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| Number | Data Element Name | Legislation |
|---|---|---|
| 9 | Highly Compensated Officer Name | FFATA |
| 10 | Highly Compensated Officer Total Compensation | FFATA |
The Government Funding Transparency Act of 2008, which amended FFATA, required that awardees report the names and total compensation of the five most highly compensated officers. This information had not been specifically collected by the federal government prior to the FFATA requirement.
For the procurement community, the Federal Acquisition Regulation (FAR) Subpart 4.14 was updated to allow for the collection of this information from prime and subcontractors.
For the financial assistance community, the Code of Federal Regulations was also updated to allow for the collection from prime and subrecipients (2 CFR Part 170). 2 CFR Part 170.320 defines the federal assistance vehicles subject to this reporting requirement.
When the definition of “total compensation” was established during the proposed FAR rule, to ensure consistency it was compared to other definitions of types of “compensation” that already existed in FAR Part 3 related to improper business processes and personal conflicts of interest and Part 31 related to cost principles and allowable costs. The term “executive” was also established defined as a part of the proposed rule, and it was compared to FAR Part 3 to ensure consistency.
There were no concerns raised or alternative definitions suggested by representatives of the procurement and financial assistance communities. The definitions have been through the public rulemaking process, and there are no known issues with the definitions.
| Recommended Data Element Name | Recommended Definition | Type of Data Element | Format/Length |
|---|---|---|---|
| Highly Compensated Officer First Name | The first name of an individual identified as one of the five most highly compensated "Executives." "Executive" means officers, managing partners, or any other employees in management positions. | Text | Alphanumeric; 35 characters |
| Highly Compensated Officer Middle Initial | The middle initial of an individual identified as one of the five most highly compensated "Executives." "Executive" means officers, managing partners, or any other employees in management positions. | Text | Alphanumeric; 1 character |
| Highly Compensated Officer Last Name | The last name of an individual identified as one of the five most highly compensated "Executives." "Executive" means officers, managing partners, or any other employees in management positions. | Text | Alphanumeric; 35 characters |
| Highly Compensated Officer Total Compensation | The cash and noncash dollar value earned by the one of the five most highly compensated “Executives” during the awardee's preceding fiscal year and includes the following (for more information see 17 CFR 229.402c2): salary and bonuses, awards of stock, stock options, and stock appreciation rights, earnings for services under non-equity incentive plans, change in pension value, above-market earnings on deferred compensation which is not tax qualified, and other compensation. | Amount | Numeric; 38 characters |