Grants Blog

Archive for the ‘reporting’ Category

President Obama recently issued a memo to federal agencies that, in my opinion, could have a significant impact on grants management practices and policies.

In the memo, entitled Administrative Flexibility , Obama focused on two areas: coordination and collaboration efforts lead by OMB, and agency streamlining.

Two of the directives to OMB could be especially significant for entities involved in grants management. Obama directs the office to “review and where appropriate revise guidance concerning cost principles, burden minimizations, and audits for state, local, and tribal governments” in order to eliminate unnecessary, unduly burdensome, duplicative, or low-priority recordkeeping requirements.

OMB is also directed to work with agencies that administer overlapping programs and collaborate with state, local, and tribal governments to standardize, streamline, and reduce reporting and planning requirements.

Agencies’ efforts must focus on identifying regulatory and administrative requirements that can be streamlined, reduced, or eliminated, and specifying where and how increased flexibility could be provided to produce the same or better program outcomes at lower cost.

There are no timeframes established in the memo, so we don’t know when agencies or OMB will undertake these efforts.

But I think it will be interesting to see the final results.

What do you think?

Information about Management Concepts’ annual Federal Grants Update seminar is now available. This one-day course 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 GPRA, subaward reporting, transparency and accountability, audit guidance, presidential and congressional priorities, and 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. Click here to see dates, locations, topics, and registration options.

Congress has just approved major changes to the Government Performance and Results Act, pushing for not only better performance from federal agencies and programs, but also better reporting and more transparency.

The measure calls for federal agencies to identify their top priorities, publicly report program results, and identify ineffective and duplicative federal programs.

Each federal agency would designate a Chief Operating Officer and a Performance Improvement Officer with primary responsibility for pursuing cost-savings through the improved analysis and coordination of duplicative programs. These officials would also look at how to better coordinate administrative functions common to every agency, such as purchasing. However, the bill gives no specific direction to agencies on how to conduct any of these assessments.

Agency and governmentwide information relating to performance is to be posted to a new public website on a quarterly basis.

President Obama is expected to sign the legislation, the Government Performance and Results Modernization Act of 2010.

It’s nearly two years late, but information about subawards under federal grants is now available on the USAspending.gov website.

In early December, the site began posting subaward information associated with new prime grant awards over $25,000, as required by the Transparency Act. According to OMB, so far data on 930 subawards in areas such as health, food and nutrition, and transportation has been displayed.  OMB expects that number to grow very quickly as new information becomes available and new subawards are made.

I looked around on the site and tried several searches. The information you can get is pretty extensive and it is really easy to use – in my opinion. Anyone else looked at the site or have any thoughts about it?

Federal agencies now have a new standard report they may use to collect information about the status of real property funded with federal assistance awards. On September 16, the General Services Administration (on behalf of the Grants Policy Committee) released the new Real Property Status Report.

The as-yet-unnumbered standard form has four parts – a cover page and three attachments. Attachment A is for General Reporting, Attachment B is a Request to Acquire, Improve or Furnish property, and Attachment C is a Disposition Request.

The final form is different from the draft released last November and was changed in response to comments from the federal agencies and the grantee community. 

To view the Federal Register notice, the comments and responses on the draft, and the form itself, click here. 

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 another new memo promoting open government, OMB offers details of how the fast-approaching Transparency Act subaward reporting process will work and the related responsibilities of federal agencies, prime grantees, and subgrantees.  

For example, in any new awards issued as of October 1 2010, federal agencies must include a new award term that delineates the Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements.

Prime grantees will be required to register in two systems to meet the act’s subaward reporting requirements: the Central Contractor Registration, and the FFATA Subaward Reporting System (FSRS). (FSRS was set up as the portal for Transparency Act subcontract reporting and is now being used to also report subgrants.)

The memo also clarifies that subawardees are not required to do the actual reporting; that is the prime recipient’s responsibility. However, the subawardee is required to provide the prime with all of the information needed.

Further, entities that are already reporting this information for Recovery Act grants through FederalReporting.gov will not be required to duplicate that reporting in FSRS.

These are just a few examples of the information included in the memo. You can view and download the entire 51-page guidance here.

Well, it’s been a while since I posted to this blog, so this one will make up for the lack of frequency in the amount of volume.

I attended the Association of Government Accountants Professional Development Conference earlier this week and want to share a summary of some of the sessions I attended. My notes are fairly basic and lack some context, so if you need more info, please feel free to contact me directly (lhayes@managementconcepts.com), or post to the blog.

Here we go…

Grants Management Line of Business

Danny Werfel, Controller of OMB’s Office of Federal Financial Management, discussed the agency’s view of lines of business. While he was specifically speaking about financial management systems, the overall principles he discussed also may be applicable to the Grants Management Line of Business (GMLoB). OMB still believes in the concept, but has learned that the model of forcing agencies to move to a complete service center doesn’t work. Instead they are looking to focus more on “shared services.” For example, an agency may  share a vendor invoicing service with other agencies but would not have to migrate their entire financial system to a common source.

