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