Notice of Expanded Transparency Act Subaward and Executive Compensation Reporting Requirements for FY2012 and Beyond
Release Date: November 10, 2011
NOT-OD-11-005: Notice of New NIH Term of Award on Transparency Act Subaward and Executive Compensation Reporting Requirements
National Institutes of Health (NIH))
The Federal Funding Accountability and Transparency Act of 2006, as amended ("FFATA", or "Transparency Act"), requires the Office of Management and Budget to establish a single searchable database, accessible to the public, with information on financial assistance awards made by Federal agencies. The Transparency Act also includes a requirement for recipients of Federal grants to report information about first-tier subawards and executive compensation under Federal assistance awards. In accordance with OMB guidance NIH implemented the Transparency Act subaward reporting requirements by applying it to only New (Type 1) competing awards issued on or after October 1, 2010 with an expectation that the scope of the requirement would be expanded by OMB to be applicable to all award transactions competing and non-competing. Since then, it became apparent that the scope will remain just New (Type 1) awards issued on/after October 1, 2010. However, applicability now also includes any subsequent award action following an applicable New NIH award.
Policy
Effective immediately, unless specifically exempted, NIH awards where the competing Type 1 award was issued on or after October 1, 2010 will be subject to the Transparency Act subaward and executive compensation reporting requirements. These requirements will now also apply to all subsequent award actions to any such NIH grant or cooperative agreement award; e.g., a Type 5 award issued subsequent to an applicable Type 1 award.
To help grantees specifically identify awards subject to the subaward and executive compensation reporting requirements described above, NIH will classify each award using the applicable term below. This language will appear in the Terms and Conditions section (Section III) of each Notice of Award issued on or after November 10, 2011.
Eligible for FFATA Reporting: Based on the Project Period Start date of this project, this award is likely subject to the Transparency Act subaward and executive compensation reporting requirements of 2 CFR Part 170. There are conditions that may exclude this award; see https://grants.nih.gov/grants/policy/awardconditions.htm for additional award applicability information.
Not Eligible for FFATA Reporting: This award is not subject to the Transparency Act subaward and executive compensation reporting requirement of 2 CFR Part 170.
Please direct all inquiries to:
Division of Grants Policy
Office of Policy for Extramural Research Administration
National Institutes of Health
6705 Rockledge Drive, Suite 350
Bethesda, MD 20892
Telephone: (301) 435-0938
FAX: (301) 435-3059
EMAIL: [email protected]
and Human Services (HHS)
