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TITLE 2—Grants and Agreements Subtitle A — OFFICE OF MANAGEMENT AND BUDGET 

GUIDANCE PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND 

AUDIT REQUIREMENTS FOR FEDERAL AWARDS

PART 170—REPORTING SUBAWARD AND EXECUTIVE COMPENSATION INFORMATION

OMB's August 27, 2010 Guidance - Open Government Directive – Federal Spending Transparency and 

Subaward and Compensation Data Reporting 

QUESTIONS APPLICABLE TO ALL CNCS GRANTEES

1. What is a prime grantee versus a subgrantee?

The term “prime grantee” refers to a non-federal entity that receives a grant directly from CNCS. Prime

grantees both apply for and receive their grants through CNCS’s eGrants system without the involvement

of an intermediary agency or organization. Regulations found at §200.74 define a prime grantee that

awards subgrants to other organizations be a “pass-through entity.”

The term “subgrantee” refers to the non-federal entity that receives a pass-through grant from a CNCS

prime grantee; these pass-through awards are commonly called subgrants, subawards, and subrecipient

funding. While the eGrants system supports collecting subgrant applications on behalf of some prime

grantees, the eGrants system is not used to award subgrants. All subgrants are awarded by prime

grantees using their own policies and systems.

You can also examine your grant number to determine if you hold a CNCS prime grant, or a subgrant.

CNCS assigns 10-character grant numbers to prime grants. These prime grant numbers always begin with

a two-digit fiscal year identifier (FY) and always have a two-character State (ST) abbreviation at the sixth

and seventh positions: FY###ST###. Only recipients of grants with the FY###ST### grant number syntax

are CNCS prime grantees. Subgrant awards will carry an identifying number but not with this precise

Title: USA Spending and Subaward Reporting Date issued: May 8, 2019

Date posted: February 28, 2020 Unique identifier: CNCS 009

Topic: FAQs that provide guidance to CNCS grantees on usaspending.gov and prime grantee responsibilities for uploading subgrant 

data.

Summary: This outline is a training tool designed to help new AmeriCorps program staff create strong member position descriptions.

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document 

is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.

FAQs: USASpending.gov and Subaward Reporting 

May 1, 2019 / Version 1.0 

These frequently asked questions are intended to provide guidance to CNCS grantees and their support 

networks on the importance of USASpending.gov; how CNCS uploads prime grant data for public access; and 

prime grantee responsibilities for uploading their subgrant data. This first edition arises from discussion during 

a March 21, 2019 CNCS webinar on this topic. 

Definitions for acronyms and abbreviations used throughout this document are found at the end. 

Regulations and other referenced guidance include: 
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syntax/format. Many, but not all, prime grantees choose to number their subgrants by adding numbers or 

a suffix to the CNCS prime grant number; other prime grantees use an entirely different subgrant 

numbering schema. 

2. Are all CNCS prime grantees authorized to subgrant? 

While CNCS’s grant programs offer robust opportunities to subgrant, not all programs permit 

subawarding. T&Cs assigned to every CNCS grant identify controlling rules and requirements. 

3. Does CNCS expect prime grantees and subgrantees to enter data into USASpending or does CNCS 

extract the information from eGrants and we grantees use this as a research tool?

Under the controlling laws, both CNCS and its prime grantees have separate reporting responsibilities. 

Reporting (uploading) prime grant data into USASpending is a federal responsibility, therefore all prime 

grant reporting is performed by CNCS. Reporting subgrant awards into FSRS is not a federal 

responsibility, instead CNCS prime grantees must perform the upload of their subgrant records into FSRS. 

This is sometimes referred to as first-tier subgrant reporting.

Because we know that there are communication bugs between USASpending and FSRS, we ask prime 

grantees to advise us when they believe their grant or subaward data is missing or incorrect in either 

system. After accounting for the anticipated lag times noted in FAQ #8, prime grantees should report 

concerns that their grant awards are missing or incorrect to knowledgemanagement@cns.gov. 

4. How are USASpending and FSRS related to one another?

All federal agencies must report their federal contract and grant spending into USASpending. Federal 

contract and grant recipients must report their subcontract and subgrant spending into the FSRS, including 

executive compensation data. The two systems share data to associate a prime award with its subawards 

(if any), combining the information into a useful record. The USASpending system is designed to support 

transparency and is the portal for providing public access to the data without needing user accounts.

5. Is subaward reporting a requirement of all federal award recipients or specific to CNCS grantees?

The requirement is federal government-wide. All federal agencies must report their prime contract and 

grant awards into USASpending, and all prime grantees and prime contractors must report their subgrants 

and subcontracts, respectively, into FSRS. Prime grantees do not report their subcontracts unless they 

administratively use contract vehicles to award subgrants. These requirements are explained in OMB's 

August 27, 2010, guidance for reporting subaward and executive compensation data pursuant to the Transparency 

Act, and in CNCS’s grant T&Cs.
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6. We receive a federal grant but do not use that funding to provide subawards, are we required to report?

