RGCI - The Federal Funding and Accountability Transparency Act Subaward Reporting System is Retiring in Early March 2025

The Federal Funding and Accountability Transparency Act (FFATA) requires prime contractors to report their first-tier subcontracts and grant recipients to report their first-tier subawards using the Federal Funding and Accountability Transparency Act Subaward Reporting System website.

The FFATA reporting requirement for prime contractors is in FAR 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, included in all solicitations and contracts that exceed $30,000. The FFATA reporting requirement for grant recipients is in 2 CFR 170, Reporting Subaward and Executive Compensation Information, and is required when the funding of a Federal award exceeds $30,000.

Beginning in early March 2025, the FFATA Subaward Reporting System (FSRS.Gov) is retiring, and contractors will be reporting their first-tier subcontracts and grantees reporting their first-tier subawards in the System of Award Management (SAM.Gov). General Services Administration (GSA) is making changes to streamline the process and reduce errors. We anticipate there will be a future update to both the FAR and 2 CFR to change the reporting from FSRS.Gov to SAM.Gov.

Who Does This Impact?

This change will impact the contractor/grantee employees who have user roles in FSRS.Gov. New user roles will need to be established in SAM.Gov for the employees who input the subcontract/subaward information.

While the conversion to SAM.Gov will begin in early March 2025, GSA has indicated there will be a blackout period of approximately one week while the changeover takes place. GSA states they will notify users but doesn’t indicate how they will be notified. As things in the government don’t always run smoothly, we recommend contractors/grantees maintain a list of subcontracts/subawards awarded during the blackout period. The timeframe for inputting the information has not been changed. Contractors/grantees are required to input the information by the end of the month after the award of the subcontract/subaward.

What About Executive Compensation?

The change did not specifically address obtaining executive compensation from subcontractors/subawardees. However, there is a requirement in SAM.Gov that all contractors input executive compensation as part of their registration unless they meet one of the exemptions.

Training and Materials

GSA stated that training and materials will be provided on registering user roles and inputting the first-tier information in SAM.Gov because the reporting process is different than FSRS.Gov. GSA hosted a training webinar in January 2025, and pre-recorded videos and knowledge articles will be available to users. There is also a GSA website to follow for updates.

Takeaways

We recommend contractors and grant recipients sign up for the training and obtain any instructional materials on registering their user roles and inputting the first-tier information in SAM.Gov sooner rather than later. There is less than a month before the conversion to SAM.Gov will take place. Prime contractors and Grantees should obtain a certification from the subcontractor/subawardee certifying that they have reported executive compensation or meet one of the exemptions in the regulations.

How Can Redstone GCI Help

Navigating regulatory changes like this can be complex, but you don’t have to do it alone. Redstone Government Consulting’s team of experts is here to help your organization stay compliant and minimize disruptions during the transition from FSRS.gov to SAM.gov. We offer training, consulting, and support to ensure your team is prepared to meet reporting requirements, establish proper user roles, and understand the new system processes. Contact us today to learn how we can support your compliance efforts.

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Written by Lynne Nalley, CPA

Lynne Nalley, CPA Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Employee & Contractor Compensation, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)