in FY2011, all subsequent award actions, including all subsequent non-competing continuation (Type 5) awards, are required to report executive compensation and subaward information in accordance with the Transparency Act.  The only exceptions are for awards to individuals, classified awards, awards under $25,000 in total costs, and awards to institutions with gross income of less than $300,000 from all sources in the previous tax year.  
  3. How can I tell if my award is subject to the Transparency Act subaward reporting requirements?
    All awards issued on/after 11/10/2011 will include language identifying whether the award is subject to the subaward and executive compensation reporting requirements of the Transparency Act.  This language will appear in the Terms and Conditions section (Section III) of each Notice of Award.  For awards where the Transparency Act applies, subaward reporting is triggered by a subaward obligation action (a subaward transaction that makes available to the subrecipient a known amount of funding for program purposes) of $25,000 or more.
  4. Does receiving a no-cost extension after October 1, 2010 invoke the reporting requirement if my grant was otherwise exempt?
    The reporting requirement is determined by the type of award and the date the award is made.  Receiving a no-cost extension has no impact on this determination.
  5. How should a grantee report on awards that are initially under $25,000 but subsequently receive additional funds that bring the total award over $25,000? What about awards that are initially over $25,000 but are subsequently reduced to less than $25,000.
    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 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 subaward amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.
  6. When must grantees report?
    In accordance with 2 CFR Chapter 1, Part 170 REPORTING SUBAWARD AND EXECUTIVE COMPENSATION INFORMATION, grantees are required to file a FFATA subaward report by the end of the month following the month in which they make any subaward obligation equal to or greater than $25,000.  Additionally, executive compensation data for the applicant organization must be included in that organization’s SAM profile at the time they apply for an NIH award.
  7. Where do grantees report?
    Do not report directly to NIH.  The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees (i.e., prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements.   That site is https://www.fsrs.gov/.  Prime contract awardees will report against sub-contracts awarded and prime grant awardees will report against sub-grants awarded. The sub-award information entered in FSRS will then be displayed on www.USASpending.gov associated with the prime award, furthering Federal spending transparency.
  8. What information are grantees required to report?

    Recipient organizations are only required to report subaward and executive compensation information, as described in NIH Guide Notice NOT-OD-11-005.  All other information is pre-populated from existing Federal agency databases to the maximum extent possible, and may be reviewed by recipients for data quality in the FSRS.  Upon completion, FSRS.gov will send the following subaward information for publication on USASpending.gov:

    1. The following data about subawards greater than or equal to $25,000 

    a. Name of entity receiving award

    b. Amount of award

    c. Funding agency

    d. CFDA program number (for grants)

    e. Program source

    f. Award title descriptive of the purpose of the funding action

    g. Location of the entity (including congressional district, as applicable)

    h. Place of performance (including congressional district, as applicable)

     i. Unique identifier of the entity and its parent; and

    j. Total compensation and names of top five executives (same thresholds as for primes)

    2. The Total Compensation and Names of the top five executives if:

    a. More than 80% of annual gross revenues from the federal government, and those revenues are greater than $25 million annually and

    b. Compensation information is not already available through reporting to the SEC

    Definitions for data elements may be found in the data dictionaries maintained at www.USASpending.gov.

    a. Name of entity receiving award

    b. Amount of award

    c. Funding agency

    d. CFDA program number (for grants)

    e. Program source

    f. Award title descriptive of the purpose of the funding action

    g. Location of the entity (including congressional district, as applicable)

    h. Place of performance (including congressional district, as applicable)

    i. Unique identifier of the entity and its parent; and

    j. Total compensation and names of top five executives (same thresholds as for primes)

    2. The Total Compensation and Names of the top five executives if:

    a. More than 80% of annual gross revenues from the federal government, and those revenues are greater than $25 million annually and

    b. Compensation information is not already available through reporting to the SEC.

    Definitions for data elements may be found beginning October 1, 2010 at the data dictionaries maintained on www.USASpending.gov.

