Grants Blog

Archive for the ‘Streamlining’ 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.

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.

This week Congress will vote on a continuing resolution to fund the federal government for the remainder of the current fiscal year. I’ve been looking at the proposal and noticed a few things that might be of interest to grants professionals.

First, while the theme of transparency and accountability grow, Congress is planning to slash funding for electronic government initiatives by about 75 percent. This would impact sites such as USAspending.gov where the public has access to information about federal aid recipients. With only $8 million to spend on e-gov, federal officials would have to make some tough choices about which transparency sites to maintain and which ones to shut down or scale back.

The second interesting tidbit is that the funding proposal would implement an across-the-board cut for all non-defense programs, but agencies would still have discretion over the funding levels for many of their individual programs.

Finally, one of the federal government’s innovation efforts is being de-funded. The Partnership Fund for Program Integrity Innovation would be zeroed out, with only enough funding to cover the projects OMB already committed to. This initiative, originally funded $34 million, was intended to support innovative programs that promoted efficiency and cooperation among federal agencies and states, local governments , and nonprofit organizations.

So, those are my first thoughts on this massive spending package for FY 11. Anyone else have comments they would like to share?

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?

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.

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. 

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.

Now is your last chance (probably) to comment on the proposed governmentwide standard Tangible Personal Property Report Form (SF-428).

Yesterday (March 25), the General Services Administration issued a Federal Registernotice inviting comments on the form and announcing that it is sending it for final information collection review before making the form available for governmentwide use. This form is a result of the government’s ongoing streamlining effort which includes issuing standard grants management reporting forms for all agencies to use.

GSA originally published the form in 2008, and received a handful of comments on it. In response, the agency made a few small changes – it clarified the instructions and numbered the attachments.

Comments are due April 26.

To view the announcement, click here.

The Office of Management and Budget is accepting comments on a set of proposed regulations that would impact several parts of the governmentwide grants administration process.

While the impetus for the proposed new rules is a legislative mandate to create a governmentwide database of information about large, potentially high-risk grantees, OMB’s proposal also addresses other areas, especially preaward. It represents the office’s ongoing efforts to relocate governmentwide guidance into one central location – Title 2 of the Code of Federal Regulations.

In many cases OMB’s proposal would simply codify existing policy. For example, a proposed new 2 CFR Part 25 would implement existing OMB guidance regarding the use of DUNS numbers. This guidance is currently in two separate OMB policy memoranda. This is just one example of what is included in the proposed regulations; there are many others.

The proposal would create or amend 2 CFR Part 25, DUNS/CCR registration; 2 CFR Part 27, program announcements; 2 CFR Part 35 postaward responsibilities; 2 CFR Part 77, termination; and 2 CFR Part 180, suspension and debarment.

As for the new database (mandated by the 2009 Defense Authorization Act) it would include information about grantees and subgrantees that receive more than $10 million in federal assistance. Those recipients would 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.

Comments are due April 19. To read the full OMB announcment, click here.

The proposed changes, along with other Title 2 developments, will be covered in our upcoming Federal Grants Update 2010 seminar. For dates and locations, click here.

The National Science Foundation – on behalf of the Grants Policy Committee and the Research Business Models Subcommittee – is accepting final comments on the new governmentwide Research Performance Progress Report (RPPR) format, while at the same time putting the format out for use by federal agencies.

In a Federal Register announcement, NSF said agencies may now use the new standard format, which is designed to help streamline the reporting process for grantees as well as allow federal awarding agencies to more easily analyze, compare, and compile research program information.

NSF says it expects this to be the last opportunity for public input before the reporting format is finalized. Comments may be submitted until February 12 via email to Suzanne Plimpton, splimpton@nsf.gov.

You can access the FR notice inviting comments here.

Our annual Federal Grants Update seminar will have additional information about this new report, as well as other developments in grants management. Dates and locations of the one-day seminar will be announced soon. Watch this blog or visit our website www.managementconcepts.com/grants for future information.