# Presentation: 932487

## Federal Funding Accountability and Transparency Act of 2006

- Presented by**Matthew Faulkner and Tyson Whitney**

## Background

- Congress sponsored three different bills to create a searchable website for information on grants and contracts.
- President signed the Act on September 26, 2006.
- Establishes searchable website for the public to search funding by data elements.
- Able to ascertain amount of Federal funding awarded to an entity.
- Able to download results of search.

- Office of the Chief Financial Officer

**Notes:**
Sole Proprietorship could include FSA’s individuals since in most cases this is the producer’s main business.  The FFATA definition is being researched and a determination will be made this week.  This will be compared to the IRS regulations for reporting Sole Proprietorships.

      - IRS regulations says individuals are included because they are using their SS# (Faulkner in OCFO does not agree).

       - We are moving in the direction of including all individuals anyway

       - The Department was originally going to include individuals because of privacy act concerns to ensure consistency across the Department in using a unique identifier.

       - OMB was supportive of this to use DUNS as a unique identifier even under FFATA. 

        - FSA us pursuing clarification with the Department (and OMB).

## Who Receives Federal Funding?

- Inclusions:
- Corporation
- Association
- Partnership
- Limited Liability Company
- Limited Liability Partnership
- Sole Proprietorship
- Legal business entity
- After Jan 1, 2009, includes any subcontractor or subgrantee.

- Office of the Chief Financial Officer

**Notes:**
Sole Proprietorship could include FSA’s individuals since in most cases this is the producer’s main business.  The FFATA definition is being researched and a determination will be made this week.  This will be compared to the IRS regulations for reporting Sole Proprietorships.

      - IRS regulations says individuals are included because they are using their SS# (Faulkner in OCFO does not agree).

       - We are moving in the direction of including all individuals anyway

       - The Department was originally going to include individuals because of privacy act concerns to ensure consistency across the Department in using a unique identifier.

       - OMB was supportive of this to use DUNS as a unique identifier even under FFATA. 

        - FSA us pursuing clarification with the Department (and OMB).

## Who Receives Federal Funding?

- Exclusions:
- Individual recipient of Federal assistance.
- Federal employee.

- Office of the Chief Financial Officer

**Notes:**
 The better question is “what is the definition of an individual” given IRS believes individuals receiving FSA and CCC benefits are considered sole proprietorship (main farm business).

## Federal Awards

- Federal Financial Assistance & Expenditures:
**Includes:**
- Grants, subgrants, loans awards, cooperative agreements & other financial assistance.
- Contracts, subcontracts, purchase orders, task orders, delivery orders.
**Excludes:**
- Transactions below $25,000.
- Disclosure of classified information.
- Prior to October 1, 2008 – credit card transactions.
- Subawardees who demonstrate gross revenues of less than 300k in the previous tax year.

- Office of the Chief Financial Officer

## Searchable Website

- Launch of Website by January 1, 2008.
- OMB released data elements & definitions for reporting requirements on March 30, 2007.  They are:
- Name of entity receiving award;
- Amount of award (based on obligations);
- Award Date;
- Transaction type (Direct or guaranteed loan, grant, cooperative agreement, contract, or other);
- Funding Agency;
- North American Industry Classification System Code _**or**_ Catalog of Federal Domestic Assistance Number;
- Program Source;
- Award title description for purpose of funding action;
- Award Identifier;

- Office of the Chief Financial Officer

**Notes:**
Per discussions w/ OCFO, the USDA pilot program currently doesn’t include FSA/CCC.

Launch of Website by January 1, 2008 includes FSA/CCC Data.

Amount of award is based on obligations.  Initially, CCC programs will be using disbursements.

Amount of award for Direct Loans and Loan Guarantees has a two data element requirement.  Must include: 1) face value of the loan, and 2) estimated cost to government of providing the credit assistance. (estimated subsidy amount) This impacts FSA-FLP but the data is currently available in PLAS & GLS.
    - FLP St. Louis captures this and computes the amount of subsidy obligated by borrower through PLAS via a table

For loans and grants reporting of Catalog of Federal Domestic Assistance (CFDA) Number, FSA currently captures in the FAADS data base.  A task currently being coordinated is for FSA to update the CFDA for all applicable FFATA programs.

## Searchable Website (cont.)

- Data Elements (cont.):
- Location of the entity receiving the award including city, state, congressional district and 9-digit zip code;
- Primary location of performance under the award including city, state, congressional district and 9-digit zip code;
- Unique Identifier of the entity receiving award (i.e., Data Universal Numbering System (DUNS) number); and
- Parent Entity of the recipient should the entity be owned by another entity (DUNS number).
- Awards must be reported within 30 days of award.
- Conduct pilot program for search of subgrants/subcontracts starting  July 1, 2007.
- Scope of data includes FY 2007 awards and after.

