Grants Blog

The General Services Administration (GSA) is undertaking a federal acquisition streamlining effort that while targeted to contracting, will nevertheless have an impact on the grants community.

On May 29 GSA plans to move the functions currently hosted by the Central Contractor Registration (CCR) and the Excluded Parties List System (EPLS) into a new System for Award Management (SAM). SAM will consolidate nine acquisition databases that track pre- and post-award contract data across the entire federal civilian and Department of Defense acquisition communities. Included in this list of systems are several used by grantees and grantor agencies, such as CCR, EPLS, the FFATA (Federal Funding Accountability and Transparency Act) Reporting System (FSRS), and the Catalog of Federal Domestic Assistance (CFDA).

The intent of SAM is to take each of these systems and their myriad databases – which now have separate login functions (with the exception of CFDA), overlapping data, and various host locations – and move them into one system. Users will have one login, one source for data, and one central host (reducing maintenance and operation costs for the federal government). SAM is not merely a portal into existing systems. It is an integration of current capabilities, information, and functionalities.

The transition to SAM will be done in phases. Phase 1 – which includes EPLS and the CCR (along with other contract-related databases) — is set to go live May 29. According to the CCR website, the CCR site will go down May 23 and from that point on, its functions will be done through SAM. For entities that currently are registered in CCR, this will really not impact them at this moment. However, any entity that is registering for the first time and those that must re-register will now have to go through SAM.

Phase 2, scheduled for deployment from December 2012 through June 2013, will include the FSRS and CFDA. (GSA, through SAM, is planning to assume responsibility for the development and maintenance of the catalog.)

For more info, go to https://www.sam.gov/sam/ or https://www.bpn.gov/ccr/.

Now that the comment deadline on OMB’s grant reform proposal has passed, it’s time for the agency to move on to the next phase of the massive initiative: reading, analyzing, and acting on those comments.

In February, OMB released a set of draft “ideas” for reforming governmentwide grants management policies, affecting everything from how agencies announce notices of funding availability to audit requirements. The proposal is centered around two major themes: consolidating and revising the current eight circulars into one; and making that one circular applicable to all entities, regardless of their type.

More than 300 entities and individuals submitted comments on OMB’s list of ideas. As might be expected, opinions varied widely. Some supported the majority of OMB’s proposed reforms and said the changes were much needed, while others considered many of the changes to be detrimental to their grants management and federal program activities. Still others thought OMB did not go far enough in its proposal for revising the circulars.

OMB will use the feedback it received on these ideas to develop a proposed new circular (or amendments to current ones) that later this year will be published in the Federal Register for public comment.

OMB has indicated that it hopes to publish that notice in the fall of 2012, but that may be an ambitious schedule. OMB must review and prepare a response to each of those 300-plus comments. Then staff can begin to develop the specific draft reforms. Once the reform proposal has been vetted by federal agencies, OMB can then publish the notice of proposed rulemaking. That first notice will give the public 60 days to comment. After that 60-day period, the plan is to publish a final request for comments, giving another 30-day window for entities to respond to OMB’s proposed revisions.

With the buzzwords “accountability” and “transparency” cited over and over, the House yesterday approved the DATA Act, a measure that would impose strict new reporting requirements on federal agencies and grant recipients.

Recipients would have to report at least quarterly on receipt and use of federal funds. Similarly, federal agencies would have to report at least quarterly on all obligations and expenditures of federal funds. The Treasury Department would also report federal agency obligations and expenditures, and all of this information would be identified by program, budget category, or other Treasury account number so that it could all be easily compared.

An interesting provision in this legislation is that it would not waive the reporting requirements for entities that receive small awards; only certain individuals would be exempt.

The House also attempted to put some teeth behind the measure by allowing federal agencies to impose penalties of up to $250,000 on recipients who fail to meet the reporting requirements. To enforce agency reporting, OMB would be directed to issue guidance requiring compliance with the new act.

The Data Accountability and Transparency Act (HR 2146) would also create a new oversight panel, the Federal Accountability and Spending Transparency Commission. This commission would have extensive power. For example, it would establish reporting deadlines, specify the data elements and the format of reports, and issue guidance to federal agencies and recipients on compliance with the new law.

Also, rather than repealing the Federal Funding Accountability and Transparency Act, as was originally proposed in the House bill, the measure that members approved yesterday would amend that legislation by aligning it with the new reporting and transferring control over FFATA reporting and USAspending.gov from OMB to the new council.

A companion measure was introduced in the Senate earlier this year, but is still awaiting action in the Committee on Homeland Security and Governmental Affairs.

Federal awarding officials now have a new tool to help them confirm individual and entity eligibility before making any grant, loan, contract, or benefit payment. Launched today, the new Do Not Pay List web site is a single point of entry for accessing relevant data.

