Grants Blog

Now that the Recovery Act is one year old, the Government Accountability Office is taking a look back — and a look forward — at how state and local agencies have used the money they received, and the efforts being made to improve accountability for those awards.

Most of the nearly 200-page report deals with specific programs and agencies, including Medicaid, Transportation, and Education, but GAO also addresses issues relating to recipient reporting, and a significant amount of attention to the OMB A-133 single audit process.

GAO seems generally pleased with OMB’s efforts to use single audits, although the office continues to urge OMB — and Congress — to amend the single audit process so that it can be more efficient and timely. And GAO has several agency-specific recommendations, such as encouraging the Education Department to work with OMB on a formula for determining FTE jobs during the summer months.

One new recommendation that should be of interest to most recipients is that OMB develop a “formal and feasible” framework for review of recipient reporting changes during the continual update period and consider providing more time for agencies to review and provide feedback to recipients before posting updated reports on Recovery.gov.

You can read the full GAO report here.

The Office of Management and Budget is accepting comments on a set of proposed regulations that would impact several parts of the governmentwide grants administration process.

While the impetus for the proposed new rules is a legislative mandate to create a governmentwide database of information about large, potentially high-risk grantees, OMB’s proposal also addresses other areas, especially preaward. It represents the office’s ongoing efforts to relocate governmentwide guidance into one central location – Title 2 of the Code of Federal Regulations.

In many cases OMB’s proposal would simply codify existing policy. For example, a proposed new 2 CFR Part 25 would implement existing OMB guidance regarding the use of DUNS numbers. This guidance is currently in two separate OMB policy memoranda. This is just one example of what is included in the proposed regulations; there are many others.

As for the new database (mandated by the 2009 Defense Authorization Act) it would include information about grantees and subgrantees that receive more than $10 million in federal assistance. Those recipients would have to provide information about any criminal convictions, civil penalties, or administrative actions against them. Self-reporting of that information would be included as a term and condition in grant awards.

Comments are due April 19. To read the full OMB announcment, click here.

The proposed changes, along with other Title 2 developments, will be covered in our upcoming Federal Grants Update 2010 seminar. For dates and locations, click here.

Information about Management Concepts’ annual Federal Grants Update seminar is now available.

This year we’ll be discussing transparency and accountability, audits, standard forms, and more.

These one-day classes start the first week in April and run throughout the summer in cities around the country. Click here to see dates, locations, topics, and registration options.

The National Science Foundation – on behalf of the Grants Policy Committee and the Research Business Models Subcommittee – is accepting final comments on the new governmentwide Research Performance Progress Report (RPPR) format, while at the same time putting the format out for use by federal agencies.

In a Federal Register announcement, NSF said agencies may now use the new standard format, which is designed to help streamline the reporting process for grantees as well as allow federal awarding agencies to more easily analyze, compare, and compile research program information.

NSF says it expects this to be the last opportunity for public input before the reporting format is finalized. Comments may be submitted until February 12 via email to Suzanne Plimpton, splimpton@nsf.gov.

You can access the FR notice inviting comments here.

Our annual Federal Grants Update seminar will have additional information about this new report, as well as other developments in grants management. Dates and locations of the one-day seminar will be announced soon. Watch this blog or visit our website www.managementconcepts.com/grants for future information.

The Grants Policy Committee is preparing a response to a GAO report about the timeliness of grant application submission through Grants.gov, and they want help from the public.

The GPC’s Preaward Workgroup is drafting an OMB response to the July GAO Report, “Grants.gov Has Systemic Weaknesses That Require Attention.” This workgroup is specifically focusing on the GAO recommendation regarding the timeliness of applications. Some of the issues being addressed by the GPC workgroup include what constitutes a timely application, how to notify applicants regarding the timeliness of applications, and handling of late applications.

While this is not a formal request for comments from the workgroup, it is an outreach effort designed to gather input from the grants community and offer stakeholders the opportunity to have their concerns and ideas reflected in the official OMB response.

Input can be provided through the GPC website at www.GPC.gov.

