Requirements for Federal Funding 

Accountability and Transparency Act 

Implementation 

In September 2010, the Office of Management and Budget issued Interim Final 

Guidance in the Federal Register (Volume 75, No. 177, September 14, 2010, 2 CFR 

Part 170) to establish reporting requirements necessary for the implementation of the 

Federal Funding Accountability and Transparency Act of 2006 (Pub. L. 109–282), as 

amended by section 6202 of Public Law 110–252. This award term implements those 

requirements and is located at 2 CFR Part 170. Learn more

Appendix A to Part 170—Award Term 

Reporting Subawards and Executive Compensation. 

a. Reporting of first-tier subawards.

1. Applicability. Unless you are exempt as provided in paragraph d. of this award 

term, you must report each action that obligates $25,000 or more in Federal 

funds that does not include Recovery funds (as defined in section 1512(a)(2) of 

the American Recovery and Reinvestment Act of 2009, Pub. L. 111–5) for a 

subaward to an entity (see definitions in paragraph e. of this award term). 

2. Where and when to report. 

i. You must report each obligating action described in paragraph a.1. of this 

award term to the Federal Funding Accountability and Transparency Act 

Subaward Reporting System (FSRS). 

ii. For subaward information, report no later than the end of the month 

following the month in which the obligation was made. (For example, if 

the obligation was made on November 7, 2010, the obligation must be 

reported by no later than December 31, 2010.) 

3. What to report. You must report the information about each obligating action that 

the submission instructions posted at http://www.fsrs.gov specify. 

b. Reporting Total Compensation of Recipient Executives.

1. Applicability and what to report. You must report total compensation for each of 

your five most highly compensated executives for the preceding completed fiscal 

year, if— 

i. the total Federal funding authorized to date under this award is $25,000 

or more; 

ii. in the preceding fiscal year, you received— 

A. 80 percent or more of your annual gross revenues from Federal 

procurement contracts (and subcontracts) and Federal financial 
assistance subject to the Transparency Act, as defined at 2 CFR 

170.320 (and subawards); and 

B. $25,000,000 or more in annual gross revenues from Federal 

procurement contracts (and subcontracts) and Federal financial 

assistance subject to the Transparency Act, as defined at 2 CFR 

170.320 (and subawards); and 

iii. The public does not have access to information about the compensation 

of the executives through periodic reports filed under section 13(a) or 

15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) 

or section 6104 of the Internal Revenue Code of 1986. (To determine if 

the public has access to the compensation information, see the U.S. 

Security and Exchange Commission total compensation filings at the 

Executive Compensation page of the SEC website.) 

2. Where and when to report. You must report executive total compensation 

described in paragraph b.1. of this award term: 

i. As part of your registration profile at the Central Contractor Registry. 

ii. By the end of the month following the month in which this award is made, 

and annually thereafter. 

c. Reporting of Total Compensation of Subrecipient Executives.

1. Applicability and what to report. Unless you are exempt as provided in paragraph 

d. of this award term, for each first-tier subrecipient under this award, you shall 

report the names and total compensation of each of the subrecipient’s five most 

highly compensated executives for the subrecipient’s preceding completed fiscal 

year, if— 

i. in the subrecipient’s preceding fiscal year, the subrecipient received— 

A. 80 percent or more of its annual gross revenues from Federal 

procurement contracts (and subcontracts) and Federal financial 

assistance subject to the Transparency Act, as defined at 2 CFR 

170.320 (and subawards); and 

B. $25,000,000 or more in annual gross revenues from Federal 

procurement contracts (and subcontracts), and Federal financial 

assistance subject to the Transparency Act (and subawards); and 

ii. The public does not have access to information about the compensation 

of the executives through periodic reports filed under section 13(a) or 

15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) 

or section 6104 of the Internal Revenue Code of 1986. (To determine if 

the public has access to the compensation information, see the U.S. 

Security and Exchange Commission total compensation filings at the 

Executive Compensation page of the SEC website.) 

2. Where and when to report. You must report subrecipient executive total 

compensation described in paragraph c.1. of this award term: 

i. To the recipient. 

ii. By the end of the month following the month during which you make the 

subaward. For example, if a subaward is obligated on any date during the 

month of October of a given year (i.e., between October 1 and 31), you 

must report any required compensation information of the subrecipient by 

November 30 of that year. 
d. Exemptions

If, in the previous tax year, you had gross income, from all sources, under $300,000, you 

are exempt from the requirements to report: 

i. 

i. Subawards,and 

ii. The total compensation of the five most highly compensated executives 

of any subrecipient. 

e. Definitions.

For purposes of this award term: 

1. “Entity” means all of the following, as defined in 2 CFR part 25: 

i. A Governmental organization, which is a State, local government, or 

Indian tribe; 

ii. A foreign public entity; 

iii. A domestic or foreign nonprofit organization; 

iv. A domestic or foreign for-profit organization; 

v. A Federal agency, but only as a subrecipient under an award or 

subaward to a non-Federal entity. 

2. “Executive” means officers, managing partners, or any other employees in 

management positions. 

3. “Subaward”: 

i. This term means a legal instrument to provide support for the 

performance of any portion of the substantive project or program for 

which you received this award and that you as the recipient award to an 

eligible subrecipient. 

ii. The term does not include your procurement of property and services 

needed to carry out the project or program (for further explanation, see 

Sec. ll .210 of the attachment to OMB Circular A–133, ‘‘Audits of States, 

Local Governments, and Non-Profit Organizations’’). 

iii. A subaward may be provided through any legal agreement, including an 

agreement that you or a subrecipient considers a contract. 

4. “Subrecipient” means an entity that: 

i. Receives a subaward from you (the recipient) under this award; and 

ii. Is accountable to you for the use of the Federal funds provided by the 

subaward. 

5. “Total compensation” means the cash and noncash dollar value earned by the 

executive during the recipient’s or subrecipient’s preceding fiscal year and 

includes the following (for more information see 17 CFR 229.402(c)(2)): 

i. Salary and bonus. 

ii. Awards of stock, stock options, and stock appreciation rights. Use the 

dollar amount recognized for financial statement reporting purposes with 

respect to the fiscal year in accordance with the Statement of Financial 

Accounting Standards No. 123 (Revised 2004) (FAS 123R), Shared 

Based Payments. 
iii. Earnings for services under non-equity incentive plans. This does not 

include group life, health, hospitalization or medical reimbursement plans 

that do not discriminate in favor of executives, and are available generally 

to all salaried employees. 

iv. Change in pension value. This is the change in present value of defined 

benefit and actuarial pension plans. 

v. Above-market earnings on deferred compensation which is not taxqualified. 

vi. Other compensation, if the aggregate value of all such other 

compensation (e.g. severance, termination payments, value of life 

insurance paid on behalf of the employee, perquisites or property) for the 

executive exceeds $10,000.