The portal allows federal agencies to to access data sources including the Death Master File, the Excluded Parties List System, Treasury’s Debt Check Database, and the List of Excluded Individuals and Entities. The site also offers data analysis of information from other sources that are not currently available through the portal, such as prison information and several privately available sources.

OMB Memo 12-11 directs federal agencies to submit to OMB a draft of the agency’s plan for using this new tool by June 30, 2012. OMB will review those plans and agencies will finalize them no later than Aug. 31,2012.

This month the National Institutes of Health will begin pilot testing the new governmentwide Research Performance Progress Report (RPPR).

Seven institutions will pilot the RPPR for NIH beginning in April 2012. During the initial pilot the RPPR will be used only for progress reports under awards that do not require submission of an annual detailed budget (i.e., awarded under the Streamlined Noncompeting Award Process or SNAP) and for individual fellowships. NIH anticipates expanding the pilot in the summer of 2012 to include all Federal Demonstration Partnership (FDP) institutions.

Grantees will complete the RPPR electronically through the eRA Commons. Although the information that grantees will provide is not significantly different from what is currently reported, the format of the RPPR will be new to NIH grantees. The RPPR will consist of a series of 8 screens where grantees will answer questions using a checkbox, by entering text or uploading a PDF, or selecting “Nothing to Report.”

The timing of full implementation of the NIH RPPR will be determined based upon the success of the initial pilot.

For additional information, visit the NIH RPPR web site.

Just a quick note: OMB is extending the deadline for submitting comments on its “Advanced Notice of Proposed Rulemaking” relating to the grants management requirements overhaul. The new comment deadline is April 30.

To read the original February 29 Federal Register notice describing OMB’s ideas for reforming grants management, click here.

I picked up some very interesting information about the DATA Act at last week’s NGP webcast.

According to Cornelia Chebinou (NGP co-chair and the director of NASACT’s Washington, DC office) The legislation that will eventually be debated on the full House floor will be significantly different than the measure that came out of the House committee. The House is using a “manager’s amendment” to make significant changes to the bill. There were few details on what the changes would be, but one thing that was mentioned was the fact that the bill will no longer repeal FFATA.

Also, bill sponsor Rep. Darrell Issa asked Majority Leader Rep. Eric Cantor to bring it to House floor as soon as possible once the amendment is done. The Senate has said it won’t act on the bill until it sees what comes out of the House.

So we might have a case of wait, wait, wait, and then some very swift action.

Just as a reminder, the DATA Act in its current form would require all recipients of grants, loans and contracts (with some exceptions for small-dollar recipients), as well as federal agencies to provide transaction information about those awards at least quarterly. A new Federal Accountability and Spending Transparency Board would set the standards for the data and would compile, analyze and publish the information.

We need your help to plan our upcoming class schedule and training. What classes would you like to see offered in various locations? Are there other cities where you think we should offer training? What new courses or products could we offer to meet your training and professional development needs?

Your answers to these and other questions will help us improve our grants management training curricula. Please take a few minutes to complete our online survey. We ask that you complete the survey by April 1. To access it, click here.

.Your feedback is greatly appreciated and is for informational purposes only.

Thanks.

Legislation has been introduced in both the House and Senate to update the nearly 75-year-old Hatch Act, a law that governs the political activities of federal, state, and local government employees.

The Hatch Act Modernization Act of 2012 would make three major changes:

• State and local government employees covered by the Hatch Act would be allowed to run for partisan elective office.

• The Merit Systems Protection Board (which rules on alleged Hatch Act violations) would have more options for penalties. Currently, the only penalty, regardless of the level of the infraction, is immediate termination. Under the proposed legislation, the board could also impose sanctions such as reprimands, suspensions, demotions, or fines.

• Employees of the District of Columbia would be subject to the same restrictions that apply to employees of state and local government agencies. Under the current act they are treated as federal employees.

It has been nearly 20 years since Congress revised the Hatch Act and supporters of the new legislation say the proposed changes are “common sense” revisions that are desperately needed. Do you have any thoughts on the Hatch Act?

I’ll be tracking this legislation as it moves through Congress, so keep watching this post.

As promised, OMB has set out a list of recommendations about ways to improve grants management — and now is your chance to comment. The notice appeared on OMB’s website earlier today, but the official version will not be published in the Federal Register until next Tuesday.

This “Advanced Notice of Proposed Guidance” briefly outlines the reform ideas OMB is considering, which could reshape the entire landscape of federal grants management.
OMB is targeting all aspects of grants management: audit, cost principles, and uniform administrative requirements. At this point, OMB is simply asking for feedback on these rather broad ideas. Using that feedback, it will then develop a detailed proposal that will be published in the Federal Register for further comment.

But now is the time to let your voice be heard. You have 30 days to comment on the ideas. To read the OMB announcement and to find out how to comment, click on the link below or watch the Tuesday Federal Register.

http://www.whitehouse.gov/sites/default/files/omb/financial/fr-notice-grant-reform-2012.pdf