Well, as most of the nation’s capital braced last week for a weekend blizzard, the Office of Management and Budget was busy releasing new guidance on the Recovery Act reporting requirements.

The memo released late Friday afternoon targets three areas: steps that federal awarding agencies must take to ensure the quality of data being reported by Recovery Act recipients; how federal agencies are to deal with recipients who have not reported or who have persistent reporting problems; and how recipients are to calculate and report the number of jobs created or saved with Recovery Act dollars.

For example, federal agencies are now required to provide recipients with a specific list of data about their awards, such as award type, amount, award number, CFDA number, federal agency number, and TAS (Treasury Account Symbol) code. OMB also offers guidance on how agencies are to assess late and non-reporters, and how to submit that list, which will be published on Recovery.gov.

The interesting aspect of the guidance for recipients is that OMB has offered detailed, step-by-step instructions and examples for calculating jobs. Further, recipients are no longer required to report cumulative jobs data, but rather simply job information for the reporting period. 

You can view the new memo here.

Yesterday the House passed its version of a bill to reauthorize the Federal Financial Assistance Management Improvement Act, pushing OMB even more to create a one-stop web portal that would consolidate all grant application and management functions and standardize the process governmentwide.

The House version of S. 303 is similar to the Senate bill passed in March 2009. Both direct OMB to beef up Grants.gov so that it serves not only as a central location for grant applications, but also for grants management. The legislation continues the push for standardized reporting forms, and requires OMB to provide Congress with a list of those federal agencies that do not use the standard forms and the central management portal.

The House bill also would require the development of a single data standard for private sector entities to use to submit information to federal agencies, including grant applications and reports.

Because the Senate bill does not contain this language – and because of other differences – members of the House and Senate must now meet in conference to work out a comprise bill before the legislation can be sent to the White House.

We’ll keep you informed about this measure as it moves through Congress. Also, this and other grants-related developments will be covered in Management Concepts’ upcoming Federal Grants Update course. The annual course is offered around the country each spring and summer. Watch our website for details in the coming months.

On a new website, Partner4Solutions, the federal government is asking state and local governments for ideas on reducing improper federal payments.

The website and request for input are part of the Obama administration’s efforts to reduce the estimated $98 billion in improper payments made in fiscal 2009.

“We know that states and local governments are already addressing these issues head-on and have identified many innovative approaches. We see this as an opportunity to better understand some of the on-the-ground best practices. Please join us as a partner by contributing your ideas and suggestions,” the website says.

You can submit suggestions and learn more about the effort to reduce improper payments here.

Once again, the Office of Management and Budget is directing federal awarding agencies to step up their efforts to ensure recipients meet their reporting responsibilities under the Recovery Act. And for those recipients who don’t comply, federal agencies will be taking action.

In a new memo, OMB Director Peter Orzag says that while a large number of recipients did report on Recovery Act projects in the first reporting period, a significant number failed to do so. He reminded federal agencies that failure to report constitutes noncompliance with grant award terms and conditions, and may have serious consequences.

To address the issue, federal agencies must take further steps to ensure Recovery Act recipients understand their reporting responsibilities as well as the consequences of noncompliance. Agencies must not only identify each recipient that has not submitted timely reports, but must also contact these organizations, assess the severity of the noncompliance and determine what corrective actions are to be taken – up to and including termination of funding.

To read the OMB memo, click here.

Just a quick follow-up to the ACORN posting from last week.

The Justice Department in a new memo said the recent law that prohibits funding for the controversial nonprofit does not prevent federal agencies – specifically HUD – from honoring existing contractual obligations with ACORN.

The fiscal 2010 Continuing Appropriations Resolution states, “None of the funds made available by this joint resolution or any prior act may be provided to [ACORN], or any of its affiliates, subsidiaries or allied organizations.”

Justice said the language used by Congress is unclear and can be read several ways. The memo says lawmakers did not use correct appropriations terminology, instead relying on the word “provide” which has no specified meaning in federal appropriations law.

For those of you interested in this and related topics, Management Concepts offers a a one-day course, Appropriations Law for Federal Grants.