FFATA Subaward Reporting System (FSRS)

FAR 204-10 requires the prime contractor to report 1) First-tier subcontract awards valued at $25,000 and 2) the names and total compensation of each of the five most highly compensated executives for both the prime and their first tier subcontractors.

On July 8, 2010 the Federal Acquisition Regulation (FAR) was changed to incorporate the clause, FAR 52.204-10, entitled "Reporting Executive Compensation and First-Tier Subcontract Awards" for all prime contract awards valued at $25,000 or more. The clause complies with the Federal Funding Accountability and Transparency Act (FFATA). FAR 52.204-10 requires the contractor to report the appropriate information through a DoD system called FFATA Subaward Reporting System (FSRS). The reports are due by the end of the month following the month of the subaward. The names and total compensation of each of the five most highly compensated executives are due by the end of the month following the month of the award as well as annually thereafter. The information reported will be made public IAW the Federal Funding Accountability and Transparency Act (FFATA). Upon submission by the prime contractor, the collected information submitted is automatically made available to the public via a single, searchable website, at www.USASpending.gov.

Contractors will be required to submit reports effective as listed below:

1. Effective immediately upon the clause being included in contracts, prime contractors will be required to report all newly awarded subcontracts valued at $25,000 or more where the prime contract award amount is $20M or more.
2. Effective Oct 1, 2010, upon the clause being included in contracts, prime contractors will be required to report all newly awarded subcontracts valued at $25,000 or more where the prime contract award amount is valued at $550K or more.
3. Effective March 1, 2011, upon the clause being included in contracts, prime contractors will be required to report all newly awarded subcontracts valued at $25,000 or more where the prime contract award amount is valued at $25K or more.

Note: Although the requirement to report subawards is being phased-in at certain dollar levels, reporting is permitted prior to the required start date.

The FSRS website can be found at www.FSRS.gov. This website provides training such as a user guide, Contractor demonstration video and Frequently Asked Questions. This site is also appropriate to register for access to FSRS and ultimately where the reports are submitted. The Federal Subcontract Reporting System (FSRS) is different than the electronic subcontracting system (eSRS). FSRS is a component of eSRS. These systems are independent of each other; although they are similar in function and appearance and provide the capability to access each other from within either system. Contractors that submit reports in eSRS are still required to report in FSRS. If you have already registered your company in eSRS you will need to register in FSRS. You may use the same username/password for either system.

If you have not already registered your company in eSRS you can register in FSRS as follows:

• Go to http://www.esrs.gov. Click on "Contractor".
• Under "New Users" heading, click on the "Register" button
• Enter your company's DUNS number (make sure it is the DUNS number that is identified on the referenced contract). Do not include any dashes when entering your DUNS number. For security purposes, the password must meet the following criteria:
  • Must be between 10 and 14 characters
  • Must contain 2 of each of the following: lower case letter, upper case letter, number, special character (i.e., !, %,^)
• If all is correct, make sure to select the "Submit" button.
• You are not quite finished. You will receive an e-mail indicating that your application for an account has been received and requesting your verification. You will need to click on the link provided in order for the registration process to continue.
• Upon approval a second e-mail will notify you that you have been approved. At this point you are finished with the registration and you can proceed to the "FSRS Sign-In" screen
• Proceed to the "FSRS Sign-In" screen.

Although The Contracting Officer is responsible to "review" the information provided, there is no official "approval" needed by the Federal Government . Upon submission by the prime contractor, the collected information submitted is automatically made available to the public via a single, searchable website, which is www.USASpending.gov.

FAR 52.204-10 as identifies various exemptions to reporting "First-tier subcontracts". Some of the exemptions include:

• a) Prime Contracts valued at below $25K are exempt.
• b) "First-tier subcontract" excludes supplier agreements with vendors, such as long-term arrangements for materials or supplies that would normally be applied to a Contractor's G&A expenses or indirect cost.
• c) Gross Income - A company is exempted from reporting if in the previous tax year the company had a gross income, from all sources, under $300,000.

he contractor and their first tier subcontractor shall report the names and total compensation of each of the five most highly compensated executives for the Contractor's preceding completed fiscal year if they receive $25M or more in annual gross revenues AND this accounts for 80% or more of its annual gross revenues.

• A company is exempted from this reporting requirement if the public does 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. To determine if the public has access to the compensation information, see the U.S. Security and Exchange Commission total compensation filings at www.sec.gov/answers/execomp.htm.

