GSA
OMB Control No: 3090-0291
Justification Part A—Supporting Statement
Overview of Information Collection:
This is a request for approval of an extension to an existing information collection.
This information collection requires information necessary for prime awardee registration into the FFATA Subaward Reporting System (“FSRS”) and review of its entity-related information. This information collection is necessary to allow for prime awardee reporting of subaward and executive compensation data pursuant to the Act.
Circumstances Making the Collection of Information Necessary
The Federal Funding Accountability and Transparency Act (FFATA), “Transparency Act,” requires information disclosure of entities receiving Federal financial assistance through Federal awards such as Federal contracts, sub-contracts, grants, and sub-grants, FFATA § 2(a)(2)(i), (ii).
Specifically, the Transparency Act’s section 2(b)(1) requires the Office of Management and Budget (“OMB”) to ensure the establishment of a publicly available website that contains the following information about each Federal award:
name of the entity receiving the award;
amount of the award;
information on the award including transaction type, funding agency, the North American Industry Classification System code or Assistance Listings number, program source, award title descriptive of the purpose of each funding action;
location of the entity receiving the award and primary location of performance under the award, including city, State, congressional district, and country;
unique identifier of the entity receiving the award and the parent entity of the recipient, should the entity be owned by another entity; and
names and total compensation of the five most highly compensated officers of the entity if the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal contracts (and subcontracts), loans, grants (and subgrants), cooperative agreements, and other forms of Federal financial assistance; and $25,000,000 or more in annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants), cooperative agreements, and other forms of Federal financial assistance; and the public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See 2 CFR Part 170 for a full reading of the regulations. (To determine if the public has access to the compensation information, see the U.S. Security and Exchange Commission total compensation filings at http://www.sec.gov/answers/execomp.htm
Beginning October 1, 2010, this Paperwork Reduction Act submission directs compliance with the Transparency Act to report prime and first-tier subaward data. Specifically, Federal agencies and prime awardees of contracts and grants will ensure disclosure of executive compensation of both prime and sub awardees and sub award data. This information collection requires reporting of only the information enumerated under the Transparency Act.
Purpose and Use of Information Collection
The information collected will be used to allow prime grant recipients to register and report information about executive compensation (if applicable) for Grants prime and subawardees and subaward information, pursuant to the Transparency Act. While some information is currently publicly available on prime awardees, executive compensation of prime awardees and subawardees, as applicable, is not. In addition, this information collection will provide public access to information on grant subaward information, pursuant to the Transparency Act.
What grants are subject to reporting pursuant to the Transparency Act?
New Federal, non-Recovery Act funded grant awards with an award date on or after October 1, 2010, and resulting first-tier subawards, are subject to the reporting requirements under the Transparency Act. New Federal grants includes grants with a new Federal Award Identification Number (FAIN) as of October 1, 2010 and does not include continuing grants awarded in prior fiscal years with new obligations beginning October 1, 2010.
For those new Federal grants as of October 1, 2010, if the initial award is over $30,000, reporting of sub award data is required. If the initial award is below $30,000 but subsequent funding results in a total award equal to or over $30,000, the award will be- subject to FFATA reporting requirements, as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently deobligated such that the total award amount falls below $30,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Paperwork Reduction Act submission.
In addition to the award amount threshold, pursuant to the Transparency Act, Federal grant awards to individual recipients, Federal grant awards made to entities earning less than $300,000 in Federal benefits in the previous tax year, and classified information are not subject to the reporting requirements in this Paperwork Reduction Act submission, FFATA §§ 2(a)(1)(C), 2(e), 5.
Who will be required to register into FSRS to report information pursuant to the Transparency Act?
Prime awardees of Federal grants will be responsible for reporting under the Transparency Act.
What information is required to register into FSRS?
This information collection requests approval of the information needed to properly register an entity in FSRS to facilitate the statutorily required reporting of Transparency Act information. In order to facilitate proper registration, an entity may be required to provide information to include:
Unique Entity Identifier (UEI)
Legal Business Name
Physical Address
Parent Unique Entity Identifier (UEI)
Federal Award Identification Number (FAIN)
Assistance Listing (AL) Number
Federal Awarding Agency of the Grant
If a prime awardee has already registered in the system to report contracts-related Transparency Act financial data, a new log-in will not be required. The system will identify the prime awardee’s grants for reporting purposes based on the registration information provided.
