Reminder on Subcontract and Subaward Reporting Requirements
Dear Partners,
The purpose of this letter is to remind prime contractors and recipients of their responsibilities to report certain subawards and subcontracts in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS), available at FSRS.gov.
In addition to being a statutory requirement under the Federal Funding Accountability and Transparency Act of 2006, this reporting is also vital for USAID to track and monitor the implementation of Agency-funded activities. Compliance with FSRS reporting requirements by prime contractors and recipients helps advance the Agency’s localization efforts and facilitates the achievement of Objective 3.2 (“Localization goals advanced through reduced barriers and A&A best practices”) in USAID’s recently-updated Acquisition and Assistance Strategy. In particular, FSRS reporting promotes transparency and accountability of Agency-funded activities, as well as visibility in how subcontracts and subawards expand our partnerships with local entities in the countries we serve.
Requirements: The requirements and detailed instructions for prime contractors and recipients regarding the reporting of subcontracts and subawards are incorporated into acquisition and assistance awards as follows:
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Acquisition: Contractors must comply with the requirements in the FAR 52.204-10 (“Reporting Executive Compensation and First-Tier Subcontract Awards”) clause found in their contract, as applicable.
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Assistance: Recipients must comply with the requirements in any applicable “Reporting Subawards and Executive Compensation” standard provision found in their award (e.g., RAA24 in ADS 303maa, RAA7 in ADS 303mab, RAA3 in ADS 303 mat).
Resources: Guidance and training tools are available to support prime contractors and recipients in complying with FSRS reporting. Please refer to the FSRS Awardee User Guide, the FSRS Awardee User Demonstration Video, and the FSRS Frequently Asked Questions (FAQs). The FSRS Resources page contains additional quick reference guides and technical documentation.
Data integrity: Information on subcontracts and subawards reported through FSRS is made publicly available through USASpending.gov. Unfortunately, USAID has identified a number of cases of missing data or other inaccuracies with the data reported by prime contractors and recipients in FSRS, resulting in imprecise information presented on USASpending.gov. For example, USAID analyzed the “Percent of Prime Award Obligated Amount” metric available on an individual award’s page on USASpending.gov and found that — in multiple cases — the data indicates a higher amount of subcontracts/subawards (by dollar value) than the dollar amount obligated under the prime award. The negative impact of these missing and inaccurate data is significant and affects USAID’s ability to monitor and achieve Agency goals. Therefore, I am requesting that all prime contractors and recipients ensure proper procedures are in place to comply with FSRS reporting requirements in their awards and enter the necessary information accurately for all applicable subcontracts and subawards.
Non-compliance: If a prime contractor or recipient is not fully compliant with applicable FSRS reporting requirements under their award, USAID may apply standard remedies available under the award for failing to meet award requirements.
Questions: If you have any questions regarding FSRS reporting requirements, please contact your cognizant Contracting Officer or Agreement Officer.
We appreciate your efforts to ensure that applicable subcontracts and subawards are accurately reported in the FSRS system.
You can find a a copy of this notice signed by the USAID Senior Procurement Executive on the IPN Acquisition and IPN Assistance Portals.
Thank you for your attention to this matter.
Mark A. Walther
USAID Senior Procurement Executive
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