FFATA Reporting: $30,000 Threshold via SAM.gov

FFATA Reporting

FFATA reporting is the mandatory disclosure of subaward and executive-compensation information required under the Federal Funding Accountability and Transparency Act of 2006. A prime recipient of a federal award (or a pass-through entity issuing subawards under it) must report each subaward action of $30,000 or more in federal funds through SAM.gov (successor to the retired FSRS.gov, migrated around March 2025), by the end of the month following the month in which the obligation was made. Recipients meeting a two-part revenue test must also report the compensation of their five most highly compensated executives. The reporting obligation sits with the pass-through entity, not the subrecipient, and the resulting data feeds USASpending.gov for public transparency.

ByCASRAI Editorial Board

· Last updated 18 Jul 2026

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Worked examples

Is an instance

A university holding a prime NIH award issues a $75,000 subaward to a partner institution; as pass-through entity, it must report the subaward in SAM.gov by the end of the following month.

Is an instance

A subaward initially issued at $18,000 is later modified to $32,000; it becomes FFATA-reportable at the point of that modification, not from its original issue date.

Looks similar, but isn't

Not an instance

A subaward that stays under $30,000 for its entire life is never FFATA-reportable, no matter how many modifications occur, as long as none reach the threshold.

Not an instance

A purchase order or vendor contract for goods or routine services is not a subaward, so it is outside FFATA subaward reporting regardless of dollar value.

FFATA reporting refers to the disclosure obligations created by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). The Act was designed to give the public visibility into how federal award money is spent once it moves beyond the prime recipient, down to the level of individual subawards.

Who has to report

The obligation falls on the prime recipient of a federal award when it acts as a pass-through entity and issues a subaward. The pass-through entity reports the subaward action itself; the subrecipient receiving the funds is not the one filing the report, though it typically has to supply the data the pass-through entity needs. This division of responsibility is the same one described in CASRAI’s guide on subaward agreement negotiation and is closely related to ongoing subrecipient monitoring obligations.

The threshold and deadline

Reporting applies to new federal prime awards of $30,000 or more made on or after October 1, 2010, and to subawards issued under them that reach or exceed $30,000 in federal funds. A subaward that starts below that threshold but is later modified up to $30,000 or more becomes reportable at the point of that modification, not retroactively from its original issue date. The report is due by the end of the month following the month in which the obligating action occurred.

Where reports are filed: the move from FSRS.gov to SAM.gov

Subaward and executive compensation reports were historically filed through FSRS.gov (the FFATA Subaward Reporting System). FSRS.gov was retired around March 2025, and FFATA reporting is now done directly within SAM.gov, which consolidated several federal award-management functions. Because this is a relatively recent systems change, anyone citing where to file should confirm current guidance rather than referencing FSRS.gov as a still-active destination.

Executive compensation reporting

Alongside subaward reporting, a recipient (prime or pass-through) must separately report the compensation of its five most highly compensated executives for the preceding fiscal year if, in that preceding fiscal year, it met both of the following: (1) 80% or more of its annual gross revenue came from federal contracts, subcontracts, loans, grants, or cooperative agreements, and (2) it received $25,000,000 or more in annual gross revenue from those same federal sources. This follows the same end-of-following-month deadline logic tied to the initial award or subaward action.

How this feeds public transparency

Data entered into SAM.gov under FFATA flows through to USASpending.gov, the public-facing federal spending transparency platform, allowing the public, researchers, and oversight bodies to trace federal award dollars down to individual subaward actions and, where applicable, executive compensation.

Examples

A university holding a prime NIH award issues a $75,000 subaward to a partner institution to perform a defined portion of the research. Because the subaward is $30,000 or more, the university, as pass-through entity, must report it in SAM.gov by the end of the month following the month the subaward was obligated.
A subaward is initially issued at $18,000, below the reporting threshold. A subsequent modification increases its total value to $32,000. The subaward becomes FFATA-reportable at the point of that modification.

Counter-examples

A subaward that remains under $30,000 for its entire life is never FFATA-reportable, regardless of how many modifications it goes through, as long as none of them push it to or past the threshold.
A purchase order or vendor contract for goods or routine services is not a subaward at all (it does not carry out a portion of the substantive programmatic effort), so it falls outside FFATA subaward reporting regardless of dollar value.

References

HRSA, FFATA guidance (hrsa.gov/grants/ffata)
SAM.gov (federal system of record for FFATA subaward and executive compensation reporting)
USASpending.gov (public transparency platform fed by SAM.gov data)
2 CFR Part 170 (FFATA subaward and executive compensation reporting requirements)

Use in your systems

JATS XML <role> element

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Schema.org DefinedTerm (JSON-LD)

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