Grants Blog

Posts Tagged ‘grants management’

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.

Just a quick note regarding the Supreme Court ruling on the health care act and its potential impact on federal grants.

Part of the decision expressly addresses the issue of whether Congress has the authority to set conditions upon the receipt of grants. The short answer is: yes, it can, as long as those conditions do not constitute “coercion.”

The Court said that in this case, the threat of withholding 100% of Medicaid funding from states that did not want to participate in the expanded coverage program was coercion and was therefore unconstitutional. However, it did not clarify if withholding lesser amounts was coercion or simply “persuasion” — which is permissible. (The Court indicated that “persuasion” was permissible when it ruled that Congress had the authority to withhold highway construction funding — which totaled about 5% of state funding — from states that did not raise the drinking age to 21).

So the Court’s health care decision leaves a lot of room for discussion, interpretation and perhaps even future legal challenges. At what point does “persuasion” become “coercion?” Does this logic apply to all grants and cooperative agreements or just certain essential services? And so forth.

We’ll be taking a closer look at this issue in our Federal Grants Update 2012 course.

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.

Looking for some advice on how to design a collaborative network? The IBM Center for The Business of Government just published a new report that highlights the successes and challenges of users who have implemented cross-agency collaborative networks.

In the introduction to the report, the authors say: Government agencies face increasing internal and external pressure to share information and to communicate across agency boundaries. Multiple-organization collaborative initiatives are far more complex and difficult than technology-based projects developed for use by a single agency. Collaboration requires a shared technology infrastructure that knits together legacy information systems of each partnering organization. Even more challenging is the need to design new approaches to organizing, funding, governing, sharing data, security, and operations.

The recommendations in the report are fairly straightforward. For example, they recommend involving all stakeholders. But they also go on to give pointers about how to do that.

You can access the report here.

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/.

Federal awarding officials now have a new tool to help them confirm individual and entity eligibility before making any grant, loan, contract, or benefit payment. Launched today, the new Do Not Pay List web site is a single point of entry for accessing relevant data.

The portal allows federal agencies to to access data sources including the Death Master File, the Excluded Parties List System, Treasury’s Debt Check Database, and the List of Excluded Individuals and Entities. The site also offers data analysis of information from other sources that are not currently available through the portal, such as prison information and several privately available sources.

OMB Memo 12-11 directs federal agencies to submit to OMB a draft of the agency’s plan for using this new tool by June 30, 2012. OMB will review those plans and agencies will finalize them no later than Aug. 31,2012.

Just a quick note: OMB is extending the deadline for submitting comments on its “Advanced Notice of Proposed Rulemaking” relating to the grants management requirements overhaul. The new comment deadline is April 30.

To read the original February 29 Federal Register notice describing OMB’s ideas for reforming grants management, click here.

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.