HB2917, known as the TRACKS Act, would amend the Federal Funding Accountability and Transparency Act of 2006 to require reporting of covered subawards. A covered subaward includes any subaward awarded to an entity located in a foreign country of concern or to a foreign entity of concern, with the prime award recipient responsible for disclosure in the same manner as other subawards.
The act also directs the Director to issue guidance within 90 days after enactment to standardize data disclosure across agencies and recipients. The core aim is to improve visibility into how taxpayer dollars flow to adversarial actors and foreign entities of concern, supporting stronger oversight and risk management across federal awards.
At a Glance
What It Does
Adds a new category called covered subaward to FFATA, defining it as subawards to foreign countries of concern or foreign entities of concern and requiring their data to be disclosed by the subrecipient in the same manner as standard subawards.
Who It Affects
Federal agencies administering awards, prime award recipients that pass funds to subrecipients, and any subaward recipients including entities located abroad.
Why It Matters
Increases transparency around foreign-directed spending within federal programs, closes data gaps, and lays groundwork for consistent cross-agency reporting and oversight.
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What This Bill Actually Does
The TRACKS Act would widen the scope of the Federal Funding Accountability and Transparency Act by adding new reporting requirements for foreign subawards. It defines what counts as a subaward and introduces the concept of a covered subaward, targeting awards sent to foreign countries of concern or foreign entities of concern.
Prime award recipients would be responsible for disclosing these data in the same way that other subawards are disclosed today, ensuring visibility into where federal dollars go when they reach non-U.S. actors. The bill also requires the Director to issue guidance within 90 days of enactment to standardize how this information is reported, creating consistency across agencies.
By rendering these transactions more visible, the measure aims to bolster oversight, risk assessment, and the ability to identify potentially troubling spending patterns. The definitions used rely on previously established NDAA 2021 provisions to determine what counts as a country or entity of concern.
The TRACKS Act does not, on its face, change funding levels or program eligibility; it changes reporting obligations to illuminate spending tailpaths to international actors of concern.
The Five Things You Need to Know
The bill adds a new concept called covered subaward to FFATA.
Covered subawards are those to entities located in foreign countries of concern or foreign entities of concern.
A covered subaward requires data disclosure by the recipient in the same manner as other subawards.
The Director must issue guidance within 90 days after enactment to standardize reporting data.
Definitions of foreign country of concern and foreign entity of concern rely on NDAA 2021 Thornberry provisions.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title and purpose
This section provides the act's official title; TRACKS stands for Tracking Receipts to Adversarial Countries for Knowledge of Spending. It clarifies the intent to track taxpayer dollars and to increase transparency around spending that might reach adversarial foreign actors. The sectionframes the bill as a modernization of reporting requirements within the FFATA framework to support stronger oversight.
Definitions added for subawards
The bill adds a definition of subaward to FFATA. A subaward is an award passed by a pass-through entity to a subrecipient for part of a Federal award, and it can flow from one subrecipient to another. Payments to a beneficiary of a Federal program are explicitly excluded from being a subaward. This lays the groundwork for distinguishing traditional subawards from foreign-directed transfers.
Reporting of foreign subawards and agency guidance
This provision creates the category of covered subaward and defines it to include subawards awarded to entities located in a foreign country of concern or to a foreign entity of concern. It requires the recipient of a covered subaward to disclose data about the subaward the same way as other FFATA subawards. It also mandates that the Director issue guidance within 90 days of enactment to establish data consistency and disclosure standards for agencies, prime award recipients, and covered subaward recipients.
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Explore Government in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Federal agency award offices gain clearer visibility into foreign-directed spending, supporting risk assessment and compliance oversight.
- Audit and inspection bodies (GAO, Inspectors General) obtain more complete data for investigations and reporting.
- Researchers and policy analysts gain more granular data to study spending patterns and national security implications.
Who Bears the Cost
- Prime award recipients (pass-through entities) shoulder added reporting obligations and potential IT/system adjustments.
- Subaward recipients, including international partners, face new data disclosure demands and potential compliance overhead.
- Federal agencies must develop, maintain, and harmonize data standards and IT capabilities to capture and report the new information.
Key Issues
The Core Tension
The central dilemma is balancing the goal of transparent spending with the administrative burden and risk of mislabeling that a broad, cross-agency requirement could entail.
The TRACKS Act introduces a substantive expansion to FFATA reporting by requiring disclosure of covered subawards to foreign countries of concern and foreign entities of concern. While this enhances visibility into federal spending, it also raises questions about data standardization, the accuracy of foreign-entity classifications, and the administrative burden on award recipients.
The 90-day guidance deadline gives agencies a tight window to harmonize definitions, data fields, and submission processes across disparate programs, which may be challenging given existing IT infrastructure and reporting practices. There is potential for misclassification or over-reporting if the terms foreign country of concern or foreign entity of concern are interpreted inconsistently, underscoring the need for precise implementation guidance and robust verification protocols.
Finally, the measure interacts with ongoing NDAA 2021 authorities, meaning the definitions it relies on may evolve, requiring ongoing alignment across statutes.
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