Grants Blog

Posts Tagged ‘reporting’

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.

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.

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?

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.

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.

Recipients of Recovery Act funds that have not filed the required reports detailing their use of funds and their programs’ progress may soon find themselves facing severe consequences – including the loss of funds, suspension and debarment, and even punitive actions.

In a new memo, President Obama directs federal agencies to “further intensify their efforts” to improve reporting compliance and to report the identities of noncompliant entities.

While the vast majority of recipients filed reports, the White House estimates that prime recipients failed to file more than 1,000 required reports covering an array of Recovery Act programs.

The president called on OMB to review the current guidance regarding reporting compliance and to issue even more guidance, if necessary.

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.