No. If you do not subaward, you do not have to, and should not, report into FSRS. FSRS is used to 

capture and report subaward and executive compensation data on subawards to meet the FFATA 

requirements.

7. Who is not a subgrantee? 

A vender is not a subgrantee. Vendors are dealers, distributors, merchants, consultants, or other sellers 

providing goods or services that are needed to conduct your grant program.

8. I've noticed some awards do not immediately appear in USASpending. Is there a lag between the date 

an award is made and the date it can be found in USASpending?

There are time lags between when grants and subgrants are awarded and their data is posted simply 

because the law provides time for performing the reporting. Also, there are system lags between upload 

and display, and we know that some data is omitted due to unresolved system bugs. Our current 

understanding reporting and system related lag times is:

Action Reporting Deadline Reporting Practice Data Display Lag

CNCS awards prime grant.

20 calendar days after the 

close of the month during 

which the prime grant 

was awarded.

5 business days or less 

after the close of the 

month during which 

the grant was awarded.

Up to 2 calendar days in USASpending.

USASpending transmits 

prime data into FSRS. Automated Automated

Overnight but can be up to 30-days. 

Some records require help desk 

intervention.

Prime grantee awards 

subgrant.

End of the month 

following the month 

when the subgrant was 

awarded.

Variable between prime 

grantees.

Up to 10 business days to display in 

FSRS.

FSRS transmits subaward 

data into USASpending. Automated Automated Up to 30 calendar days to display in USASpending.

If you believe data is not current or accurate by the end of these lag times, you should report the case to 

CNCS at knowledgemanagement@cns.gov.

9. What uniformity exists in the way agencies are expected to post their data? 

With respect to the format and meaning of each data element total uniformity is expected but not yet 

achieved. Prime grant award data posted by CNCS and the subgrant data posted by prime grantees can 

only include the prescribed data elements that these systems collect. Data uploading is screened using 

electronic “data brokers.” While the screening is mostly successful, data brokers do not block all non-
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conforming data. The DATA Act is compelling federal agencies to make significant investments to resolve 

and strengthen data consistency.

QUESTIONS APPLICABLE TO STATE SERVICE COMMISSIONS ONLY

10. Does CNCS report formula grant funds to USASpending?

Yes. We upload every grant awarded for all CNCS grant programs, including formula grant funds 

awarded to State Service Commissions.

QUESTIONS REGARDING REPORTING SUBGRANT (SUBAWARD) DATA

11. Do prime grantees enter subgrant information, or is it extracted from eGrants?

Prime grantees enter subgrant data into the FSRS. Subgrant data is not extracted from eGrants. 

12. When must we report subgrants?

You are required to report the award of subgrants into FSRS no later than the end of the month that follows 

the month when the subgrant was awarded or amended. For example, two subgrants awarded under the 

same prime grant, one on June 1st and the other on June 10th, must both be reported into FSRS no later than 

July 31st of the same year.

13. Do cooperative agreements have to be reported?

Both USASpending and FSRS consider the term "grants" to include grants and cooperative agreements.

14. How do we determine the dollar threshold for subaward reporting?

You must report a subaward if the subgrant will cumulatively equal or exceed $25,000 of federal funds 

awarded to that organization through that individual subgrant, inclusive of any planned continuation 

awards or funding amendments. The $25,000 or more requirement means that you must: 

• report all subawards at the $25,000 and greater threshold, which is cumulative over the life of the 

award.

• report initial awards that are below $25,000 but subsequent grant modifications will result in a total 

award equal to or over $25,000, when the award reaches or exceeds $25,000. 

• report awards that equal or exceed $25,000 but funding is subsequently de-obligated such that the total 

award amount falls below $25,000; the entire award record continues to be subject to the reporting 

requirements.
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CNCS encourages its prime grantees to report all subawards, including zero-dollar and awards that will 

not reach the reporting threshold. Practiced by CNCS, we have found the approach to not only be in the 

public interest, but simpler to administer since it is unnecessary to screen by award amount.

15. What data do we report into FSRS?

Reporting requires uploading the following subaward information for each subgrant:

 

• Name of entity receiving award, 

• Amount of award (federal funds only),

• Funding agency, 

• CFDA program number, 

• Program source,

• Award title descriptive of the purpose of the funding action, 

• Location of the entity (including congressional district), 

• Place of performance (including congressional district), 

• Unique identifier of the entity and its parent (DUNS), and 

• Total compensation and names of top five executives (same thresholds as for primes) if:

o More than 80% of annual gross revenues of the prime come from the federal government, and 

those revenues are greater than $25M annually; and, 

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

To avoid reporting delays, a best practice is to ensure that the prime grantee’s policies collect these data 

points when the subgrant is applied for and awarded.

 

16. It can be a challenge to collect information from subawards within the timeline specified and/or with 

the complete information requested. What can prime grantees do to facilitate this collection?

Please review FAQ #15. The data needed to report into FSRS should be collected by prime grantees before 

awarding a subgrant and therefore should not be a hinderance to reporting on-time.

17. Reporting in FSRS is really confusing. How do I create a report, edit mistakes, and capture 

deobligations in my reporting? 

