Understanding Your Reporting / Audit Requirements

Every CDC grant has reporting requirements that must be followed. These reporting requirements are designed to ensure that the recipient is adhering to federal regulations and policies. The accurate and timely submission of required reports is extremely important for the recipient’s success and continued funding. Below are examples of the types of reports and/or audits that you must submit and respond to.

Transparency Act and Executive Compensation Reporting

Federal Funding Accountability and Transparency Act (FFATA), P.L. 109-282, as amended by section 6202 of P.L. 110-252 requires the full disclosure of all entities and organizations receiving federal funds including awards, contracts, loans, other assistance, and payments through a single publicly available website, https://www.USAspending.gov.

Grant recipients must report subaward, and executive compensation information in regards to first-tier subawards greater than or equal to $25,000 into the Federal Subaward Reporting System (FSRS). Reporting is required no later than the end of the month following the month in which the obligation was made. For executive compensation, you should provide the names and total compensation of the five most highly compensated officers. The Digital Accountability and Transparency Act of 2014 (DATA Act) requires the full disclosure of all federal agency expenditures.

Full text of the requirements under FFATA and HHS guidelines are at:

• https://www.gpo.gov/fdsys/pkg/PLAW-109publ282/pdf/PLAW-109publ282.pdf
• https://www.fsrs.gov/documents/ffata_legislation_110_252.pdf
• https://www.hhs.gov/grants/grants/grants-policies-regulations/index.html#FFATA

Reporting Progress

Progress Reports are required at least annually as part of the non-competing continuation award process. Recipients should refer to their Notice of Award (NoA) for reporting requirements, or the Grants Management Specialist (GMS) assigned to your award will provide information on how, when, and where to submit progress reports. Non-competing continuation awards are made based on the bona fide need of the recipient, availability of funds, and satisfactory performance, as evidenced in the progress report.

Each grant recipient is required to submit an Annual Progress Report (APR), due no later than 120 days prior to the end of the budget periods. The APR serves as the continuation application for the follow-on budget period. The report includes information on performance measures, evaluation results, work plan, successes, challenges, CDC program support to recipients, and administrative reporting. Recipients will submit the APR through GrantSolutions. CDC’s GrantSolutions for Grantees webpage has more information for grant recipients.

Additional information regarding the Final Progress Report is in the “Understanding Closeout” section.

Reporting your Federal Financial Report (FFR)

CDC requires grant recipients to submit various programmatic and financial reports which are due at specific times during the life cycle of a grant award. All reports must be accurate, complete, and submitted on time.

The FFR (Form SF-425) is required and must be submitted in accordance with the terms and conditions provided in the NoA. The report must include only those funds authorized and disbursed during the timeframe covered by the report. The report also must cover any authorized extension during the reported budget period. For more information, see the FFR Expenditure Data section on the reporting page.

Reporting Inventions

All grant recipients must submit an original Final Invention Statement and Certification (Form HHS 568) even if no inventions resulted under the grant. The Bahy-Dole Act (P.L 96-517) grants recipients the right to elect title and retain ownership to inventions they develop with funding under a CDC award. By accepting the award, the recipient agrees to comply with the applicable policies and regulations. More information regarding inventions can be found in the HHS Grants Policy Statement, Section II-72, as well as Title 37, Code of Federal Regulations (CFR) Part 401..

When completing the Form HHS 568, the Principal Investigator (PI) must list all inventions conceived, or first actually put into practice, during the course of work under the project, from the original effective date of support through the date of expiration or termination, regardless is previously reported. If there were no inventions, indicate “None” on the statement. The Final Invention Statement and Certification Form must be signed by the PI and the institution’s authorized official.

Audit Requirements

A non-federal entity that expends $750,000 or more during the non-federal entity’s fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.

Organizations expending less than $750,000 during their fiscal year are not required to have an annual audit for the year but must ensure that their grant related records are made available to CDC or other designated officials for review or audit.

For foreign-based and international organizations, CDC applies an audit threshold of $300,000. Specific statutes or authorities may set a different audit threshold. You will need to refer to your NoA to determine the audit threshold that applies.

Audit requirements, (including differences between single and program-specific audits), for state and local governments, and non-profit organizations (including institutions of higher education) receiving federal awards or subawards, can be found in 45 CFR Part 75, Subpart F, Audit Requirements.

Applicable non-federal entity recipients performing a single audit will submit the data collection form (SF-SAC), and the Single Audit reporting package through the Federal Audit Clearinghouse’s Internet Data Entry System (IDES). Note that recipients must be logged on in order to access. Foreign recipients send their audits directly to CDC at OGS Audit Resolution.

When an auditee expends federal awards under only one federal program (excluding research and development [R&D]), and the federal program’s statutes, regulations, or the terms and conditions of the award do not require a financial statement audit of the auditee, the auditee may elect to have a program-specific audit conducted. This excludes research and development (R&D). A program-specific audit may not be elected for R&D unless all of the federal awards expended were received from the same federal agency, or the same federal agency and the same pass-through entity, and that federal agency, or pass-through entity in the case of a sub-recipient, approves in advance a program-specific audit.

Audit requirements for for-profit (commercial) organizations, including for-profit hospitals, are defined in 45 CFR Part 75.501 (h)-(k). A for-profit organization is required to have a non-federal audit if, during its fiscal year, it expended a total of $750,000 or more under one or more HHS awards (as a direct recipient or consortium participant).

Recipients and sub-recipients that are commercial organizations (including for-profit hospitals) have two options regarding audits. 1) A financial related audit (as defined in the Government Auditing Standards, frequently referred to as the Yellow Book) of all HHS awards in accordance with Government Auditing Standards; or 2) an audit that meets the requirements contained in 45 CFR Part 75, Subpart F, Audit Requirements.

GrantSolutions

Non-research grant recipients use GrantSolutions for grants management activities.

GrantSolutions is a web-based system, accessible from anywhere you can use the internet.

GrantSolutions contains your official grant file. You will use GrantSolutions for

• non-competing continuation applications,
• post-award amendment actions,
• electronic storage of grant documents like applications, progress reports and site visit reports, and
• corresponding with your project officer and grants management specialist.

You can also receive notifications such as your Notice of Award and post-award amendment decisions. All actions in GrantSolutions have a time and date stamp for tracking purposes. Everyone working on your grant will have access to important grant documents including you and your team, your grants management specialist, and your project officer.

For more information regarding grant recipient roles, actions, and support, please visit the GrantSolutions for Grantees webpage.

Research grantees will continue using eRA Commons for grants management.