Archive for May, 2012

Some Progress Seen But Grant Closeout Remains A Challenge

Nearly $800 million in undisbursed federal funds remained in expired grant accounts at the end of fiscal year 2011, according to a new report from the Government Accountability Office. And while some agencies have taken steps to reduce that amount and speed the grant closeout process, more work needs to be done.

In a May 2012 follow-up to a 2008 report, GAO repeated its basic recommendation: OMB needs to establish governmentwide guidance for grant closeout.

In the 2012 report, GAO noted that while the total amount of undisbursed funds in FY 11 essentially equaled the amount reported in its previous study, the percentage of total grant funding that those funds represented was lower – meaning that agencies were doing a better job of getting rid of those unobligated monies and closing accounts.

For example, in February 2011, HHS established an interagency workgroup—the Accelerated Closeout Team—led by the Office of Grants and Acquisition Policy and Accountability to coordinate a departmentwide response in strengthening financial controls and accelerating the number of grant and contract closeouts.

“Our analysis shows that there has been an improvement in closing out expired grant accounts with undisbursed balances in PMS since our 2008 report,” GAO said in the report. Nevertheless, GAO continues “The presence of tens of thousands of expired grant accounts in PMS with no undisbursed funds remaining raises concerns that these accounts are not receiving sufficient attention. Reducing the number of accounts with zero balances remaining would help ensure that administrative and financial closeout—the final point of accountability for these grants—is being completed. It would also minimize the amount agencies pay in potential fees for maintaining these accounts, which can accumulate over time.”

If you are interested in learning about effective grant closeout, Management Concepts’ two-day Closeout of Grants for Federal Personnel will be helpful. This course provides students with a framework and actionable process for overseeing and conducting grant closeouts. Visit www.managementconcepts.com/grants for more information.

SAM Is Going Live Soon — And It Will Impact Grantees

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/.

330 Comments — Now What?

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.