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Posted by on Sep 14, 2010

New Award Terms Set for FFATA, DUNS/CCR

Today the Office of Management and Budget issued regulations requiring federal agencies to include new award terms in their grants and cooperative agreements.

First, agencies must now include language requiring applicants to have DUNS numbers and to maintain current registration in the CCR. The term will be included in awards for grants and cooperative agreements effective Oct. 1 2010, while the deadline for other assistance recipients – such as those receiving loans, subsidies, insurance, food, and “direct appropriations” – is Oct. 1, 2011. The actual award term is included in the appendix to the regulation.

The new DUNS/CCR regulation is located in 2 CFR Part 25.

OMB also published an interim final regulation regarding the new award term for the Transparency Act subaward reporting requirement. This new term is located in 2 CFR Part 170 (Note: this location is different than the one originally proposed by OMB in 2008: Part 33. Under the revised Title 2 structure, Part 33 is now preaward, so the new Transparency Act term will be located in Part 170, which is the national policy section.)

OMB notes that this new CFR part provides standard wording for an award term (also included as an appendix) that each agency must include in grant and cooperative agreement awards it makes on or after Oct. 1, 2010. There is a distinction between this and the operational details on what and how to report. That format and information proposal was issued as an information collection request by the General Services Administration on July 23. This current regulation is simply the award term that notifies recipients of their responsibilities for reporting information about first-tier subawards and executive compensation.

The Transparency Act’s definition of ‘‘federal award’’ includes multiple types of financial assistance awards, but only subawards under grants and cooperative agreements need to be reported at this time. Subawards under all types of financial assistance will need to be reported at a later date, which OMB will explain in future memoranda, according to the notice.

You can view the OMB notices here.

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