Federal Funding Accountability and Transparency Act (FFATA) Responsibilities

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Policy Code: 
4156
Approval Authority: 
Chancellor
Policy Type: 
University Policy
Policy Owner: 
Administration and Finance
Responsible Office: 
Administration and Finance - 828.251.6742

I. Purpose

The Federal Funding Accounting and Transparency Act (FFATA) requires all recipients of federal awards to report purchases of $25,000 and greater under federal contracts. The act requires the reported data be made available to the public via www.USASpending.gov.

II. Scope

These provisions apply to all University recipients of federal grants, contracts and awards.

III. Definitions

A. Recipient – University individual receiving and responsible for federal funding and reporting.

IV. Policy

The Office of Sponsored Scholarship and Programs, Grants/Endowment Accountant, and Purchasing Office will work together to ensure FFATA requirements are observed. To comply with FFATA requirements all vendors issued purchase orders or subcontracts subject to FFATA reporting must have a Duns and Bradstreet Universal Numbering System (DUNS #) and a valid System for Award Management (SAM) registration. The University of North Carolina at Asheville will not issue a contract or a purchase order until these requirements are met.

A. Responsibilities

  1. The Recipient is responsible for completing the UNC Asheville FFATA Purchasing Form and submitting it to the Office of Sponsored Scholarship and Programs. Without this form and supporting documents, the University will not generate a contract or purchase order against federal funding source.
  1. Office of Sponsored Scholarship and Programs is responsible for:

a. Determining if a pending contract is subject to FFATA reporting.
b. Confirming that the supplier has obtained a DUNS # and a valid SAM registration before submitting a requisition to Purchasing.
c. Forwarding the completed FFATA Requirements form and a confirming print out of the vendor’s valid SAM registration to Purchasing with the contract and purchase order.

  1. The Grants/Endowment Accountant has the overall responsibility to ensure compliance with FFATA reporting related to prime Federal grants and contracts. This individual is responsible for submitting required information to the Federal government through the FFATA Sub-award Reporting System (www.FSRS.gov) in accordance with established deadlines.
  1. The Purchasing Office is responsible for:

a. Reviewing and affirming that the SAM confirmation has been adequately completed  prior to generating a purchase order.
b. Adding purchase order data to the FFATA Purchasing Form and forwarding the completed form and copy of the SAM to the Grants/Endowment Accountant.

B. Procedures

  1. The Grants/Endowment Accountant issues an award notification to the Recipient, Office of Sponsored Scholarship and Programs, and Purchasing Office stating that FFATA reporting requirements apply.
  1. The Recipient initiates a FFATA Purchasing Form and prints the vendor’s valid registration from the SAM for all purchases of $25,000 or greater when FFATA reporting requirements apply to funding.

a. If the vendor does not have a valid SAM registration, the Recipient will notify the vendor of the FFATA registration requirement.
b. If the vendor is not willing to register an alternate vendor must be found.

  1. The Recipient will forward the FFATA Purchasing Form and SAM validation to the Office of Sponsored Scholarship.
  1. The Office of Sponsored Scholarship and Programs will:

a. Verify that all information is complete.
b. Generate a subcontract and purchase order request.
c. Copy materials for the contract record.
d. Forward all materials to the Grants/Endowment Accountant for verification.

  1. The Grants/Endowment Accountant will:

a. Verify that all information is complete.
b. When appropriate, obtain the appropriate signatures on the forms.
c. Send contracts and purchase order requests to Purchasing Office.
d. Prepare the FFATA reports and upload by the deadlines established by the federal government.

  1. The Purchasing Office will verify that the FFATA Purchasing Form, SAM validation and purchasing instruments contain all required data elements prior to processing a Purchase Order.

C. Instructions/Links

Dun & Bradstreet Universal Numbering System (DUNS #) is a unique identifier for business entities that receive federal assistance. To apply for a DUNS # go to www.dnb.com.

System for Award Management (SAM) is a registration system for entities that conduct business with the federal government.

  • To register with SAM go to http://www.sam.gov/portal/public/SAM/.
  • For certificate of valid SAM registration, select SAM Search and enter supplier’s DUNS #. Registration must be valid for at least two months after the anticipated purchase order encumbrance date. Confirmation consists of printing the registration page.

Federal Subaward Reporting System (FSRS) is the system used to report FFATA data. The Grants/Endowment Accountant has registered and will report for UNC Asheville. www.USAspending.gov is the public website that includes information on all Federal spending awards.

Associated Forms: