Reporting Requirements for Annual Financial Reports of State Agencies and Universities
Pass-Through Activity
Federal Funded Loans/Grants
Federal Funding Accountability and Transparency Act
The Federal Funding Accountability and Transparency Act (FFATA), Public Law Number 109-282, as amended by Section 6202 of Public Law Number 110-252, requires federal prime awardees of grants or cooperative agreements to report first-tier subawards of $30,000 or more in Subaward Reporting in SAM.gov. These subawards were previously reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As of March 8, 2025, the FSRS.gov website was retired, and all subaward reporting data and functionality are now on SAM.gov.
A prime awardee or a sub-awardee are both subject to audit. When the reporting compliance requirement is marked with a Y indicator in the Part 2 Matrix of the Current Year Compliance Supplement, the program is subject to audit. If the auditor determines that the first-tier awards are direct and material, auditors test the compliance with the reporting requirements of the Code of Federal Regulations (CFR) Title 2, Part 170.
Note: The Comptroller’s office recommends agencies view the FSRS to SAM Overview video for a quick tutorial.
FFATA requires each state agency or institution to report federal award pass-throughs equal to or greater than $30,000 on a monthly and timely basis. It is the prime awardees responsibility to report all federal pass-throughs equal to or greater than $30,000 in Subaward Reporting in SAM.gov to support the reporting in SEFA. Sub-awardees cannot report on behalf of the prime awardee. A pass-through recipient must provide the required information to the prime awardee to facilitate timely submission. The deadline for each month is 30 days from the end of previous month. For example, reporting for the month of July is due in Subaward Reporting in SAM.gov by Aug. 31.
To comply with the FFATA requirements and the uniform guidance in CFR (Title 2, Part 200), each state agency and institution must report all of its subaward activity in Subaward Reporting in SAM.gov by Aug. 31 each fiscal year. The SAM.gov website includes access, bulk upload trainings, and how-to videos for users to reference.
Activity for July and August will be reported on the typical monthly schedule (30 days from the end of the previous month).
Failure to meet FFATA reporting requirements may result in an audit finding in the preparation of the State of Texas Annual Comprehensive Financial Report (ACFR). Such findings are reported in the State of Texas Federal Portion of the Statewide Single Audit Report.
The Comptroller’s office intends to develop and enhance the SEFA web application for future fiscal year reporting to enable agencies to voluntarily share data for FFATA reporting.
When do prime awardees need to report federal subawards in the SAM.gov website?
- Did the prime awardee receive federal grant funds greater than or equal to $30,000?
- No: The prime awardee does not have to complete entry for that federal award identification number.
- Yes: Proceed to question 2.
- Did the prime awardee award federal funds to another party greater than or equal to $30,000?
- No: The prime awardee does not have to complete entry for that federal award identification number.
- Yes: The prime awardee must report the sub-award.
Note: If the initial award is below $30,000, but subsequent grant modifications result in a total award equal to or over $30,000, the award is subject to the reporting requirements as of the date it exceeds $30,000.
If the initial award equals or exceeds $30,000, but funding is subsequently deobligated, bringing the total award amount below $30,000, the award continues to be subject to the reporting requirements of the transparency act.
If you have questions regarding FFATA or Subaward Reporting in SAM.gov, email subawardreporting@gsa.gov or sefa.texas@cpa.texas.gov.