A Year in Review for the Grants Community
December 19 marks the one year anniversary of the Office of Management and Budget (OMB) releasing the interim final rule for the Uniform Guidance. In the last year, the grants community has spent considerable resources in understanding the new requirements and ensuring compliance. In addition to the implementation of 2 CFR 200, there have been other notable developments that will affect grants administration in 2016 and beyond.
Let’s take a look back at the significant developments in the last year.
- December 26, 2014: 2 CFR 200 became applicable to all new Federal awards and existing awards that receive modified award terms and conditions
- February 18, 2015: OMB opened a public survey to gather feedback from non-Federal entities regarding implementation of 2 CFR 200. The survey closed on March 17, 2015.
- March 31, 2015: The Treasury Department updated USASpending.gov.
- May 8, 2015: OMB and the Treasury released 57 standardized data elements to implement the Digital Accountability and Transparency Act (DATA Act)
- May 27, 2015: The Chief Acquisition Officers Council (CAO) opened the National Dialogue and Pilot to Reduce Reporting Compliance Costs for Federal Contractors and Grantees. This dialogue allows the grants community to provide feedback on ways the Federal government can reduce compliance requirements.
- July 14, 2015: OMB released the 2015 Compliance Supplement, which modified the existing Matrix of Compliance Requirements, provided guidance for performing audits for awards under 2 CFR 200 and previous requirements, and removed guidance for internal controls.
- July 22, 2015: OMB published final guidance to implement the Federal Awardee Performance and Integrity Information System (FAPIIS) for Federal grant awards. Beginning on January 1, 2016, Federal awarding agencies will have to review FAPIIS to evaluate an applicant’s qualifications. OMB amended 2 CFR 200 to reflect the new FAPIIS requirements.
- August 6, 2015: Multiple agencies, including the Department of Education and Department of Justice, released proposed rules to modify existing requirements regarding grant awards made to faith-based organizations.
- August 31, 2015: OMB and the Treasury finalized the standardized data elements required under the DATA Act.
- September 10, 2015: OMB made technical corrections to 2 CFR 200. In addition to making editorial corrections to 2 CFR 200, OMB amended the Uniform Guidance to provide non-Federal entities a two-year grace period to comply with the new procurement standards. The Council on Financial Assistance Reform (COFAR) also released updated Frequently Asked Questions (FAQs) for 2 CFR 200.
- September 29, 2015: The COFAR released the 2014 Administrative Metrics to establish a baseline for evaluating the implementation of 2 CFR 200.
- September 30, 2015: The mandate for the Recovery Accountability and Transparency Board expired.
- October 1, 2015: The micro-purchase threshold increased from $3,000 to $3,500.
- October 8, 2015: OMB released the final Agency Priority Goals under the Obama Administration. expired.
- October 14, 2015: The National Science Foundation (NSF), on behalf of multiple Federal awarding agencies, released the proposed standardized Research Terms and Conditions for Federal research awards made under 2 CFR 200.
- November 9, 2015: OMB made correcting amendments to 2 CFR 200 regarding FAPIIS implementation.
- November 10, 2015: The Treasury released USASpending.gov, which is a preview of how USASpending.gov will eventually function to comply with the DATA Act.
- December 9, 2015: OMB published a notice in the Federal Register seeking public comments on the revised SF-SAC form.
This timeline of some of the key developments in grants management demonstrates why so many in the grants community have felt confused, energized, challenged, and perhaps even overwhelmed in the past year. Let’s hope 2016 is a little less hectic!