NIH Policy on FFATA Subaward and Executive Compensation Reporting

Applicability of Transparency Act Subaward Reporting Requirements Notice Number: NOT-OD-26-066

Key Dates

Release Date: April 10, 2026

Related Announcements

None

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

NIH is reminding the extramural research community of longstanding subaward and executive compensation reporting requirements of the Federal Funding Accountability and Transparency Act (FFATA). All NIH awards issued on or after October 1, 2010 are subject to these requirements, which are published in the NIH Grants Policy Statement (GPS) Section 4.1.8. The NIH GPS is incorporated by reference as a standard term and condition of every NIH award. NIH is aware of a small population of recipients with projects beginning prior to October 1, 2010 where the Notice of Award (NOA) inaccurately advised in section three that the subaward and executive reporting requirements were not applicable. In these instances, the NIH GPS language regarding subaward and executive reporting supersedes the NOA language. Impacted recipients will be contacted by the NIH Office of Policy for Extramural Research Administration (OPERA) to request they certify compliance with the reporting requirement.

A component of Public Law 109-282, the Federal Funding Accountability and Transparency Act of 2006 as amended, requires most recipients of new Federal funds to report on subawards/subcontracts/consortiums equal to or greater than $30,000. This includes awards that are initially below $30,000 but subsequent grant modifications result in an award equal to or greater than $30,000.

FFATA specifies the data that should be captured for each pass-through entity and first-tier subrecipient of Federal awards, regardless of award type. To promote data consistency and reduce reporting burdens, existing agency data sources will be leveraged to pre-populate reports for pass-through entities as well as for subrecipients when available. Recipients are responsible for confirming the pre-populated data and providing any additional required information.

Included in these requirements is the need to report the names and total compensation of the five most highly compensated officers of the entity if the entity as part of their registration profile in SAM in the preceding fiscal year: 1) received 80 percent or more of its annual gross revenues in Federal grants, subawards, contracts, and subcontracts; and 2) received $25,000,000 or more in annual gross revenues from Federal grants, subawards, contracts, and subcontracts; and 3) had gross income, from all sources, of $300,000 or more; and 4) the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See FFATA § 2(b)(1).

Inquiries

Please direct all inquiries to:

Office of Policy for Extramural Research Administration
Division of Grants Compliance and Oversight
[email protected]

Weekly TOC for this Announcement
NIH Funding Opportunities and Notices Department of Health
and Human Services (HHS) NIH... Turning Discovery Into Health ®