Grants Blog

Archive for June, 2011

Federal agencies are asking for your help in finding ways to reduce the administrative burdens and costs associated with cost principles compliance in federally sponsored research projects. Colleges, universities, grants offices, associations, and others involved in research have until July 28 to offer their ideas.

For several years, a federal interagency task force has been looking at 2 CFR 220 (Circular A-21) with respect to its application in federally sponsored research at educational institutions. That task force has gathered preliminary information on areas that could be improved, and is now inviting the public to offer their comments on these issues. Specifically, the task force is seeking input in the following areas:

• effort reporting,
• recovery of direct costs associated with administrative and project management support for investigators,
• institutional eligibility for the Utility Cost Adjustment,
• consistency among agencies that establish governmentwide
  F&A rates,
• programs with F&A reimbursement at other than governmentwide rates,
• rationalization between agencies of regulations and reporting requirements
• audits of research institutions and awards, and
• definitions of general and research equipment

All comments must be submitted electronically to:

http://grants.nih.gov/grants/guide/rfi_files/a-21/add.htm

You can read the full request for information here.

The task force plans to produce a summary of the suggestions by September, and will then begin to draft a set of recommendations that it will forward to OMB for review.

Yesterday, a House subcommittee held hearings on “Improving Oversight and Accountability in Federal Grant Programs.” Officials from OMB, GAO, federal agencies, and the private sector all testified. And while (in my opinion) there was not a lot of new information or new ideas, the fact that Congress is now paying more attention to grants management is a fairly significant development.

So here is a link to the subcommittee’s website, where you can find testimony and watch a recorded version of the hearing.

I’m curious to see what action Congress, agencies, or the administration actually take. What do you think? Will we see concrete steps toward improved effectiveness and use of single audits? Will there be changes in the preaward process? Will regulations be amended? Take a look at the testimony and let me know what you think.

It seems it is not a matter of whether, but when, the federal government will impose new reporting requirements on recipients of federal financial assistance. On the same day, President Obama issued a new executive order on the matter while a key member of Congress introduced legislation that could have a drastic impact on grants management.

Both the executive order and the legislation have the ultimate goals of increasing transparency (read increasing reporting) and reducing waste. And both are based largely on the lessons learned through the Recovery Act. So the impetus for the changes in transparency, accountability, and reporting is strong. The only questions that remain are how to reach those goals.

Obama’s initiative, which is being spearheaded by Vice President Biden, creates a new Government Accountability and Transparency Board to “provide strategic direction for enhancing the transparency of federal spending and advance efforts to detect and remediate fraud, waste, and abuse.”

Obama’s order goes to say that the board will “apply the approaches developed by the [Recovery Act Board] across government spending.”

Meanwhile, Rep. Darrell Issa, R-Calif., Chairman of the House Committee on Oversight and Government Reform, introduced the Digital Accountability and Transparency Act, or DATA Act.  His legislation would also create a permanent governmentwide accountability board, and would go further.

The DATA Act would require the new accountability board to establish common identifiers and consistent reporting standards for all federally collected data. It would also require all recipients of federal grants, contracts, and loans to report on their receipt and use of federal funds at least quarterly. Compliance would be a condition of receiving funds. And agencies could impose penalties of up to $250,000 on those that don’t report. (Does this mean OMB would need to amend the administrative requirements in Circular A-102 and 2 CFR 215?)

Finally, the legislation would repeal the Federal Funding Accountability and Transparency Act.

Information on Issa’s legislation is available here. To read the executive order, click here.

I’ve been looking at the recently released 2011 A-133 Compliance Supplement and found several items of interest (at least to me) that I thought I would pass along. 

OMB added a a new element to the core compliance requirements to alert auditors and program officials as to whether the reporting requirements of the Transparency Act apply to a particular program. The compliance supplement also explains that, at the current time, “this reporting at the program level may be “Not Applicable” for several different reasons: (1) there are no subawards under the program; (2) the program is exempt from this requirement because it is ARRA-funded; or (3) the program is other than a grant or cooperative agreement program. In the latter case, this designation may change once additional types of financial assistance are made subject to the Transparency Act’s reporting requirements.”

Also, when determining compliance with Recovery Act reporting requirements, auditors are only required to test for compliance with basic information such as the CFDA number and financial information such as expenditures. While the number of jobs created or retained is a required data element for Recovery Act reporting, OMB specifically says that the auditor is not required to test this data.

Feel free to post to our blog with anything else you may find of interest in the new Compliance Supplement.

Finally, the Office of Management and Budget has released the 2011 Circular A-133 audit guidance document.

As usual, new programs have been added, other programs have been deleted, and individual program descriptions have been updated. In addition, OMB has added guidance and references relating to Transparency Act reporting, and clarified reporting requirements and auditors’ responsibilities relating to Recovery Act funding.

Watch this blog for additional information in the future. In the meantime, go here to view or download the Compliance Supplement.

Enjoy!