Pass-Through Entities Should Verify FFATA Subaward Reporting Before Audits

The draft 2026 Supplement highlights FFATA subaward reporting as an item for organizations to check before audit fieldwork. The issue is relevant to entities that pass federal funds to other organizations: when the applicable award requires FFATA reporting, qualifying first-tier subawards must be reported. The source summarizes the threshold as $30,000 or more, making award-term review and subaward-level recordkeeping important parts of audit preparation.

The reporting process also involves a system transition. According to the source, the federal reporting system used for this purpose replaced FSRS in March 2025. Pass-through entities should therefore confirm that their procedures and audit documentation point to the current system, rather than relying on records or instructions tied only to the former platform. The source does not name the replacement system, so organizations should verify the applicable reporting destination using current official guidance and their award requirements.

For procurement and grants management teams, this is a compliance-control issue rather than a new funding opportunity. The practical first step is to determine whether each relevant federal award requires FFATA reporting, then identify first-tier subawards meeting the stated threshold. Finance, grants administration, and subrecipient-management staff can use that population to check that required filings were completed and that the reported amounts and dates agree with underlying subaward records.

Audit readiness depends on being able to trace reported information back to award and subaward documentation and to reconcile subrecipient totals with the Schedule of Expenditures of Federal Awards (SEFA). A mismatch between reporting records and internal schedules may require investigation before fieldwork. The source’s central reminder is timely: “One item in the draft 2026 Supplement is worth checking now: FFATA subaward reporting.” Since the item is identified as part of a draft supplement, organizations should monitor relevant final guidance while reviewing existing controls against current award terms and reporting requirements.

• Review each federal award’s terms to determine whether FFATA reporting applies; the source does not indicate that the requirement applies to every award.
• Identify first-tier subawards of $30,000 or more when reporting is required.
• Confirm that applicable filings were made in the federal reporting system that replaced FSRS in March 2025.
• Verify the current reporting destination and retain evidence of filings in the organization’s audit documentation.
• Reconcile reported subaward amounts and dates against executed subaward records and related internal tracking.
• Compare subrecipient totals with the SEFA and investigate differences before audit fieldwork.
• Coordinate grants, finance, and subrecipient-management records so the reporting trail is complete and consistent.
• Treat the draft 2026 Supplement reference as an audit-readiness prompt and check for applicable final guidance.