What should NYS OASAS-funded providers know about the Federal Funding Accountability and Transparency Act?
Any NYS OASAS provider that receives State Aid designated as 013F: Federal on their OASAS funding agreement should be aware of the Federal Funding Accountability and Transparency Act, or FFATA.
FFATA is a US law requiring certain information related to federal awards, such as the Federal Substance Use Block Grant (SUBG), must be publicly accessible.
When OASAS funds an LGU or direct contract agency with 013F: Federal SUBG dollars, those entities become first tier subawardees of New York’s SUBG award. Every subawardee must have a Unique Entity Identifier (UEI).
For each first-tier subawardee, OASAS is required to report in the Federal System for Award Management the following:
- Subaward amount – The estimated obligation of Federal SUBG funds from a specific award.
The SUBG is administered by OASAS on a July-June funding cycle. When OASAS budgets SUBG funds to a provider, the estimated subaward amount corresponds with that July-June period.- For providers on a July-June fiscal period, the estimated subaward amount will mirror the 013F total on your OASAS funding agreement.
- For providers on a Calendar fiscal period, the estimated subaward amount is approximately half the annual budgeted 013F on your OASAS funding agreement for each of two years. The initial reported estimated subaward will mirror the annual amount. Future updates will take into account known changes in the second annual period impacted.
- Executive Compensation data - The names and total compensation of your five most highly compensated executes for your most recently completed fiscal year IF: The public does not have access to executive compensation information through reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or § 6104 of the Internal Revenue Code of 1986 (note that up-to-date filing of Form 990 also suffices);
- AND Eighty percent (80%) or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act (including OASAS SUBG funding), as defined at 2 CFR § 170.320 (and subawards);
- AND $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts), and Federal financial assistance subject to the Transparency Act (and subawards).
To assist OASAS in complying with FFATA, OASAS periodically communicates information to providers based on award and provider fiscal periods via email to the Executive Director and Financial Officer(s) as listed in the OASAS Provider Directory System (PDF). These emails require (1) confirmation of receipt; (2) confirmation of UEI; and (3) confirmation that the criteria for reporting executive compensation information do not apply. Failure to respond by the stated deadline will result in the withholding of future advances of Federal funds.
Questions related to the information above may be directed to [email protected].