UC Comment Letters

This comment letter responds to the General Services Administration (GSA)'s Information Collection on the Federal Funding Accountability and Transparency Act Sub-Award Reporting System Registration Requirements for Prime Grant Awardees (FFATA reporting requirements) published in the Federal Register on February 29, 2024. UC acknowledges that FFATA subaward reporting is statutorily required, but says GSA’s estimated annual burden of 30 minutes per respondent is a major underestimate because UC submits reports monthly and campuses spend roughly 18 to 30 hours per report, or about 200 to 360 hours per year. UC recommends improving FSRS guidance and technical support, resolving recurring system errors, reducing duplicative data entry, carrying forward unchanged information for existing subawards, and limiting required FSRS fields to those actually required by FFATA.