ED Indicates Institutions Without Subawardees Exempt from FFATA Reporting Requirements for CARES Act Funds

By Jill Desjean, NASFAA Policy & Federal Relations Staff

The Department of Education (ED) last month published an Electronic Announcement (EA) notifying institutions that their Coronavirus Aid, Relief, and Economic Security (CARES) Act Section 15011 quarterly reporting requirements would be satisfied by their compliance with the Federal Funding Accountability and Transparency Act (FFATA) of 2006

This announcement, published July 10, raised considerable confusion from institutions, primarily because FFATA reporting is for federal grantees who make subawards from those federal grants, which is not the case for the majority of institutional CARES Act grant recipients. In conversations with ED, the department acknowledged widespread confusion on reporting requirements and confirmed that it would be rare for institutional CARES Act recipients to have subawardees and, as such, most institutions would not be subject to FFATA reporting for their CARES Act funding. 

ED indicated to NASFAA that it will be issuing a Frequently Asked Questions document to explain that schools that do not have subawardees for their CARES Act formula grants would not have a FFATA reporting obligation. It is unclear whether that FAQ document will offer an alternative for meeting the CARES Act Section 15011 reporting requirements for the majority of institutions who are exempt from FFATA and, as such, still need to complete quarterly reporting if they received more than $150,000 in CARES Act funds.

As a reminder, the CARES Act Section 15011 reporting requirement is separate from the CARES Act section 18004(e) Higher Education Emergency Relief Fund (HEERF) reporting requirements, which are satisfied by the 30-day Fund Report and the proposed data collection announced by ED on July 29.

FFATA reporting continues to be required for other federal grants institutions receive and for which they make subawards, which could include CARES Act funds in the rare instances that institutions make subawards from those funds.


Publication Date: 8/7/2020

Joanie F | 8/27/2020 9:14:11 PM

If our website reporting per the "30-day" Fund report is happening, and FFATA awards are put in as the worklist, then create a report is developed but it isn't clear if the Prime and Subawards are the same or not, and now we may not need to report in FFATA, could we please just get clear, direct guidance so we can ensure we are compliant and quit chasing clarity? We are trying to serve students, be safe, open and more. Please help with a clear path- concise and specific.

Dori B | 8/7/2020 8:15:59 AM

This "one size fits all" model of regulatory guidance has been absolutely ridiculous, with no thought to how it may or may not apply to all institutions. I am continuously amazed at the guidance, announcements, etc., issued by ED that clearly demonstrate the profound lack of understanding that not all institutions of higher education are traditional four-year institutions. I imagine this has been said many times, but the management of regulatory guidance regarding the CARES Act has been a complete disaster.

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