Grants Blog

Archive for the ‘Grantseeking’ Category

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.

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 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.

In a new memo, OMB has directed all federal agencies to once again begin using Grants.gov now that the portal has been upgraded and is capable of handling a large influx of proposals. The system was overwhelmed last year after enactment of the Recovery Act, and OMB had allowed agencies to move away from Grants.gov and to use alternative methods for receiving applications.

But according to the memo, recent upgrades and planned improvements have alleviated any risk that Grants.gov might fail and all agencies must move back to Grants.gov for receipt of applications by the end of April.

OMB also notes in the memo that the departments of Energy and Interior are conducting a “proof of concept” that would use the FedBizOpps.gov contracting platform for grants. However, OMB gave no details about the effort and said it expects to have results of the test sometime this summer.

The Grants Policy Committee is preparing a response to a GAO report about the timeliness of grant application submission through Grants.gov, and they want help from the public.

The GPC’s Preaward Workgroup is drafting an OMB response to the July GAO Report, “Grants.gov Has Systemic Weaknesses That Require Attention.” This workgroup is specifically focusing on the GAO recommendation regarding the timeliness of applications. Some of the issues being addressed by the GPC workgroup include what constitutes a timely application, how to notify applicants regarding the timeliness of applications, and handling of late applications.

While this is not a formal request for comments from the workgroup, it is an outreach effort designed to gather input from the grants community and offer stakeholders the opportunity to have their concerns and ideas reflected in the official OMB response.

Input can be provided through the GPC website at www.GPC.gov.

Yesterday the House passed its version of a bill to reauthorize the Federal Financial Assistance Management Improvement Act, pushing OMB even more to create a one-stop web portal that would consolidate all grant application and management functions and standardize the process governmentwide.

The House version of S. 303 is similar to the Senate bill passed in March 2009. Both direct OMB to beef up Grants.gov so that it serves not only as a central location for grant applications, but also for grants management. The legislation continues the push for standardized reporting forms, and requires OMB to provide Congress with a list of those federal agencies that do not use the standard forms and the central management portal.

The House bill also would require the development of a single data standard for private sector entities to use to submit information to federal agencies, including grant applications and reports.

Because the Senate bill does not contain this language – and because of other differences – members of the House and Senate must now meet in conference to work out a comprise bill before the legislation can be sent to the White House.

We’ll keep you informed about this measure as it moves through Congress. Also, this and other grants-related developments will be covered in Management Concepts’ upcoming Federal Grants Update course. The annual course is offered around the country each spring and summer. Watch our website for details in the coming months.