Filing the FFATA Subaward Report: SAM.gov Steps, Deadlines, and Pitfalls

The FFATA subaward reporting form is filed by prime federal grant and contract recipients through SAM.gov to disclose first-tier subawards of $30,000 or more in federal funds. Since March 2025, SAM.gov has replaced the retired FSRS.gov portal for this purpose. Each report is due by the last day of the month after the month the subaward was executed.

Who Has to File

The obligation sits with the prime awardee, meaning the entity that signed the grant agreement or contract directly with a federal agency. You report only first-tier subawards; anything flowing further down the chain is not your responsibility under FFATA.¹ Both grants and procurement contracts funded with federal money are covered.²

Several exemptions in 2 CFR Part 170 take prime recipients out of the reporting requirement:³

Prime recipients whose gross income in the previous tax year was under $300,000 are exempt from both subaward and executive compensation reporting.
Individuals who receive federal financial assistance as natural persons, not through a business or nonprofit, are excluded.
Awards where the total federal funding will not reach $30,000 do not carry the reporting term.
Technical assistance delivered as services rather than money, transfers of federally owned property, and classified awards fall outside FFATA reporting.

If a modification later raises a previously below-threshold subaward to $30,000 or more, you have to report it at that point.³

What to Gather Before You File

Most of what the form needs comes straight from the executed subaward agreement and the subrecipient’s SAM.gov entity record. Pull it together before you sign in.

The Unique Entity Identifier (UEI) for both the prime awardee and the subrecipient. The UEI is the 12-character identifier assigned through SAM.gov that replaced the old DUNS number. Subrecipients receiving only pass-through funding may need just a UEI rather than a full SAM.gov registration.⁴⁵
The subaward amount in federal funds, not any non-federal cost share.
The date the subaward was officially executed.
The place of performance, meaning the street address and congressional district where the subrecipient will do the work.
A concise project description of what the subrecipient will do with the funds.

Confirm the subrecipient’s UEI is active and that the legal name and address on its SAM.gov entity record match the subaward agreement. Mismatches between these records are among the data-quality issues auditors flag most often. Pull the details from SAM.gov’s entity search rather than from what the subrecipient wrote on an application months earlier.

When Executive Compensation Reporting Also Applies

Sometimes the form requires the names and total compensation of the subrecipient’s five highest-paid executives. That kicks in only when all three of these conditions were true for the subrecipient’s most recently completed fiscal year:³

The subrecipient received 80 percent or more of its annual gross revenues from federal contracts, subcontracts, grants, and subawards.
Those federal revenues totaled $25,000,000 or more.
The executives’ compensation is not already publicly available through SEC filings under the Securities Exchange Act of 1934 or through IRS Form 990 disclosures under Internal Revenue Code section 6104.

All three have to be met. If the subrecipient files publicly with the SEC or makes its Form 990 available, the third condition fails and you skip the compensation section.⁶ Total compensation includes salary, bonuses, stock options, and other fringe benefits. In practice, most subrecipients either fall below the $25 million threshold or already file publicly, so this section applies to a small share of subawards.

Submitting the Form Through SAM.gov

All subaward reporting has run through SAM.gov since March 2025, and FSRS.gov is retired. If you had an FSRS.gov account, connect it by signing in with your legacy FSRS username and password, verifying your entity name and UEI, and confirming your reporting role under My Roles in your SAM.gov Workspace.⁷

If you never had an FSRS account, you need a Data Entry role for entity reporting inside SAM.gov. Request it through your Workspace, and note in the comment that you need the subaward reporting permission.⁷

Once you have access, the workflow is:

Locate the prime contract or grant tied to the subaward.
Create a new subaward report. The system pulls existing data from the prime award; you enter the subrecipient UEI, subaward amount, date, place of performance, and project description.
Review every field on the summary screen, submit, and save the confirmation for your compliance records.

Submitted data flows to USASpending.gov, where anyone can search federal spending down to individual subawards.¹

When the Report Is Due

Each subaward report is due by the last day of the month following the month the subaward was made. A subaward executed on November 7 has to be reported by December 31.⁸ Organizations that issue several subawards in a month often build a recurring reconciliation into monthly close so the deadline doesn’t sneak up.

Common Mistakes That Trigger Audit Findings

FFATA reporting deficiencies are among the most frequently cited findings in federal single audits. Auditors compare what sits on USASpending.gov against your executed subaward agreements and look for four recurring problems:

A qualifying subaward that was issued and never reported at all.
A subaward reported after the end-of-month deadline.
A dollar figure that does not match the executed agreement, often because a modification was processed but the report was never updated.
Blank or incorrect entries in required fields like place of performance, project description, or UEI.

A quarterly comparison of your internal subaward records against USASpending.gov catches most of these before an auditor does. If something is missing or the amounts don’t match, correct the report in SAM.gov promptly. FFATA compliance is a legally binding term built into the Notice of Award, and repeated findings can lead to special conditions on future grants.⁹ Some agencies run their own quarterly compliance checks, which is another reason to review proactively.¹⁰

1
U.S. Election Assistance Commission. FFATA
2
BroadbandUSA. Federal Funding Accountability and Transparency Act (FFATA) for Grants
3
eCFR. 2 CFR Part 170 – Reporting Subaward and Executive Compensation Information
4
U.S. Environmental Protection Agency. Federal Funding Accountability and Transparency Act
5
SAM.gov. Entity Registration
6
Legal Information Institute. 2 CFR Appendix A to Subpart C of Part 170 – Award Term
7
SAM.gov. Subaward Reporting in SAM.gov
8
Office on Violence Against Women. Award Condition: Reporting Subawards and Executive Compensation
9
Health Resources & Services Administration. Requirements for Federal Funding Accountability and Transparency Act Implementation
10
Health Resources & Services Administration. Federal Funding Accountability and Transparency Act (FFATA) Frequently Asked Questions