In addition, the prime awardee will be responsible for verifying the accuracy of pre-populated information about itself (e.g., name, address, UEI, Parent UEI. Because the Federal Government has a majority of this information already through the prime awardee’s prior registration in the System for Award Management (SAM) the prime awardee will not be required to provide this information again. See attached data elements spreadsheet for a detailed description of data elements and source of pre-population. Where most of this information will be pre-populated, however, the prime awardee will be responsible for reviewing this information for accuracy.
It is intended that, to the maximum extent possible, information already collected from Federal agencies on Federal grants and prime awardees will be pre-populated to minimize duplicative reporting of the prime awardees’ entity information (e.g., address, UEI) and grant information (e.g. AL number, award amount, prime award description).
By when will the prime awardee need to register into FSRS and be responsible for reporting under the Transparency Act?
The prime awardee will be responsible for reporting information about itself, as needed, or its subawardee, if any, by the end of the month following the month the award or obligation was made.
For subaward reporting:
If applicable, the prime awardee must report subawardee data by the end of the month following the month the award or obligation was made.
Example 1:
Prime recipient awards subaward on October 1, 2023
Prime recipient must report subaward information by November 30, 2023
Example 2:
Prime recipient awards subaward on October 31, 2023
Prime recipient must report subaward information by November 30, 2023
For executive compensation reporting:
If applicable, the prime awardee must report its own executive compensation data by the end of the month following the month the award or obligation was made.
Example 1:
Federal agency awards grant to prime awardee on October 1, 2023
Prime awardee must report executive compensation data, if necessary, by November 30, 2023
Example 2:
Federal agency awards grant to prime awardee on October 31, 2023
Prime awardee must report executive compensation data, if necessary, by November 30,
2023
Similarly, the prime awardee must report the subawardee’s executive compensation data by the end of the month following the month the award or obligation was made.
Example 1:
Prime recipient awards subaward on October 1, 2023
Prime recipient must report subawardee’s executive compensation data, if necessary, by November 30, 2023
Example 2:
Prime recipient awards subaward on October 31, 2023
Prime recipient must report subawardee’s executive compensation data, if necessary, by November 30, 2023
Use of Information Technology.
This collection of information will be electronic. The FFATA Sub award Reporting System (FSRS) is accessed at http://www.fsrs.gov. The prime awardee will be allowed to report information about itself, as needed, and its subawardees, if applicable, by specific grant, or through a batch uploading mechanism. The system will allow a prime awardee to save its reporting for further review or addition, or report immediately. Providing such flexibility, in both the form of reporting (individual and batch uploading capabilities) and in timing will ensure that the burden is minimized to the maximum extent possible.
Further, as discussed above, it is intended that to the maximum extent possible, information already collected from Federal agencies on Federal grants and prime awardees will be pre-populated to minimize duplicative reporting of the prime awardees’ entity information (e.g., address, UEI) and grant information (e.g., program number, award amount, prime award description).
Efforts to Identify Duplication and Use of Similar Information.
As discussed above, it is intended that to the maximum extent possible, information already collected from Federal agencies on Federal grants and prime awardees will be pre-populated to minimize duplicative reporting of the prime awardees’ entity information (e.g., address, UEI) and grant information (e.g., AL number, award amount, prime award description).
Impacts on Small businesses or Other Small Entities.
As discussed above, it is intended that to the maximum extent possible, information already collected from Federal agencies on Federal grants and prime awardees will be pre-populated to minimize duplicative reporting of the prime awardees’ entity information (e.g., address, UEI) and grant information (e.g., AL number, award amount, prime award description).
Consequences of Collecting the Information Less Frequently.
The collection of this information complies with P.L. 109-282 requiring the statutorily required reporting of information on: (1) executive compensation of applicable grants prime and subawardees and (2) other grants award-related information about grants subawardees accessible to the public, thus making Government more transparent. See attached data elements spreadsheet for full list of data elements.
Paperwork Reduction Act Guidelines.
Respondents will be submitting information electronically at www.fsrs.gov. Prime recipients will be required to report its own executive compensation data, if needed pursuant to the Transparency Act, by the end of the month of the prime award’s obligation from the Federal Government to the prime awardee, plus an additional 30 days. The same timeframe is applied for a prime awardee’s reporting of subaward information, if a subaward is obligated. The frequency of this reporting is specifically required by the Transparency Act. FFATA § 2(c)(4) (“The website established under this section shall be updated not later than 30 days after the award of any Federal award requiring a posting.”)
Respondents will not be required to keep records for more than three years. The information collection is not connected with a statistical survey, is not connected with the use of statistical data classification, and does not request data that is confidential.