Although CNCS does not control or use the FSRS system, we are working to better communicate reporting 

procedures and to address our prime grantees’ concerns with GSA (the system owners). The procedure for 

reporting is described below.

FSRS reporting requires that you fist identify your prime grant(s) on a worklist where the prime awards are 

associated with your prime grantee DUNS number. Once you have the correct prime grant(s) on your 

worklist you can create a report from either the Quicklinks section by clicking the Create FFATA Report
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button or from the main navigation select Create/Review Reports, then click FFATA Report or Batch Upload 

Report. Reports in FSRS can either be draft, submitted or reopened status. If desired, you can save reports 

in draft if you prefer to assemble and enter award information as it becomes available during a reporting 

cycle. A submitted report cannot be deleted; you can only delete draft reports. If you want to report 

changes to a subaward, you create a new report for that subaward from Quicklinks or use the Copy button 

on the existing subaward report to create and submit a report of the additional funding amounts against 

that subaward.

FSRS accepts one report a month per subaward. How many reports per subgrant you create depends on 

whether you amend that subgrant; the system supports up to 12 reports a year for one subaward. The 

amount per subgrant is cumulative of all submitted reports for that subgrant, meaning the amounts in each 

report are added together to sum to the total presented as the cumulative awarded federal funding under 

that subgrant. 

Reopening and resubmitting the same report to update for monthly changes over the life of the subgrant is 

incorrect. Instead, reports are submitted one for each time you award or amend a subgrant. Once the first 

initial subgrant report is submitted, there is no need to report again until you add or subtract federal funds 

from that subgrant. Submitting reports when you have not awarded additional federal funds will create 

duplicate amounts in your cumulative record for that subgrant.

A Reopen to Edit function is provided so that changes can be made to a report. You would open an existing 

report and resubmit if you needed to make corrections to already submitted data. This is performed by 

going to the original, initial subgrant report and make the changes/correction to that report. 

CNCS is investigating reports that FSRS will give you an error and not let you proceed if you try to report 

on a subgrant awarded earlier than October 1, 2010 and less than $25,000. 

18. What do I do if my prime grant number is not in the FSRS?

Contact us at knowledgemanagement@cns.gov. Please allow ten (10) business days for us to create a help 

desk ticket, resolve the problem, and notify you. We are addressing a known, apparently random and 

infrequent bug, that prevents FSRS and USASpending from exchanging prime and subgrant data as 

expected.

QUESTIONS REGARDING USASpending

19. Is data searchable by Congressional District?

Users can query by congressional district or a combination of congressional district and other search filters 

such as awarding agency and federal fiscal year by using the advanced search feature.
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20. Can I use SQL in advanced search?

A SQL search feature does not currently exist. We have asked the developers to create this feature, and 

they are considering it. Data can be downloaded then uploaded into database software such as Access to 

perform SQL searches.

21. Are non-federal matching fund amounts included in the amounts reported? 

CNCS must include non-federal share (matching) dollar amounts when reporting prime grant awards into 

USASpending. The amount reported for each prime grant includes cash and in-kind match value. 

Prime grantees reporting their subgrants into FSRS are not asked to report the non-federal share matching 

values for the subgrants they report.

During our March 21, 2019, webinar, we stated that matching amounts were reported and that these 

amounts included in-kind share. We regret that we did not explain that USASpending does not display 

the non-federal share amounts after a basic query. Instead, the non-federal share values are included when 

you download prime grant records from USASpending.

QUESTIONS REGARDING CNCS TRAINING AND TECHNICAL ASSISTANCE

22. How much training is available on this topic?

While robust resources exist on the USASpending.gov and FSRS websites, CNCS is in the early states of 

developing training content to assist our grantees. You can find our March 21, 2019, webinar at 

https://www.nationalservice.gov/documents/2019/webinar-usaspending-march-21-2019. We will broadly 

announce the availability of additional resources using our GovDelivery announcements.

23. Is there a way to keep informed on when the additional training is available?

Be sure to subscribe to our Grants and Financial Management Updates topic for GovDelivery bulletins; 

instructions for subscribing are at: 

https://public.govdelivery.com/accounts/USCNCS/subscriber/new?topic_id=USCNCS_160
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Acronyms & Abbreviations

CNCS Corporation for National and Community Service https://www.nationalservice.gov/

CFDA Catalog of Federal Domestic Assistance https://beta.sam.gov/

DATA Digital Accountability and Transparency Act https://www.grants.gov/learn-grants/grantpolicies/data-act-2014.html

FAQs Frequently Asked Questions

FFATA Federal Funding Accountability and Transparency Act or 

“Transparency Act”

https://www.grants.gov/learn-grants/grantpolicies/ffata-act-2006.html

FSRS FFATA Subaward Reporting System https://www.fsrs.gov/

GSA General Services Administration https://www.gsa.gov/

OMB Office of Management and Budget https://www.whitehouse.gov/omb/

SQL Structured Query Language

T&C Terms and Conditions (CNCS Grants)

https://www.nationalservice.gov/resources/financialmanagement/terms-conditions-and-certificationsassurances-cncs-grants