FFATA Up-date

By Bob Beattie

I was hoping to get an update on Dave's FFATA questions of July 5, 2007, so I asked these follow up questions on the Grants.gov S2S listserv.

• What are the changes to the formsets required by FFATA??
• What will be the timing of these changes?

As a reminder of what the law requires, a web site where OMB is seeking input on the process mentions the following items:

1. the name of the entity receiving the award;
2. the amount of the award;
3. information on the award including transaction type, funding agency, title, etc;
4. the location of the entity receiving the award;
5. a unique identifier of the entity receiving the award.

The full text of the law gives more detail.

In response to my questions, the NSF representative to the SF 424 Forms Families & FFATA Implementation Subcommittee gave a very nice update of what forms changes would be needed. Luckily, most of these are already contained in the SF424R&R and it is the SF424 family that would get the most changes.

• DUNS - Required;
• Parish (this would be a global change everywhere that "County" appears in a SF 424 forms family);
• Project/Performance Site Congressional Districts;
• Areas Affected by Project (Continuation from SF 424 Cover Page);
• Congressional Districts of Areas Impacted by the Program/Project (Continuation from SF 424 Cover Page)

Can we assume that the DUNS number can just be take from the application itself? Since this part of the law, and thus the database, is not concerned with sub-awards we should assume that there is only 1 DUNS number -- that of the recipient organization. "Parish" might just be added to the field now called "County" and that field becomes a required one. The Project Performance Site Congressional District(s) are also on the SF424.

The field "Areas Affected by Project" is currently ill defined. The NIH Guide on the SF424R&R says this:  "List only the largest political entities affected by the project (for example, state, counties, cities)."

Is this supposed to mean the TYPE of entity, or the NAME of the entity? As far as the FFATA requirements are concerned, why does the type of entity matter? Moreover, the law does not require name(s) of the places affected by the project. Rather the law requires "the location of the entity receiving the award and the primary location of performance under the award, including the city, State, congressional district, and country."

There can be quite a substantial difference between the place of performance and the places affected by a project. This same logic can be applied to the data element "Congressional Districts of Areas Impacted by the Program/Project."  The law is not asking for this. The law seeks to help people understand where grant and contract money goes, not where it has impact. Where the project money goes is easy to determine, where the project has impact is not so easy to identify, especially for research projects.

Moreover, the crucial problem I see with the approach of the SF 424 Forms Families & FFATA Implementation Subcommittee is that it is seeking to obtain the required information at the proposal stage. Many more proposals are submitted than are accepted. There are often changes between what is proposed and what is eventually funded. I would suggest that any new data needed for the FFATA be collected at the award stage, not at the proposal stage.

In summary, leave the Grants.gov forms alone. Let the System-to-System developers keep working with what they have now. There will be a Federal Register call for comments on all of this soon (look to a future blog entry with the URL). I urge people to consider all the work that will be needed for both data not required by the law and changing the forms. I suggest that people comment that the process of FFATA compliance should be relegated to the award stage in the grants management process.