 Federal Grants Reporting

The implementation of the Federal Funding Accountability and Transparency Act’s subrecipient reporting requirements in October means a lot of things need to be changed, such as grant terms and conditions, according to Werfel. He said OMB is working on these changes, but gave no details on exactly what actions will be taken or when.

 He also specifically noted one of the most significant and pervasive Recovery Act reporting problems: subsequent reports from the same recipient on the same project often don’t get “linked.” For instance, a change in identifying information, such as a correction to a DUNS number or grant number, means reports are not connected to one another. Anyone looking at a particular entity or project might assume a recipient just stopped reporting on the project, and that another project was started. Werfel emphasized that federal agencies, recipients, and pass-through entities need to be aware of this.

 Recovery Act A-133 Pilot Demonstration Project

OMB plans a second A-133 Recovery Act pilot project that will be announced later this month (July). It will include more states, and probably different programs this time, according to John Fisher, of the HHS Office of Inspector General, and a lead in the implementation of the first pilot project. The second pilot is also likely to focus more on audit resolution. The Recovery Act requires federal entities to make management decisions on the findings that were reported in the pilot project within 3 months (March 31, 2010). But a significant number of the findings still had not been resolved as of July 8, he commented. (It’s important to note that slow and incomplete audit resolution by federal agencies came up in almost every grants session, and several presenters, including Danny Werfel, said OMB and Congress will be taking a close look at this issue.)

 On a side note, Gil Tran was supposed to make this presentation but was not at the conference because he was still working on the A-133 Compliance Supplement, which was supposed to be out “this week,” meaning July 15 or16. One interesting tidbit: Gil has to get sign-off from 19 different federal officials before he can release the supplement.

 Reducing Improper Payments

Werfel said one of the most promising and interesting ideas they are looking at to reduce improper payments is revising A-87 (2 CFR Part 225. the state and local cost principles) to allow states to recapture more indirect costs. This incentive would reward states that reduce improper payments by allowing them to keep more for administrative expenses and offset the costs of program administration. OMB is seriously looking at how A-133 audits can be used more effectively in preventing, rather than simply detecting, improper payments. This could mean anything from speeding up the audit timeline to focusing more on larger entities or larger grant programs. However, he gave no specifics on A-133 revisions.

 Werfel also told attendees that in the fall, OMB plans to launch a grant program to support innovative streamlining and grants management partnership projects. The goal is to promote efficiency while improving program services and is based on ideas submitted to Partner4Solutions.gov.

 Yellow Book Update

The Government Accountability Office is drafting a revised Yellow Book and expects that draft to be ready for public comment in late July or early August, with the final revision complete by February or March 2011. But those are moving targets because GAO is attempting to align the Yellow Book with AICPA standards, which are still in the process of being revised.

 Most of the changes that auditors will see are technical in nature or align Yellow Book requirements with other standards. But one area that will change is the standard for auditor independence. Marcia Buchanan, Assistant Director for Auditing Standards at GAO, said Chapter 3, on auditor independence, will be restructured. There will be a conceptual framework that will serve as a guideline for determining whether an auditor is independent, but there will no longer be a laundry list of prohibited activities. This will give auditors more flexibility and allow them to apply judgment in unique situations.

The Office of Management and Budget has issued yet even more guidance aimed at stepping up recipient reporting under the Recovery Act. And this time, the memo directs federal agencies to take very specific steps to enforce compliance.

Memo 10-17, issued May 4, details five specific steps awarding agencies must take and sets specific deadlines for doing so. Nothing in the memo is especially new, but the fact that OMB included deadlines for agency actions is noteworthy. In summary, federal agencies must notify their recipients of the reporting requirements, contact and report on those entities that don’t comply, enhance oversight for persistently noncompliant grantees, and enforce compliance through all means available to them.

If you want to read the details of the memo, click here.

Nearly four years after it was enacted, the Federal Funding Accountability and Transparency Act is once again on OMB’s radar. According to a recent memo, OMB is revamping the USAspending.gov site, creating a new mandate for ensuring the accuracy of Transparency Act data, and perhaps most notably, establishing a deadline for agencies to begin reporting subaward information.

Agencies have been reporting primary recipient award data to USAspending.gov for several years, but now they must begin to collect and report subaward data by October 1 of this year. (That information was supposed to have been available more than two years ago.) This subaward reporting requirement only applies to new awards made on or after that date, and only to first-tier subrecipients.

The information to be collected is similar to what is already being reported for Recovery Act awards, with one notable exception. The Transparency Act requires that entities report the names and total compensation of the five most highly compensated officers if the entity received 80 percent or more of its annual gross revenues in federal awards and $25 million or more in annual gross revenues from federal awards; and if the public does not have access to compensation information through IRS or SEC records.

Well, there is much more to this new OMB memo and it will take more time for me to wade through it all and digest the information. But I wanted to let you know about it as soon as possible. You can read the complete guidance by clicking here.

And remember, we’ll be covering this, as well as other developments, in our Federal Grants Update class. You can find dates and locations of this one-day seminar by clicking here.