Grants Blog

Archive for June, 2010

In an effort to stem payments to ineligible individuals and entities, President Obama has ordered federal agencies to check nearly half a dozen existing databases before making any financial assistance award – including grants.

In a June 18 presidential memo, Obama said that in the preaward phase, agencies must consult, where appropriate, the Social Security Administration’s Death Master File, the General Services Administration’s Excluded Parties List System, the Department of the Treasury’s Debt Check Database, the Department of Housing and Urban Development’s Credit Alert System or Credit Alert Interactive Voice Response System, and the Department of Health and Human Services’ Office of Inspector General’s List of Excluded Individuals/Entities.

OMB will issue guidance on exactly how agencies can meet the new preaward requirements and on the impact the eligibility check will have on funding decisions.

The memo also directs OMB to coordinate these databases, a so-called “Do Not Pay List,” with the new Federal Awardee Performance and Integrity Information System (FAPIIS) so that agencies can access them through a single entry point. (FAPIIS was mandated by the 2009 Defense Authorization Act and will include information about contractors and grantees (and subcontractors and subgrantees) that receive more than $10 million in federal assistance. Those recipients will 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.)

To view the presidential memo, click here.

President Obama’s themes of tying performance to funding, and tightening the discretionary budget belt will carry forward into fiscal year 2012 and beyond. In June 2010, OMB issued budget guidance to federal agencies that are now working to develop their FY 12 budget requests for submission to OMB. The guidance, which came in the form of two memos, directs agencies to “identify the programs and subprograms that have the lowest impact on your agency’s mission and constitute at least five percent of your agency’s [FY 10] discretionary budget.” 

In Memo M-10-19, OMB noted that agencies should not simply reduce spending across the board. Instead, agencies should aim to restructure their operations strategically. This should include eliminating low-priority programs and activities, re-engineering staffing plans, improving procurement and grants management processes, and strengthening IT and financial management.

 A follow-up memo, M-10-20, gave more insight into how these reductions are to be achieved. Agencies are to evaluate programs based on their impact on the agency’s mission and relevant administration initiatives. Agencies should consider whether the program has an unclear or duplicative purpose, uncertain federal role, a completed mission, or lack of demonstrated effectiveness, according to the June guidance. The intent is to identify those programs with the lowest impact. OMB emphasized that agencies were not to meet the five-percent low-priority program target with across-the-board reductions or incremental savings in administrative costs.

You can view both of the memos on OMB’s website. Also, remember that these and other recent developments in grants administration will be covered in our Federal Grants Update 2010 seminar which is currently running in locations around the country.