  9. I’m already filing annual progress reports and periodic financial reports with NIH. Does my institution have to file with FSRS too?
    Yes.  NIH progress reports and financial reports are unrelated to Transparency Act reporting and you should continue filing these reports with NIH in accordance with established reporting requirements.  Additionally, file Transparency Act reports with FSRS for any subawards provided under your grant.
  10. How can I get more information on the NIH FFATA requirements?
    A useful resource on the NIH Federal Funding Accountability and Transparency Act requirements   can be found at: http://grants.nih.gov/grants/public_accountability/ffata.htm.  If you have questions about the FSRS.gov system used to report subaward and executive compensation data, please contact the Federal Service Desk at www.FSD.gov.  For all other Subaward and Executive Compensation reporting issues please send your questions to GrantsPolicy@mail.nih.gov or contact the Division of Grants Policy at (301) 435-0949.
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  B. System for Award Management (formerly CCR), and DUNS Requirements

  1. Is a Dun & Bradstreet Data Universal Numbering System (DUNS) Number required for Federal agencies receiving federal grant funds?
    Registration in System for Award Management (SAM), [which replaced Central Contractor Registration (CCR) in July 2012] is not required for Federal agencies that are prime grantees.  However, a DUNS number is required for Federal agencies receiving NIH awards as a prime recipient or as a subrecipient on an award to a prime recipient that is not a Federal agency.
  2. Must a subrecipient organization have a DUNS number for a subaward less than $25,000?
    Yes.  Grantees must ensure that all first-tier subrecipients have received a DUNS number at the time the subaward obligation is made, regardless of the dollar level of the subaward.
  3. Must a grantee institution have an active System for Award Management (SAM), formerly Central Contractor Registration (CCR) registration at the time they apply for an award?
    Yes.  Each entity that applies for an award and does not have an exemption must be registered in SAM prior to submitting an application.
  4. What happens if, for example, my institution applies for an award on October 30 and their SAM registration expires on November 2?

    Unless exempted from this requirement under 2 CFR 25.110, the recipient must maintain the currency of information in SAM until the final financial report required under this award is submitted or the recipient receives the final payment, whichever is later. This requires that recipients review and update the information at least annually after the initial registration, and more frequently if required by changes in the information.

    If a recipient has not complied with the requirement to maintain an active SAM  registration with current information, the NIH may determine that that institution is not qualified to receive an award.

  5. Are foreign organizations required to obtain a DUNS number and register in SAM?
    NIH has required all foreign and domestic organizations applying for NIH grants to have a DUNS number since October 1, 2003, and an active SAM registration is required for all foreign and domestic organizations applying electronically (through Grants.gov) for NIH grant support.  These requirements for applicant organizations have not changed except that the SAM registration requirement is now extended to all submissions—paper and electronic.  However there is a new requirement for foreign subrecipients to obtain a DUNS number; previously this was not required for foreign subrecipients.
  6. Does FFATA also require subrecipients to register in the eRA Commons?
    No.  SAM registration, DUNS numbers and eRA Commons registration are all very different requirements.  The use of DUNS numbers and registration in SAM allow the government to uniquely identify organizations, track awarded funds, and validate address/point of contact information. This is different than registration in eRA Commons which allows NIH applicants and grantees to interface electronically with NIH through the full life cycle of the grant application.  Institutional registration in eRA Commons is typically only required for prime grantee institutions (not subrecipients) that have not previously done business with NIH or its partner agencies.  eRA Commons registration is not part of the FFATA requirements.
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  C. Subaward and Executive Compensation Data

  1. What is a FAIN?
    A FAIN is a Federal Award Identification Number (e.g., R01CA987654) similar to the NIH Grant Number (e.g., 1-R01-CA987654-01).  According to OMB Federal Register Notice published on September 14, 2010, a FAIN is used to identify new Federal grants and cooperative agreements that are subject to executive compensation and subaward reporting, and differentiates these awards from other awards or obligating actions that provide additional funding under continuing awards funded in prior fiscal years. 
  2. I have a subcontract on my award with a vendor. Does my institution need to report this under the subaward reporting requirements?
    The subaward reporting requirements do not apply to vendor relationships when a prime recipient procures property and services needed to carry out the project or program as described in Sec. ___.210 of the attachment to OMB Circular A–133, ‘‘Audits of States, Local Governments, and Non-Profit Organizations’’.  The reporting requirements only apply to subawards, which are defined as a legal instrument that provides support for the performance of any portion of the substantive project or program for which you received the award and that you as the recipient award to an eligible subrecipient.  A subaward may be provided through any legal agreement, including an agreement that you or a subrecipient considers a contract.
  3. Are foreign grantees required to report executive compensation data under FFATA?
    The requirement for FFATA Executive Compensation reporting applies to both foreign and domestic grantees, as well as their subrecipients.  However, many foreign NIH grantees and subrecipients receive only small amounts of Federal funding and will not have reached the following levels in the previous fiscal year that require executive compensation reporting:  
    • 80 percent or more of the annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, and
    • $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act.

