Grants Blog

Archive for the ‘reporting’ 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.

Earlier this year there was a flurry of activity and far-ranging discussion surrounding a new DATA Act, legislation that would impose strict new reporting requirements on federal agencies and grant recipients.

But what happened to that proposed measure?

Apparently, it has died in the Senate.

During a Sunday morning talk show, Rep. Darrell Issa, the bill’s primary sponsor in the House, was discussing the Republican agenda when he said “we want to be jobs and the economy,” Issa said. “The Data Act passed unanimously out of the House, and it’s died in the Senate. That would bring greater transparency and accountability and save money. We have those issues we’re working on.”

If the measure does see any action in the Senate, we’ll let you know.

With the buzzwords “accountability” and “transparency” cited over and over, the House yesterday approved the DATA Act, a measure that would impose strict new reporting requirements on federal agencies and grant recipients.

Recipients would have to report at least quarterly on receipt and use of federal funds. Similarly, federal agencies would have to report at least quarterly on all obligations and expenditures of federal funds. The Treasury Department would also report federal agency obligations and expenditures, and all of this information would be identified by program, budget category, or other Treasury account number so that it could all be easily compared.

An interesting provision in this legislation is that it would not waive the reporting requirements for entities that receive small awards; only certain individuals would be exempt.

The House also attempted to put some teeth behind the measure by allowing federal agencies to impose penalties of up to $250,000 on recipients who fail to meet the reporting requirements. To enforce agency reporting, OMB would be directed to issue guidance requiring compliance with the new act.

The Data Accountability and Transparency Act (HR 2146) would also create a new oversight panel, the Federal Accountability and Spending Transparency Commission. This commission would have extensive power. For example, it would establish reporting deadlines, specify the data elements and the format of reports, and issue guidance to federal agencies and recipients on compliance with the new law.

Also, rather than repealing the Federal Funding Accountability and Transparency Act, as was originally proposed in the House bill, the measure that members approved yesterday would amend that legislation by aligning it with the new reporting and transferring control over FFATA reporting and USAspending.gov from OMB to the new council.

A companion measure was introduced in the Senate earlier this year, but is still awaiting action in the Committee on Homeland Security and Governmental Affairs.

This month the National Institutes of Health will begin pilot testing the new governmentwide Research Performance Progress Report (RPPR).

Seven institutions will pilot the RPPR for NIH beginning in April 2012. During the initial pilot the RPPR will be used only for progress reports under awards that do not require submission of an annual detailed budget (i.e., awarded under the Streamlined Noncompeting Award Process or SNAP) and for individual fellowships. NIH anticipates expanding the pilot in the summer of 2012 to include all Federal Demonstration Partnership (FDP) institutions.

Grantees will complete the RPPR electronically through the eRA Commons. Although the information that grantees will provide is not significantly different from what is currently reported, the format of the RPPR will be new to NIH grantees. The RPPR will consist of a series of 8 screens where grantees will answer questions using a checkbox, by entering text or uploading a PDF, or selecting “Nothing to Report.”

The timing of full implementation of the NIH RPPR will be determined based upon the success of the initial pilot.

For additional information, visit the NIH RPPR web site.

I picked up some very interesting information about the DATA Act at last week’s NGP webcast.

According to Cornelia Chebinou (NGP co-chair and the director of NASACT’s Washington, DC office) The legislation that will eventually be debated on the full House floor will be significantly different than the measure that came out of the House committee. The House is using a “manager’s amendment” to make significant changes to the bill. There were few details on what the changes would be, but one thing that was mentioned was the fact that the bill will no longer repeal FFATA.

Also, bill sponsor Rep. Darrell Issa asked Majority Leader Rep. Eric Cantor to bring it to House floor as soon as possible once the amendment is done. The Senate has said it won’t act on the bill until it sees what comes out of the House.

So we might have a case of wait, wait, wait, and then some very swift action.

Just as a reminder, the DATA Act in its current form would require all recipients of grants, loans and contracts (with some exceptions for small-dollar recipients), as well as federal agencies to provide transaction information about those awards at least quarterly. A new Federal Accountability and Spending Transparency Board would set the standards for the data and would compile, analyze and publish the information.

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

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.

The Office of Management and Budget has approved a new Real Property Status Report Form, providing grantees with a governmentwide form for reporting on real property status or seeking disposition instructions.

The General Services Administration published the form (SF-429) as interim final last September, but OMB returned it to GSA in December 2010 for further revisions. OMB has now approved the revisions.

The report has a cover sheet and three attachments: A. General Reporting; B. Request to Acquire, Improve or Furnish; and C. Disposition or Encumbrance Request.

On the new form, GSA:

Here is a link to the new form and instructions.

Do you have comments on the usefulness of the Federal Financial Report (SF-425), how it could be improved, other ways to collect the same information, or similar ideas about the collection of financial information? Well, OMB wants to hear from you.

In the July 28 Federal Register, OMB invited comments on the renewal of the SF-425. OMB is currently not planning to make any changes to the data collection form, but in the notice, it specifically said it was interested in receiving comments on:

“How the SF–425 and SF–425A are an improvement over the data collections they replaced (SF–269, SF–269A, SF–272, and SF–272A); how using a specification for a data exchange or other data model instead of structured forms could facilitate the submission and collection of the financial data identified in the SF–425 and SF–425A; and any proposals, use cases, specifications, or models for eliminating redundancies in reporting grant financial information and increasing its usefulness regardless of how the financial information is reported (form, data input, system-to-system, etc.).”

Comments are due September 26 and can be sent through www.regulations.gov. Click here to read the FR notice.

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.