New Reporting Requirements For Grant and Cooperative Agreement Recipients

On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first requires (among other things) that, for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the Central Contractor Registration ("CCR"), and the second requires (among other things) that recipients of grants and other forms of federal financial assistance must (subject to a few limitations that generally mirror those in the FAR) provide information about the recipient's executive compensation, first-tier subawards over $25,000, and subrecipients' executive compensation.