Consultation and Public Comments.
A 60-day notice published in the Federal Register at 89 FR 14842 on February 29, 2024. One paper with multiple comments was received. A 30-day notice published in the Federal Register at 89 FR 47561 on June 3, 2024.
Comment: GSA received a comment on whether the GSA’s estimate of the public burden of this collection of information is accurate.
Response: This information collection is specific to the burden of reporting entities registering to report in FSRS, not the actual subaward reporting. The burden of this registration activity is reasonable for the activity of registering in FSRS..
Comment: GSA received a comment on ways to enhance the quality, utility, and clarity of the information to be collected to aid pass-through entities (PTEs) in submitting reliable, high-quality data in FSRS. The comment provided suggestions on 1) improving FSRS FAQs by including screenshot and step-by-step instructions for questions with complex answers, 2) explain how to resolve “Another contractor is already designated as the prime contractor for this contract.” error and 3) provide dedicated technical support solely for FSRS and train support staff thoroughly on the FSRS system.
Response: FSRS and the Federal Service Desk have significant help materials and guides to assist users with reporting data into FSRS.gov. The Federal Service Desk has agents that can assist entities where they are unable to answer their question within the help content. GSA appreciates feedback on usability and user experience and considers it when making updates to the respective service or page so as to improve the site user experience.
Comment: GSA received a comment asking what are ways to minimize the burden of the collection of information.
Response: This information collection is specific to the burden of reporting entities registering to report in FSRS, not the actual subaward reporting. 2 CFR Part 170 provides the regulatory guidance associated with reporting subawards that are input into FSRS.
Explanation of any payment or gift to respondents, other than remuneration of
Awardees.
No payment or gifts to respondents will be provided.
Privacy & Confidentiality.
The information requested is specifically enumerated under the Transparency Act and is required by the Act to be released to the public.
Justification for questions of a sensitive nature.
Information of a sensitive nature is not requested.
Estimated total annual public hours and cost burden.
On an annual basis, approximately 2,488 new awardee users will register in FSRS. The burden hours associated with each information submission is 0.5 hours. This is based on the assumption all prime grant awardees are registered in SAM. Prime grant awardees will only be required to manually input a minimal amount of information. The burden hours are calculated as follows:
Total Burden:
2,488 New Awardee Users x 0.5 hours = 1,244 burden hours.
GSA will continue to review and revise these burden estimates as more information becomes available.
Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
The registration cost estimates are computed using the equivalent of hourly rates for a GS 11/1. These hourly rates are comparable to salaries of staff that will perform these functions for the respondent. The time required for data entry and review is estimated at 0.5 hrs. per registration. Using the Office of Personnel Management‘s January 2023 Salary Table, the hourly rate for a GS 11/1 is $37.66. Therefore, the cost for one new awardee is as follows:
Data Entry (GS 11/1 equiv.) hourly rate of $37.66 x .5 hr. = $18.83
36.35% overhead $6.84
Total Cost, One Registration $25.67
Summary (FY23)
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Registrations |
Hours/Response |
Total |
Total Cost |
Cost Calculation |
Hours |
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New Awardees |
2,488 |
0.5 hr./response |
1,244 |
$31,933.48 |
$25.67/registration x 1,244 hours |
The estimated total annual cost burden is $25.67 x 1,244 total hours = $31,933.48. The estimated cost per response is $25.67.
GSA has provided its best estimates based on available information. GSA will continue to review and revise these burden estimates as more information becomes available.
Estimated annual cost to the Federal Government.
The cost associated with collecting FSRS registrations is part of operating and maintaining the FSRS system as a whole, as well as any training and assisting of federal and nonfederal users to complete reports. The annualized cost of these efforts is approximately $670,189. This figure was determined through task order obligations related to operation and maintenance of FSRS.
Explanation for Program Changes or Adjustments.
There was a significant decrease in the number of registrations compared to the last information collection. There is no definitive reason for this, the number of subawards have stayed flat. One possibility could be most awardees are already registered.
Publicizing results.
The information collected will be published on USASpending.gov. Information will be provided free to the public.
Reasons Display of OMB Expiration Date is Inappropriate.
Such approval is not being requested.
Explanation of exception to certification statement.
There are no exceptions to the certifications.
B. Collections of Information Employing Statistical Methods.
Statistical methods are not used in this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | PriscillaOwens |
| File Modified | 0000-00-00 |
| File Created | 2024-07-22 |