Archive for September, 2010
Federal agencies now have a new standard report they may use to collect information about the status of real property funded with federal assistance awards. On September 16, the General Services Administration (on behalf of the Grants Policy Committee) released the new Real Property Status Report.
The as-yet-unnumbered standard form has four parts – a cover page and three attachments. Attachment A is for General Reporting, Attachment B is a Request to Acquire, Improve or Furnish property, and Attachment C is a Disposition Request.
The final form is different from the draft released last November and was changed in response to comments from the federal agencies and the grantee community.
To view the Federal Register notice, the comments and responses on the draft, and the form itself, click here.
I just learned that OMB is sponsoring a webinar to discuss the new Transparency Act (FFATA) subaward reporting requirements. The Town Hall Meeting is Thursday, Sept. 23, from 10-noon. For more information, click here.
Today the Office of Management and Budget issued regulations requiring federal agencies to include new award terms in their grants and cooperative agreements.
First, agencies must now include language requiring applicants to have DUNS numbers and to maintain current registration in the CCR. The term will be included in awards for grants and cooperative agreements effective Oct. 1 2010, while the deadline for other assistance recipients – such as those receiving loans, subsidies, insurance, food, and “direct appropriations” – is Oct. 1, 2011. The actual award term is included in the appendix to the regulation.
The new DUNS/CCR regulation is located in 2 CFR Part 25.
OMB also published an interim final regulation regarding the new award term for the Transparency Act subaward reporting requirement. This new term is located in 2 CFR Part 170 (Note: this location is different than the one originally proposed by OMB in 2008: Part 33. Under the revised Title 2 structure, Part 33 is now preaward, so the new Transparency Act term will be located in Part 170, which is the national policy section.)
OMB notes that this new CFR part provides standard wording for an award term (also included as an appendix) that each agency must include in grant and cooperative agreement awards it makes on or after Oct. 1, 2010. There is a distinction between this and the operational details on what and how to report. That format and information proposal was issued as an information collection request by the General Services Administration on July 23. This current regulation is simply the award term that notifies recipients of their responsibilities for reporting information about first-tier subawards and executive compensation.
The Transparency Act’s definition of ‘‘federal award’’ includes multiple types of financial assistance awards, but only subawards under grants and cooperative agreements need to be reported at this time. Subawards under all types of financial assistance will need to be reported at a later date, which OMB will explain in future memoranda, according to the notice.
You can view the OMB notices here.
In another new memo promoting open government, OMB offers details of how the fast-approaching Transparency Act subaward reporting process will work and the related responsibilities of federal agencies, prime grantees, and subgrantees.
For example, in any new awards issued as of October 1 2010, federal agencies must include a new award term that delineates the Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements.
Prime grantees will be required to register in two systems to meet the act’s subaward reporting requirements: the Central Contractor Registration, and the FFATA Subaward Reporting System (FSRS). (FSRS was set up as the portal for Transparency Act subcontract reporting and is now being used to also report subgrants.)
The memo also clarifies that subawardees are not required to do the actual reporting; that is the prime recipient’s responsibility. However, the subawardee is required to provide the prime with all of the information needed.
Further, entities that are already reporting this information for Recovery Act grants through FederalReporting.gov will not be required to duplicate that reporting in FSRS.
These are just a few examples of the information included in the memo. You can view and download the entire 51-page guidance here.