FFATA Reporting Requirements: Thresholds, Deadlines, and Penalties

If your organization holds a federal grant, cooperative agreement, or procurement contract and passes any of that money to another organization, FFATA reporting requirements make you responsible for reporting each first-tier subaward of $30,000 or more. Reports go into SAM.gov and are due by the end of the month after the month you obligated the subaward. The data feeds USASpending.gov, and missing reports can cost you far more than the time it would have taken to file them.1Government Publishing Office. Public Law 109-282 – Federal Funding Accountability and Transparency Act of 2006

Who Has to File

The reporting burden sits with the prime recipient, the organization that receives funding directly from a federal agency. When a prime recipient passes federal money to a subrecipient or subcontractor to carry out part of the work, the prime files the report. The subrecipient does not file its own FFATA report.2eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information

Both grants and contracts are covered. Grants follow 2 CFR Part 170; procurement contracts follow FAR clause 52.204-10. The practical obligations are nearly identical, so a university subawarding research funds and a defense contractor subcontracting work face the same monthly rhythm.3Acquisition.GOV. 48 CFR 52.204-10 – Reporting Executive Compensation and First-Tier Subcontract Awards

When a Subaward Triggers a Report

A report is required for each subaward action that obligates $30,000 or more in federal funds. If the initial subaward is below $30,000, no report is due at that point. But if a later modification pushes the cumulative subaward to $30,000 or above, reporting kicks in as of the date the subaward crosses that line.4U.S. Election Assistance Commission. FFATA

A modification to an existing subaward is itself separately reportable when the modification increases the total by $30,000 or more.2eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information

Who’s Exempt

Three exemptions matter. First, if your organization reported gross income under $300,000 from all sources in the previous tax year, you are exempt from FFATA reporting entirely, including both subawards and executive compensation. Second, FFATA does not apply to individuals who receive federal financial assistance as natural persons, such as someone receiving a fellowship or scholarship unrelated to a business or nonprofit they operate. Third, subawards that stay below the $30,000 threshold do not require a report.2eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information

What Data You Have to Report

For each reportable subaward, the prime recipient collects and enters several categories of information:

  • Subrecipient identification, including the subrecipient’s name, Unique Entity Identifier (UEI), and parent entity UEI if the subrecipient is owned by another organization.
  • Award details, meaning the dollar amount of the subaward, the date of the obligation, and a description of the project or purpose.
  • Location data for the primary place of performance: city, state, zip code with the four-digit extension, congressional district, and country.
  • The funding source identifier, which is the CFDA number for grants or the NAICS code for contracts.

Getting the congressional district right matters because agencies use this field to map spending, and it is driven by the actual place-of-performance address rather than a headquarters address.1Government Publishing Office. Public Law 109-282 – Federal Funding Accountability and Transparency Act of 2006

Every organization involved in a federal award needs a UEI, the 12-character alphanumeric code assigned through SAM.gov. Prime recipients maintain full SAM.gov registrations, renewed annually. Subrecipients whose only interaction with the federal system is receiving a subaward may only need a UEI without completing full registration.5SAM.gov. Entity Registration

Collect the UEI before the subaward is executed. Without a valid UEI, you cannot complete the FFATA report for that subaward. If a subrecipient has not yet been assigned a UEI when the reporting deadline arrives, omit it from the current month’s report and add it retroactively once the identifier is issued.

When Executive Compensation Has to Be Disclosed

FFATA also requires disclosure of the names and total compensation of the five highest-paid executives at both the prime recipient and any reportable subrecipient, but only when all three of the following conditions are met for that entity:

  • The organization received 80 percent or more of its annual gross revenue from federal awards in the preceding fiscal year.
  • That federal revenue totaled $25,000,000 or more.
  • The compensation data is not already publicly available through SEC filings or IRS Form 990 disclosures.

If any one condition is not met, the executive compensation disclosure does not apply to that entity. Most smaller nonprofits and universities will not hit all three triggers.2eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information

Where to File

Subaward reports are filed through SAM.gov. The previous standalone system, FSRS.gov, was retired on March 8, 2025, and all reporting functionality moved into SAM.gov.6SAM.gov. Subaward Reporting in SAM

The person filing needs a SAM.gov account with the Data Entry role and subaward reporting permissions for the entity. Organizations that previously used FSRS.gov accounts can link those credentials to SAM.gov through a one-time migration. Once logged in, locate the prime award, enter the subaward data for each reportable first-tier subaward, and submit. The data then flows to USASpending.gov, where it becomes publicly searchable alongside the prime award.4U.S. Election Assistance Commission. FFATA

The Filing Deadline

Each subaward report is due by the end of the month following the month in which the obligation was made. A subaward obligated any day in October must be reported by November 30. An obligation made on July 3 must be reported by August 31.2eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information

Each month’s report should cover only the subawards obligated during the prior month. Filing cumulative reports that include previously reported subawards creates duplicate entries. SAM.gov does not automatically flag duplicates, so the prime recipient is responsible for making sure each subaward appears only once.

What Happens If You Don’t Report

FFATA reporting failures do not carry a single statutory fine, but the practical consequences are serious. Federal agencies can impose specific award conditions to correct the compliance gap, which adds administrative overhead and scrutiny to everything the recipient does. Late or missing reports can trigger single audit findings and corrective action plans. Agencies can also record adverse information in the Federal Awardee Performance and Integrity Information System (FAPIIS), which other agencies review when evaluating future award applications. A poor FAPIIS record can effectively shut an organization out of new federal funding.

In the most severe cases, an awarding agency can move toward early termination of the grant or contract and require a return of funds. Treating FFATA as optional paperwork can jeopardize not just the current award but the organization’s ability to compete for future federal dollars.

Records You Have to Keep

Recipients and subrecipients must retain all records supporting their FFATA reports for at least three years from the date the final financial report is submitted. For awards with quarterly or annual financial reporting, the clock starts from the submission of each such report. If litigation, an audit, or a claim involving those records begins before the three-year period expires, the records must be kept until the matter is fully resolved.7eCFR. 2 CFR 200.334 – Record Retention Requirements

In practice, hold onto subaward agreements, obligation dates, UEI documentation, place-of-performance records, and any executive compensation data collected from subrecipients. Auditors will trace reported figures back to source documents.

Mistakes to Avoid

  • Filing cumulative reports instead of monthly ones. Each report should cover only subawards obligated in the prior month. Running totals create duplicates that are hard to unwind.
  • Entering a five-digit zip code without the four-digit extension. The system expects the full zip+4 for the place of performance.
  • Trying to fix a de-obligation with a negative dollar amount. You cannot reduce a previously reported subaward by filing an offset. Corrections have to be made by editing the original submitted report.
  • Losing reporting continuity when staff leave. SAM.gov reporting access does not automatically transfer. Past reports need to be migrated to a new staff member’s account, and someone has to request the appropriate role before the next deadline.
  • Submitting a report with a subrecipient that has no UEI yet. Omit that subrecipient from the current report and add it once the identifier is assigned. Do not leave the field blank.

Build FFATA compliance into your subaward workflow from the start. Collect UEIs and place-of-performance data before executing the agreement, and the monthly filing becomes a short administrative task rather than a scramble.