Grants Blog

Archive for the ‘Grantseeking’ Category

Beginning in August, federal agencies will have to “test” new or revised forms to ensure that the forms and instructions are clear and easy for users to understand.

This requirement was issued by OMB’s Office of Information and Regulatory Affairs (OIRA) through an August 9 memo to the heads of all federal agencies. In the text of that memo, OIRA Administrator Cass Sunstein wrote:

“With respect to Federal forms, simplicity and ease of comprehension are exceedingly important. In recent years, agencies have made important efforts to simplify and streamline forms and, where appropriate, to eliminate them. Despite these efforts, it is a continuing challenge for agencies to minimize complexity and confusion. The purpose of this memorandum is to help agencies to meet that challenge by testing whether forms are sufficiently clear and comprehensible.”

Agencies will test forms either before issuing them for public comment or during the OIRA review. This testing should: ensure that the forms are not unnecessarily complex, burdensome, or confusing; help agencies obtain reliable information about the likely burdens on members of the public; and identify ways to reduce burdens and to increase ease of comprehension.

Advance testing might include focus groups, in-person observations of users’ perceptions of the forms and questions (cognitive testing), web-based experiments, and randomized controlled experiments.

A copy of the memo, which includes links to several guidance documents and resources for federal agencies, is available at
www.whitehouse.gov/omb/inforeg.

Deployment of SAM, the new System for Award Management, is being delayed until late July.

SAM is a project sponsored by GSA that will consolidate numerous grants and contracts databases into one location. This consolidation will give users one central point for finding information, and also one login site for accessing data currently housed on sites such as EPLS, CCR and numerous others. GSA originally planned to launch Phase 1 of the project in late May, but is now indicating that it will be late July before it goes live.

For more information, go to www.SAM.gov.

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/.

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

The Office of Management and Budget is working on a draft “omnibus circular” that would consolidate and revise the current uniform administrative requirements, cost principles, and audit circulars.

While details are sketchy, the new circular could represent a significant change for grants management. For example, OMB may raise the single audit threshold, consolidate the current cost principles into one set, and set standards for merit-based reviews of grant applications.

OMB officials say a Federal Register notice inviting comments on the proposal will be published before the end of February. You will have 60 days to comment, and then OMB will review all of the input before issuing a second notice. If all goes according to OMB’s schedule, the new circular could be in effect by early fall. However, for those of us in the grants management community, we know this is an ambitious goal. Nonetheless, I wanted to give everyone a heads-up about the coming notice so you can be prepared to submit comments.

Keep watching this blog for more information. In addition, our annual Federal Grants Update seminar will cover this proposal in detail once it is published.

We’ve just posted information about our annual Federal Grants Update course to the Management Concepts web site. This one-day seminar is a great way to keep track of the latest developments in grants management and to learn about pending changes that may impact your day-to-day grants work.

This year we’ll be discussing OMB’s plans for consolidating and revising the grants management circulars, new grants oversight boards, A-133 audits, suspension and debarment, and much more.

Classes start the first week in April and run throughout the summer in cities around the country. We can also bring the course to your location. Visit the web page here for additional information about the topics that will be covered, locations and dates, and registration information. And if you have any other questions, feel free to contact me.

There has been a lot of talk in Congress about grants accountability, but mostly in the realm of post-award administration. Now comes a bill that addresses those topics before an award is made. HR 3433, the s-called GRANT Act, would call for some rather dramatic shifts in the way discretionary grants are awarded.

For example, federal agencies would have to establish and publish merit-based selection criteria. And before an award is made, agencies would have to evaluate whether the applicant is capable of properly managing federal awards and successfully completing the project. This seems fairly noncontroversial to me and aligns with current OMB circulars and administrative requirements.

But the legislation would make all of the preaward information available to the public — everything from the applicant’s proposal to the award notice and the final award decision and applicant rankings.

Further, agencies would post each recipient’s final report on a public website, along with any other information that could be useful to “future researchers or the public.”

As for A-133 single audits, the proposed legislation would require OMB to report on how the process could be made more useful and efficient, something OMB has been working on for years.

This legislation, which you can read here, is just now beginning to make its way through Congress, but I thought some of the above points are very interesting and show lawmakers’ continued interest in grants. Do you see anything else in the bill that you find interesting?

The Office of Management and Budget has just created a new Council on Financial Assistance Reform to ”foster more efficient and effective federal financial management.”

The council will work with the Government Accountability and Transparency Board and federal agencies to:

• coordinate the development and implementation of a standardized business process, data standards, and IT
• work with key stakeholders  to eliminate unnecessary regulatory, reporting, and grant agreement requirements and increase flexibilities for satisfying grant requirements;
• identify emerging issues in grants management and policy; and
• serve as a clearinghouse of information on innovations and best practices in grants management.

The council replaces the Grants Policy Committee which was established in 1999 and the Grants Executive Board which was established 2004.

I’ll keep you posted on any new developments and council actions as they occur.

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.

According to a recent post on the Grants.gov blog, the installation of new hardware and software at the Central Contractor Registry has caused a severe processing backlog.

Both new CCR registrants and those looking to renew their current registration are being affected. Although the technical problems at CCR  have been resolved, there is still a backlog and the delay could impact an entity’s ability to submit a timely grant application through Grants.gov.

Applicants experiencing delays are encouraged to contact the relevant federal awarding agency for guidance.