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Federal Spending Transparency: Opportunities Exist to Improve COVID-19 and Other Grant Subaward Data on

GAO-24-106237 Published: Nov 16, 2023. Publicly Released: Nov 16, 2023.
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Fast Facts

States and other federal grant recipients can "subaward" some of the money to another recipient to do some of the work. Guidance directs most award recipients to report their subawards for display on Having access to quality federal spending data is critical during national emergencies when relief funds are distributed quickly—as during the COVID-19 pandemic.

But some grant subaward data on was incorrect or missing information. Also roughly 26% of reported non-COVID-19 subawards, and about 11% of reported COVID-19 subawards, are likely duplicates.

Our recommendations are for improving subaward data.

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What GAO Found

Federal grant award recipients, such as nonprofit organizations, can pass on a portion of their awards to another entity as a subaward to carry out a portion of the work. Office of Management and Budget (OMB) guidance directs recipients of federal grants (prime recipients) to report grant subawards they make to the Federal Funding Accountability and Transparency Act of 2006 Subaward Reporting System (FSRS) for display on, with exceptions. Prime recipients are legally responsible for the quality of the reported data. OMB guidance directs federal agencies to support overall subaward data quality.

GAO's analysis of grant subaward data available from identified data quality issues, including grant subawards with missing information, impossibly large amounts, and likely duplicative records. GAO found that 26 percent of non-COVID-19 grant subawards and 11 percent of COVID-19 grant subawards reported by prime recipients are likely duplicate records (see figure).

Percent of Likely Duplicate Grant Subaward Records on

Percent of Likely Duplicate Grant Subaward Records on

Note: A “subaward” is an award provided by a recipient to a subrecipient to carry out part of a federal award. Grant subawards cover subawards that are made under federal grant awards. The term does not include subawards made under other forms of federal financial assistance awards (i.e., loans) or subawards made under federal contracts (subcontracts). COVID-19 grant subawards refer to subawards reported to that were made after April 1, 2020, and are associated with a prime award with a disaster emergency fund code indicating it received COVID-19 funding.

FSRS includes some built-in data entry tools, such as mandatory data fields, but there are few validation tests to alert prime recipients about potential data entry errors during the reporting process. The General Services Administration (GSA), which administers FSRS, plans to address some known reporting challenges as part of its plan to modernize FSRS. In the interim, the Department of the Treasury, which administers, could more clearly disclose subaward data limitations by putting them where users are likely to see them.

OMB guidance delineates agency responsibilities for communicating prime award recipients' subaward data reporting requirements. However, OMB guidance is unclear on what processes agencies are expected to implement to support subaward data quality. Without clear expectations from OMB, agencies may not consistently or adequately support subaward data quality, which could affect the usability of subaward data.

Why GAO Did This Study

Congress has long recognized the importance of providing quality data to the public to ensure the transparency of federal spending, including subawards. This is critical during national emergencies when federal emergency relief funds, such as those appropriated in response to the COVID-19 pandemic, must be distributed to the public quickly.

The CARES Act includes a provision for GAO to monitor and oversee funds used to prepare for, respond to, and recover from the pandemic. This report (1) assesses the quality of grant subaward data available on, including COVID-19-related awards; and (2) examines the extent to which guidance governing subaward reporting supports the quality of the subaward data.

GAO conducted a series of tests on roughly 6 million grant subaward records available on; reviewed the legal framework that governs subaward reporting; and interviewed officials from selected agencies to understand how they support subaward data quality.


GAO is making two recommendations to GSA, including that it incorporate data validation controls into its plan for modernizing the reporting system; one recommendation to Treasury to improve grant subaward data quality disclosures on; and one recommendation to OMB to clarify agency roles for supporting grant subaward data quality. GSA and Treasury concurred with the recommendations, and OMB did not have any comments on the report.

Recommendations for Executive Action

Agency Affected Recommendation Status
General Services Administration The Administrator of GSA should incorporate automated data validations or other controls that will address known FSRS data quality limitations, such as incorrect award amount entries, into the design and development plan for modernizing FSRS or for a successor system (Recommendation 1).
GSA agreed with this recommendation. In January 2024, GSA officials told us that they will review existing plans for improving data entry in modernization of FSRS and determine any gaps that exist between existing planned improvements and findings of the report. GSA will solicit inter-agency feedback on potential improvements that may be implemented and incorporate final approved changes into the FSRS modernization approach plans by July 31, 2024. We will continue to monitor GSA's progress towards implementing this recommendation.
General Services Administration The Administrator of GSA should provide additional guidance to help prime recipients improve the quality of their subaward data submissions, such as actions to prevent duplicative reporting (Recommendation 2).
GSA agreed with this recommendation. In January 2024, GSA officials told us that GSA has developed an approach for addressing gaps in help documentation and communications for both legacy FSRS and modernized FSRS systems. GSA plans to deliver improved guidance by May 31, 2024. We will continue to monitor GSA's progress toward implementing this recommendation.
Department of the Treasury The Secretary of the Treasury should disclose additional subaward data quality limitations on the pages where users search for or view subaward data (Recommendation 3).
Treasury concurred with this recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Office of Management and Budget The Director of OMB should clarify its expectations for agencies to support the quality of subaward data reported by prime recipients (Recommendation 4).
OMB did not have any comments on the report. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Full Report

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Disaster emergenciesFederal agenciesFederal awardsFederal spendingGrant awardsGrant programspandemicsProgram transparencyPublic health emergenciesReporting requirements