Grants Blog

Posts Tagged ‘OMB’

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!

Grant recipients (both pass-through entities and subrecipients) may want to take note of an interesting item in OMB’s recent guidance on implementation of the Improper Payments Elimination and Recovery Act (PL 111-204).

OMB says that for grant programs, agencies must consider payment recapture audits at the grant recipient level. “Federal agencies should work with state and local governments to ensure that they have enough resources to conduct payment recapture audits (for example, through direct funding, allowable administrative expenses, or contingency contracts),” OMB writes. It continues, “[G]enerally, federal agencies should not look to pass-through entities for repayment of improper payments identified by payment recapture audits for funds they pass-through until repayment has been made by the sub-recipient or the final payee.”

On this last point, I think it’s important to note that OMB is only referring to monies that were identified in recapture audits.

How agencies will implement this memo remains to be seen, but I thought some might find OMB’s take on the matter interesting.

You can view the complete OMB memo guidance here.

Just about an hour ago, OMB issued guidance to agencies about how to prepare for a federal government shutdown. I haven’t had a chance to read through the whole thing yet, but I thought it important to let everyone know as soon as possible.

The memo is available here.

I’ll pass along any other information I come across as soon as possible.

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?

If you purchase goods or services using federal grant funds, you might be interested in this: the simplified acquisition threshold for procurements under grants has not changed, even though the FAR level was recently increased to $150,000.

The threshold for grants – which is detailed in OMB’s grants management circulars – is based on the FAR’s underlying statute, not the FAR itself. According to OMB’s Office of Federal Financial Management, an interagency workgroup is looking into whether OMB should change the grants threshold to $150,000 for consistency with the FAR. However, they want to consider what impact this would have on the various grants communities before they make any change.

So for now, the simplified acquisition threshold for grants remains at $100,000.

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?

 The Office of Management and Budget is planning to distribute $37.5 million to help federal agencies support innovative projects that improve federal assistance programs delivered through state and local governments.

 The Partnership Fund for Program Integrity Innovation will support initiatives that improve payment accuracy, improve administrative efficiency, improve service delivery, and remove access barriers for eligible beneficiaries.

 The first step is for entities to submit pilot ideas. OMB will evaluate those ideas, solicit more detailed project and evaluation plans from the most promising suggestions, and then transfer funds to federal agencies to begin selected projects. The federal agencies will choose the state, local, or other relevant agencies for participation and possible funding.

Detailed information about the initiative is spelled out in a new OMB memo, including directions on how federal agencies can submit ideas. The memo, 11-01 is available here. Other stakeholders are invited to submit ideas via the website http://www.partnersforsolutions.gov. The deadline is 30 October 2010.