The FSRS website (www.FSRS.gov) provides training such as a user guide, Contractor demonstration video and Frequently Asked Questions. This site is also appropriate to register for access to FSRS and ultimately where the reports are submitted. The Contractor demonstration video details the various blocks that the contractor will see as they complete the report in FSRS.

1. Log on to the FSRS website at www.FSRS.gov and click on "Contractor" button. 
   Note: You can also log onto www.eSRS.gov and click on "Contractor" button but you will need to use the toggle button on the top to switch to FSRS.
2. Type in your login and password.
3. The Home Page will give you 2 main options: 
    
   • a. "Add Contract to WorkList" – This button is a little misleading because Contractors will not be able to add a contract that has not already been entered into the Federal Procurement Data System Next Generation (FPDS-NG) by the Contracting Officer. However, one useful application of this button is to verify whether the contract and/or delivery order number being used by the contractor is already loaded in FPDS-NG. If it is already loaded then it will indicate under "Search Results" that the contract has already been added to your work list. It will ask you to click "cancel" to return to your contract work list.

      

     • Note: If the award action that you need to report on is a contract where delivery/task orders are issued then you will need to indicate that 1) this is a Task Order and 2) Enter the Prime Contract number and the Referenced Individual Delivery Vehicle (IDV) number. In some cases you may need to reverse the numbers. For example: If the Contract number is HDEC04-09-D-XXXX, and the Delivery Order number is 0043 then the information would be entered as follows:
     
     
     • Prime Contract #: 0043
     • Referenced IDV #: HDEC04-09-D-XXXX
   
   
   • b. "File FFATA Report" – This is the button you will need to use to create your subcontract report. You will need to enter the appropriate contract/delivery order as explained above. Upon accessing the proper award document there will be some information that is pre-populated and the remainder will need to be completed by the prime contractor as follows:

PRE-POPULATED INFORMATION

The following information should be pre-populated and not require contractor submission. However, if any of this pre-populated information is incorrect then contractor will need to bring this up to the attention of the Contracting Officer in order to properly submit the report. The Contracting Officer will need to adjust the information in FPDS-NG prior to contractor submission of the FSRS report.

NON PRE-POPULATED INFORMATION

The following information may require contractor to provide information in the report. Please contact the Contracting Officer if you are unclear as to what information is being required.