    In cases where a foreign institution receives significant Federal funding (as listed above), they are required to report executive compensation information under FFATA the same as U.S. domestic institutions.

  4. Where do we report executive compensation?
    Recipients of NIH awards subject to the executive compensation reporting requirement should provide this information in their Entity Management section of their System for Award Management (SAM) as part of the registration and updating process.  Subrecipients subject to the executive compensation requirements but who have not already provided it in their SAM profile should provide this information to the prime awardee for reporting through www.FSRS.gov.
  5. Whom do I contact at NIH if the agency-provided data in FSRS or USASpending appears incorrect?
    Grantees should contact the Grants Policy mailbox at GrantsPolicy@mail.nih.gov with information about any data quality issues regarding their grants.  Additionally, in the FSRS system grantees will see a red flag next to certain pre-populated data fields. Users can indicate that the data being auto-populated is incorrect by marking the “is this information correct?” field “no”. The grantee is then required to explain their response. While the submitted FFATA report data is not changed, the flag designation for the field, and the explanation of that flag, is viewable by NIH and the discrepancy will be reviewed.
  6. How should a grantee report on subawards that are expected to exceed $25,000 over the duration of the subaward, but for which the initial obligation is less than $25,000.
    In accordance with OMB guidance, each action that obligates $25,000 or more in Federal funds must be reported.  So the subaward reporting requirement is not triggered by actions that obligate less than $25,000.
  7. My University has a large number of grants from NIH but I don’t see any of them listed in www.FSRS.gov. Is there a problem with the system?
    In accordance with HHS guidance, NIH’s implementation of the FFATA subaward reporting requirements is limited to Type 1 (New) grants and cooperative agreements awarded after October 1, 2010 and any subsequent award action following such a “New” award.   For instance, if a grant was “New” (Type 1) in FY2011 and is subsequently awarded a Type 5 in FY2012, then that record should be seen in FSRS.  However, if a FY2012 Type 5 follows a Type 2 issued September 30, 2010 or before, then it will not be seen in FSRS.   So even if your institution has many awards issued before October 1, 2010, or any Type 2 or Type 5 awards issued after October 1, 2010, those awards will not appear for your institution unless they are a subsequent award to a “New” award issued on/after October 1, 2010.   
  8. How long after my award is issued will it appear in FSRS.gov for reporting?
    In most cases, awards should be available in FSRS.gov for reporting purposes within a month of the issue date listed on the Notice of Award.  Submission of grant award information from NIH requires transmission through multiple government systems, including the HHS TAGGS (Tracking Accountability in Government Grants System), before it becomes available in USASpending.gov. Time is then required for USASpending.gov to successfully transmit the data to FSRS.gov; only then is it available for subaward and executive compensation reporting.
  9. What should I do if my award is not available in FSRS.gov for reporting?

    NIH has received reports of grants that require subaward reporting through FSRS.gov not appearing on the site and being unavailable for reporting.  In these situations, we recommend grantees take the following actions:

    • Review the NIH Award Terms and Conditions web page (http://grants.nih.gov/grants/policy/awardconditions.htm) and confirm that the subaward reporting requirements apply to that particular grant.
    • If the award is over a month old, check USASpending.gov to see if the information has already been transmitted by NIH.  Award information may take at least a month before appearing in USASpending.gov so grantees should wait a bit longer before attempting to report again.
      • If the award is over a month old and the data is available in USASpending.gov, contact the Federal Service Desk (www.FSD.gov) for assistance with making it available in the FSRS.gov system.
      • If the award is over a month old and the data is not yet available in USASpending.gov, contact the NIH GrantsPolicy@mail.nih.gov mailbox for assistance.  You do not need to contact your Grants Management Officer or Program Official.

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