- Office of the Chief Financial Officer

## Important Dates	

**March 30, 2007**
- OMB informed agencies of data elements and definitions reporting requirements
**April 2007**
- OMB will inform agencies of final technical solution for the website requirements
- Start development of website with search capability
**July 1, 2007**
- Conduct pilot program for search of subgrants/contracts
**January 1, 2008**
- Launch of website required under the Act
- Includes FY 2007 data, but not subgrantees or subcontractors
- Doesn’t include credit card transactions
**January 1, 2009**
- Pilot program shall terminate _prior_ to January 1, 2009
- Subgrants/Contracts to be included in website search
- Waiver for entities that prove they have annual gross revenues from previous tax year <$300,000
**January, 2010**
- GAO report on Act implementation
**Annually**: Report to Congress on implementation progress

- Office of the Chief Financial Officer

## FFATA Infrastructure

- FFATA Task Force (meets monthly)
- FFATA Committees (meet as needed)
- Contracts
- Grants Programs
- Loans, Subsidy, Insurance and Other Programs
- USDA Working Group (meets every Friday)
- USDA Agency Work Groups (meet as needed)

- Office of the Chief Financial Officer

## FFATA Functional Requirements

- Title 2 CFR will be amended to include the following requirements as a precondition to receiving an award:
- Acquiring a DUNS number;
- Registration in the Central Contractor Registry;
- Terms and Conditions to ensure that the FFATA data is reported by awardees and subawardees;
- New USDA Regulations will cover FY 2008 forward;
- Agencies must comply with Paperwork Reduction Act clearance requirements associated with asking for DUNS number data from customers.
- USDA plans to have a validation solution to provide DUNS numbers via the General Services Administration (GSA).
- This is expected to be available beginning the end of May.

- Office of the Chief Financial Officer

**Notes:**
Further discussions are needed in establishing transition timeframe for requiring DUNS number as part of program eligibility.

FSA is looking for Dept. guidance to help educate the borrowers and producers regarding the requirement to obtain a DUNS number.  A mass Public Relations program needs to be started ASAP.

 Bullet 3:  
   - Historically, under Debt Collection Information Act  (1996 DCIA) about 8 years ago, Treasury was pushing for all recipients to receive their payments electronically via EFT, but when the Department pushed as a condition of eligibility, Treasury backed off. (not all producers had access especially in remote areas – use of waivers for special conditions).

  - Requirement for DUNS needs to be communicated before FY2008 loan & producer payment cycle begins.

## Subaward Requirements	

- 2007: Conduct pilot to collect subaward data.
- 2009: Include subaward data in searchable website.
- Must be reported within 30 days of award.
- Data must be reported in same format as primary award.
- Cost of data collection and reporting to be charged to award as allowable cost.

- Office of the Chief Financial Officer

## FY 2007 Government-wideImplementation Strategy

- Acquiring DUNS numbers for customers who have received awards, but who have not provided a DUNS number:
- GSA validation to attempt to match award records with DUNS numbers;
- For records not matched to a DUNS number:
- Use Paperwork Reduction Act (PRA) collection notice to request DUNS from awardees; and then
- Issue communication to FY 2007 awardees to obtain DUNS number.
- Modify award applications/forms to collect FFATA data for use in FY 2008; and
- Modify systems, as necessary, to collect and report on FFATA data elements.

- Office of the Chief Financial Officer

## FY 2008 Government-wideImplementation Strategy

- 2 CFR
- FFATA requirements made as pre-conditions to receiving an award.

- Office of the Chief Financial Officer

## USDA Implementation Issues

- Develop USDA solution to meet both FFATA and Federal Assistance Awards Data System (FAADS) requirements.
- Modify award applications/forms to collect FFATA data for use in FY 2008.
- Modify systems, as necessary, to collect and report on FFATA data elements.

- Office of the Chief Financial Officer

## Proposed Database Alternatives– Front Runners

- OMB Watch:
- Purchase OMB Watch software and methodology.
- Expedites achievement of FFATA requirements.
- Federated Search:
- Creation of a distributed/federated environment to exchange and present the data.
- Maintenance of data at numerous sites.
- Each site would control and update locally.
- Search would be initiated from a common site.
- Estimated cost over five years $18M.
- Currently assumed this option will be adopted.

- Office of the Chief Financial Officer

**Notes:**
The other IT option is the Centralized Database which involves:
maintenance of single database to support all reporting requirements.
database will be updated with information extracted from individual agency databases.
Search would be initiated from a common site.
Estimated Cost over five years $57M - $67M.

None of these costs include costs for FSA development and maintenance.
Database to capture data.
Cost to incorporate and capture DUNS number.

## Additional Resources:

- General FFATA information: _[http://www.federalspending.gov/comments/comments.do](http://www.federalspending.gov/comments/comments.do)_
- OMB watch site: _[http://www.fedspending.org/](http://www.fedspending.org/)_
- FAADS: _[http://www.census.gov/govs/www/faads.html](http://www.census.gov/govs/www/faads.html)__ _
- USDA FFATA contacts:
- Matthew Faulkner: _[matthew.faulkner@usda.gov](mailto:matthew.faulkner@usda.gov)_
- Tyson Whitney: _[tyson.whitney@usda.gov](mailto:tyson.whitney@usda.gov)__ _

- Office of the Chief Financial Officer