Open Government Directive

Federal Spending Transparency and Subaward and Compensation Data Reporting



Increasing transparency and improving access to Federal Government information, particularly information on Federal spending, is a primary objective of Open Government. To that end, this Memorandum provides Federal agencies with guidance on reporting subaward and compensation data for Federal contracts and grants. As required by the Federal Funding Accountability and Transparency Act(“Transparency Act” or “FFATA”) and subsequent OMB guidance, information on the first-tier subawards related to Federal contracts and grants and the executive compensation of awardees must be made publicly available. This memorandum and accompanying documents provide agencies with guidance to implement these reporting requirements.

Federal agencies must continue efforts to increase the availability of public information related to Federal spending and to improve the data quality of information so reported. To provide the public access to information on Federal spending through, this Guidance directs agencies to:

  • Require prime awardee reporting of first-tier subawards associated with new Federal contracts and grants as of October 1, 2010 (Appendix A);
  • Require prime awardee reporting of executive compensation for new Federal contracts and grants as of October 1, 2010, as set forth in FFATA;
  • Require prime awardees of Federal grants to register in the Central Contractor Registration (CCR) system;
  • Ensure alignment of agency systems’ and processes to meet these reporting requirements(Appendix B, Awardee Reporting Architecture); and
  • Participate in the development of a long-term architecture to facilitate the availability of other Federal spending information (e.g., loans, other assistance).

The Guidance and Awardee Reporting Architecture contained in this Memorandum leverage existing information and processes to enhance data quality and data integrity, both of which are necessary to provide complete public access to Federal spending information. The Awardee Reporting Architecture delineates how existing systems, platforms, business processes,and technologies will work in synergy to pre-populate, collect, and report Federal spending information. Subaward information for Federal contracts and grants will be collected using a single collection tool.

Following this Guidance and Awardee Reporting Architecture, OMB will also issue additional guidance on data quality guidelines and the scope of reporting for sensitive but unclassified information.

To continue our partnership and collaboration with the public, OMB and Federal agencies shall jointly initiate aggressive outreach to the public stakeholders. This outreach will serve two important ends. First, it will provide opportunities to educate stakeholders on the Transparency Act’s subaward and compensation data reporting requirements. And second, it will serve as a forum to solicit continued input on Federal spending transparency initiatives.

I appreciate your hard work in ensuring that our Federal Government continues to provide the public with necessary government spending information. If you have any questions regarding this Memorandum, please contact Karen Lee at