When the Transparency Act side-swiped everyone with FFATA and the new FSRS reporting system, the schools at Johns Hopkins banded together to develop a basic plan for how to handle the new regulations and maintain compliance.
For a while, our system worked. We (the ORA) entered data into FSRS during even months (February, April, et al.) and updated purchasing during odd months (January, March, et al.). Despite the occasional kinks, we were able to keep current and generally seemed to have everything under control.
Little did we know that the federal government would expand its FFATA reporting responsibilities. At that point, we started to see our system’s cracks, as bins started overflowing with files waiting to be entered. The volume in and of itself was one thing, as it was and is relentless. However, two larger issues have appeared that grind things to a halt but, unfortunately, are largely out of our control:
- What do you do when the prime award has not been uploaded into the FSRS system by the sponsor? In our case, USAID seems to be behind in its upload duties, which keeps us from being able to add our subrecipients in a timely fashion. For the time being, we are simply documenting our attempts and crossing our fingers that USAID gets their act together.
- What do you do when your subrecipient is waiting for a DUNS number? Now that every subrecipient is required to have a DUNS number we find ourselves in a strategic waiting game. Agreements are executed and waiting to be entered into FSRS, but the subrecipients (usually foreign) are still waiting to receive a DUNS number. However, even when our sub has received its ID number, it regularly is not recognized in the system. Once again, we document our attempts and cross our fingers that everything will be straightened out soon.
When it comes to compliance, we want to do everything in our power to make sure we practice what we preach to our PIs. While we believe our methodology to be sufficient for our efforts, we also believe that our colleagues may have discovered additional ways to combat any issues that arise.
So, we want to know your processes for FFATA. How is your office handling FFATA entries and the problems that arise? Are we the only institution having trouble uploading prime agreements from USAID? And are there other issues out there that your office has encountered?