Grants Blog

Posts Tagged ‘OMB’

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.

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.

In a recent memo, the Office of Management and Budget told federal agencies to send out the remaining Recovery Act funds as quickly and efficiently as possible — or they could be returned to the federal treasury in two years. 

OMB said ”there remain billions in discretionary Recovery Act funds that, although they have been obligated, have not yet been outlayed. In light of the current economic situation and the need for further economic stimulus, it is critical that agencies spend these remaining funds as quickly and efficiently as possible.” 

In fact, if those funds have not been spent by September 30, 2013, agencies will reclaim them.

Agencies should work with grant recipients, OMB said, to accelerate the spending rate for all awarded funds while still achieving core programmatic objectives. Agencies are encouraged to reduce administrative hurdles that can delay expenditure of funds, as well as decrease delays between the receipt of invoices and the outlay of funds.

Federal agencies can request waivers from the 2013 deadline in cases where contractual commitments by the grantee with vendors or subrecipients prevent adjusting the timeline or where project completion may not be possible (such as in large transportation projects).

To accomplish this accelerated pace, agencies will be amending current grant award agreements and adding these deadline requirements to new grant agreements.

OMB memo M-11-34 is available here.

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.

Federal agencies are asking for your help in finding ways to reduce the administrative burdens and costs associated with cost principles compliance in federally sponsored research projects. Colleges, universities, grants offices, associations, and others involved in research have until July 28 to offer their ideas.

For several years, a federal interagency task force has been looking at 2 CFR 220 (Circular A-21) with respect to its application in federally sponsored research at educational institutions. That task force has gathered preliminary information on areas that could be improved, and is now inviting the public to offer their comments on these issues. Specifically, the task force is seeking input in the following areas:

• effort reporting,
• recovery of direct costs associated with administrative and project management support for investigators,
• institutional eligibility for the Utility Cost Adjustment,
• consistency among agencies that establish governmentwide
  F&A rates,
• programs with F&A reimbursement at other than governmentwide rates,
• rationalization between agencies of regulations and reporting requirements
• audits of research institutions and awards, and
• definitions of general and research equipment

All comments must be submitted electronically to:

http://grants.nih.gov/grants/guide/rfi_files/a-21/add.htm

You can read the full request for information here.

The task force plans to produce a summary of the suggestions by September, and will then begin to draft a set of recommendations that it will forward to OMB for review.

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.

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.

I’ve been looking at the recently released 2011 A-133 Compliance Supplement and found several items of interest (at least to me) that I thought I would pass along. 

OMB added a a new element to the core compliance requirements to alert auditors and program officials as to whether the reporting requirements of the Transparency Act apply to a particular program. The compliance supplement also explains that, at the current time, “this reporting at the program level may be “Not Applicable” for several different reasons: (1) there are no subawards under the program; (2) the program is exempt from this requirement because it is ARRA-funded; or (3) the program is other than a grant or cooperative agreement program. In the latter case, this designation may change once additional types of financial assistance are made subject to the Transparency Act’s reporting requirements.”

Also, when determining compliance with Recovery Act reporting requirements, auditors are only required to test for compliance with basic information such as the CFDA number and financial information such as expenditures. While the number of jobs created or retained is a required data element for Recovery Act reporting, OMB specifically says that the auditor is not required to test this data.

Feel free to post to our blog with anything else you may find of interest in the new Compliance Supplement.

Finally, the Office of Management and Budget has released the 2011 Circular A-133 audit guidance document.

As usual, new programs have been added, other programs have been deleted, and individual program descriptions have been updated. In addition, OMB has added guidance and references relating to Transparency Act reporting, and clarified reporting requirements and auditors’ responsibilities relating to Recovery Act funding.

Watch this blog for additional information in the future. In the meantime, go here to view or download the Compliance Supplement.

Enjoy!