The announcement below is provided for informational purposes. While no action is required at this time, FFATA will require changes to our sub-contracting and other procurement processes. further information will be provided in the near future.
Effective October 1, 201, new federal rules took effect. The rules are a result from the passage of the Federal Funding Accountability and Transparency Act (FFATA). The rules require federal prime awardees to report new first-tier subcontracts via a federal website so the public is aware of those subcontracts, and we are therefore accountable for the subcontracts. The first-tier subcontracts are subcontracts issued only by the prime awardee for the award.
The OSP and OGCA will handle the reporting necessary under FFATA. However, principal investigators and departmental administrators will assist in providing some of the information and need to be aware that new first-tier sub contracts after October 1, 2010 MUST HAVE A DUNS NUMBER AND BE REGISTERED IN CCR. Most colleges and universities have a DUNS number and are registered in CCR. CCR is the federal government’s Central Contractor Register. If you want government business, you must register in CCR. you need a DUNS number in order to register in CCR. When you register, you provide your banking information so you are paid electronically (another government rule). If one of our potential first-tier subcontractors is not registered in CCr, the subcontract cannot be issued until they are registered. NO EXCEPTIONS – this includes foreign first-tier subcontractors.
Under FFATA there are two types of first-tier subcontracts – those issued under grants and cooperative agreements and those issued under federal contracts signed by a contracting officer. First-tier subcontracts issued under federal contracts will required departmental and Procurement and Payment Services (PPS) help if we are to ensure that we are complying properly with the new rules. The definition of a subcontract for Federal Contracts is more broadly defined than for subcontracts under grants and cooperative agreements. It includes a “subcontract awarded by the contractor to furnish supplies or services for performance of a prime contract”, but excludes long-term supplier agreements with vendors.
the broader definition means we need to include some vendor purchase orders of greater than $25,000 after October 1, 2010. PPS has provided the OGCA a listing of non long-term supplier purchase orders greater than $25,000 during October. Centrally, we will contact those first-tier subcontractors for their DUNS number and have them register in CCR if they are not currently. Going forward, PPS buyers WILL NOT issue purchase orders if the subcontractor qualifies as a first-tier subcontractor and is not registered with CCR. If you are in doubt, please contact the sub-contractor PI, who should be able to put you in touch with the responsible party that the subcontractor knows. PPS will expect the department to work with the subcontractor to get them registered with CCR if they need to be.
Wire transfers do not go through the purchasing system. Therefore, we need to be especially diligent to make sure these subcontractors, including international first-tier subcontractors, have registered in CCR before their wire transfers are processed.
The efforts and procedure changes required are under development by staff members of OSP, OGCA, and PPS. Over the next few weeks, additional guidance will be provided via this listserv, The Research Administration Newsletter and the OSP/OGCA websites as policies, procedures and forms are developed and implemented over the next few weeks. We appreciate your help in implementing this latest federal requirement.
