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Reporting Requirements for Annual Financial Reports of State Agencies and Universities

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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 to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).

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 2023 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.

FFATA requires each state agency or institution to report federal award pass-throughs equal to or greater than $30,000 in FSRS 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 FSRS 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 in FSRS. 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 FSRS 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 retroactively report all of its prior fiscal 2023 months’ subaward activity (Sept. 1, 2022 – July 31, 2023) in FSRS by Aug. 31. FSRS provides Excel templates for batch upload reporting. Registered and logged-in FSRS users can find instructions, templates and additional details under File/Review Reports > Batch Upload Reports on the FSRS website’s main menu. This information assists with retroactively reporting fiscal 2023 prior months. Any of the templates can be uploaded directly into FSRS by the prime awardee.

Activity for July and August 2023 will be reported on the typical monthly schedule (30 days from the end of the previous month).

Failure to meet these 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 FSRS?
  • Did the prime awardee receive a federal grant of at least $30,000?
    • No: The prime awardee does not have to complete entry in FSRS for that federal award identification number.
    • Yes: Proceed to question 2.
  • Did the prime awardee award federal funds to another party of at least $30,000?
    • No: The prime awardee does not have to complete entry in FSRS for that federal award identification number.
    • Yes: The prime awardee must report the sub-award in FSRS.  

If you have questions regarding the FFATA or reporting in FSRS, see FSRS’ FAQs page or email sefa.texas@cpa.texas.gov.