1. Prime Contract Number: Pre-populated
2. Delivery /Order Number: Pre-populated
3. Contracting Office Agency ID: Pre-populated with "97AZ"
4. Contracting Office Agency Name: Pre-populated with "Defense Commissary Agency".
5. Contracting Office ID: Pre-populated with the Agency office ID (For example: HDEC0X. This ID is typically the same first 6 characters of the contract number).
6. Contracting Office Name: Pre-populated same as block 4.
7. Funding Agency ID: Pre-populated (Typically with 97AZ which is associated with DeCA)
8. Funding Agency Name: Pre-populated
9. Funding Office ID: Pre-populated same as block 7.
10. Funding Office Name: Pre-populated same as block 8.
11. DUNS #: It is very important to ensure that the DUNS listed in this report matches that listed on contract. FSRS will pull the appropriate company information from the System for Award Management(SAM) database and pre-populate most of the fields on the screen.
12. Vendor Name: Pre-populated with same vendor name as shown on award.
13. Doing Business As: If applicable, Pre-populated with same vendor name as shown on award.
14. Organization/Business Types: Pre-populated with CCR info
15. Vendor Physical Address: Pre-populated with info listed on award
16. Parent DUNS of Vendor: Pre-populated with CCR info
17. Parent Vendor Name: Pre-populated from name of block 16 info.
18. Principle Place of Performance: Should pre-populate most of the information. Sometimes the "City" may not show up. Contractor may need to complete this to ensure report can be submitted.
19. Treasury Account Symbol (TAS): If this is not already pre-populated, the contractor will be required to provide the predominant TAS to complete this field. The TAS is a 6 character number but there may be an additional optional 3 characters that can be added. Unless there is a period (.) after the first 6 digits it should be left alone. The TAS is typically included in the accounting line code of the award. There are 3 boxes for reporting the TAS. The first 2 digits (1st box) represent the Agency Identifier (This will typically be '97' to represent DoD. The next 4 characters (2nd box) represents the "Main Account Code". The 3rd box represents an optional 3 character Subaccount Code.
    • Note: The information will be rejection if the TAS does not match the codes that are identified in the Department of Treasury's Federal Account Symbol and Titles Source list in Part II (available at www.fms.treas.gov/fastbook/index.html ). A couple of TAS examples specific to our agency are as follows: 
      • Example 1: 97X4930.004 – DeCA Working Capital Funds
      • TAS: 97 4930 004
      • 2 characters: Agency Identifier (i.e. 97)
      • 4 characters; Main Account Code (i.e. 4930)
      • 3 optional characters; Subaccount Code (i.e. 004)
    • Note: Please note that the "X" is not included in the TAS. Also, it is not required to include the optional 3 character subaccount code. Therefore in this example, the contractor may include 97 (1st box) and 8164 (2nd box) and leave the 3rd box clear.
20. NAICS Code: Pre-populated. The predominant NAICS Code identified in the main contract will appear.
21. DESCRIPTION OF REQUIREMENT. Pre-populated from main contract.
22. AWARD AMOUNT - Pre-populated from obligation action being reported on.
23. Date Signed - Pre-populated from obligation action being reported on.
24. Subcontract Award Date: Contractor is required to list the Month in which he is reporting the subaward information. The Contractor is required to submit report(s) by the end of the month following the month of award of a first-tier subcontract with a value of $25,000 more.
25. Program or Project title: Contractor is to list the title of the Program or Project title assigned to this subaward action.
26. Unless exempted, the contractor and their first tier subcontractor shall report the names and total compensation of each of the five most highly compensated executives for the Contractor's preceding completed fiscal year if they receive $25M or more in annual gross revenues AND this accounts for 80% or more of its annual gross revenues. Block 26 allows the contractor the opportunity to indicate whether this is "YES" (i.e. true) or "NO" (not true). If you indicate "NO" then you are ready to go to the "Subcontractor Data" Information. If you indicate "YES" then proceed to block 27 to see if your company may still qualify to be exempted.
27. If you answered "YES" to block 26 and unless exempted, the contractor and their first tier subcontractor shall report the names and total compensation of each of the five most highly compensated executives for the Contractor's preceding completed fiscal year if 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. To determine if the public has access to the compensation information, see U.S. Security and Exchange Commission total compensation filings at http://www.sec.gov/answers/execomp.htm. If the contractor responds "YES," the public does have access to this information then no further information is required and you are ready to proceed to the "Subcontractor Data" section. If the response is "NO" then list the Name and Total compensation Amount for each individual. Please note that you are required to report on all 5. If there is less than 5 then please indicate N/A and 0 dollars in order for the system to record the information.

SUBCONTRACTOR DATA

Upon completion of the above information pertaining to the Prime Contractor, the next section is entitled "Subcontractor Data". This where the prime contractor provides information about their subcontractors. In addition to information that was not pre-populated as usual (if company is listed in CCR), some of the areas which will require the Prime Contractor to provide information about their subcontractors are as follows:

DUNS #: Provide the subcontractor's DUNS number. If the subcontractor is listed in CCR then inserting the DUNS will automatically much of the same information that was collected from the Prime Contractor.

Amount of the Subcontract: Provide the amount associated with subcontracting the work associated with the contract award action being reported on.

Date of the Subcontract: Self-Explanatory

Description - Provide a description of the overall purpose and expected outcome, OR results of the contract, including significant deliverables and, if appropriate, associated units of measure. This is one area that the Contracting Officer can review to see if it is consistent with the purpose of the award action. A maximum of 4000 characters is available in this block.

Subcontractor Place of Performance - Provide the Street Address, City, State, zip code + 4 (last 4 digits will also pre-populate the appropriate congressional district)

Subcontract Number - Provide the appropriate Subcontract Number used to identify this action.

Reporting of the names and total compensation of each of the five most highly compensated executives - In the same way Prime Contractors are required to report this (See blocks 26 and 27), Subcontractor information is also required.

Upon completion of the above, the FSRS Report is ready to be submitted. Press the "Submit" button and the information is automatically submitted. As indicated earlier, Although The Contracting Officer is responsible to review the information provided, there is no official approval needed by the Federal Government . Upon submission by the prime contractor, the collected information submitted is automatically made available to the public via a single, searchable website, which is www.USASpending.gov.