Grants Blog

Posts Tagged ‘Transparency’

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?

I just learned that OMB is sponsoring a webinar to discuss the new Transparency Act (FFATA) subaward reporting requirements. The Town Hall Meeting is Thursday, Sept. 23, from 10-noon. For more information, 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.

In another new memo promoting open government, OMB offers details of how the fast-approaching Transparency Act subaward reporting process will work and the related responsibilities of federal agencies, prime grantees, and subgrantees.  

For example, in any new awards issued as of October 1 2010, federal agencies must include a new award term that delineates the Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements.

Prime grantees will be required to register in two systems to meet the act’s subaward reporting requirements: the Central Contractor Registration, and the FFATA Subaward Reporting System (FSRS). (FSRS was set up as the portal for Transparency Act subcontract reporting and is now being used to also report subgrants.)

The memo also clarifies that subawardees are not required to do the actual reporting; that is the prime recipient’s responsibility. However, the subawardee is required to provide the prime with all of the information needed.

Further, entities that are already reporting this information for Recovery Act grants through FederalReporting.gov will not be required to duplicate that reporting in FSRS.

These are just a few examples of the information included in the memo. You can view and download the entire 51-page guidance here.

Nearly four years after it was enacted, the Federal Funding Accountability and Transparency Act is once again on OMB’s radar. According to a recent memo, OMB is revamping the USAspending.gov site, creating a new mandate for ensuring the accuracy of Transparency Act data, and perhaps most notably, establishing a deadline for agencies to begin reporting subaward information.

Agencies have been reporting primary recipient award data to USAspending.gov for several years, but now they must begin to collect and report subaward data by October 1 of this year. (That information was supposed to have been available more than two years ago.) This subaward reporting requirement only applies to new awards made on or after that date, and only to first-tier subrecipients.

The information to be collected is similar to what is already being reported for Recovery Act awards, with one notable exception. The Transparency Act requires that entities report the names and total compensation of the five most highly compensated officers if the entity received 80 percent or more of its annual gross revenues in federal awards and $25 million or more in annual gross revenues from federal awards; and if the public does not have access to compensation information through IRS or SEC records.

Well, there is much more to this new OMB memo and it will take more time for me to wade through it all and digest the information. But I wanted to let you know about it as soon as possible. You can read the complete guidance by clicking here.

And remember, we’ll be covering this, as well as other developments, in our Federal Grants Update class. You can find dates and locations of this one-day seminar by clicking here.

Information about Management Concepts’ annual Federal Grants Update seminar is now available.

This year we’ll be discussing transparency and accountability, audits, standard forms, and more.

These one-day classes start the first week in April and run throughout the summer in cities around the country. Click here to see dates, locations, topics, and registration options.

Yesterday the House passed its version of a bill to reauthorize the Federal Financial Assistance Management Improvement Act, pushing OMB even more to create a one-stop web portal that would consolidate all grant application and management functions and standardize the process governmentwide.

The House version of S. 303 is similar to the Senate bill passed in March 2009. Both direct OMB to beef up Grants.gov so that it serves not only as a central location for grant applications, but also for grants management. The legislation continues the push for standardized reporting forms, and requires OMB to provide Congress with a list of those federal agencies that do not use the standard forms and the central management portal.

The House bill also would require the development of a single data standard for private sector entities to use to submit information to federal agencies, including grant applications and reports.

Because the Senate bill does not contain this language – and because of other differences – members of the House and Senate must now meet in conference to work out a comprise bill before the legislation can be sent to the White House.

We’ll keep you informed about this measure as it moves through Congress. Also, this and other grants-related developments will be covered in Management Concepts’ upcoming Federal Grants Update course. The annual course is offered around the country each spring and summer. Watch our website for details in the coming months.

On a new website, Partner4Solutions, the federal government is asking state and local governments for ideas on reducing improper federal payments.

The website and request for input are part of the Obama administration’s efforts to reduce the estimated $98 billion in improper payments made in fiscal 2009.

“We know that states and local governments are already addressing these issues head-on and have identified many innovative approaches. We see this as an opportunity to better understand some of the on-the-ground best practices. Please join us as a partner by contributing your ideas and suggestions,” the website says.

You can submit suggestions and learn more about the effort to reduce improper payments here.

If you think the contents of the Federal Register can be informative but have found the data hard to use and sort through, there is some good news. The Federal Register has been converted into XML, a form of text that allows users to browse, reorganize, and customize the data in just about any way they want.

For example, rather than browsing the daily contents of the Federal Register by agency or department as you used to do, you can now rearrange the information to see what announcements might affect your grant program or join real-time discussions about proposed regulations.

The transition is part of the Obama administration’s Open Government initiative and was implemented by the Government Printing Office and the National Archives and Records Administration. The XML version of the last ten years of the Federal Register are now available at http://www.federalregister.gov.

In an effort to improve the transparency of Recovery Act awards, the Obama Administration is restricting lobbying efforts by potential recipients, and making any lobbying activities that do occur visible to the public.

OMB has just issued a memo to federal agencies that updates the lobbying restrictions that were imposed on Recovery Act funds. In essence, after competitive grant applications have been submitted, there can be no oral communication between federal agency officials and anyone regarding that specific project, whether or not they are registered lobbyists. The prohibition applies after the submission of formal applications , and up through the award of competitive grants under the Recovery Act.

There are a few exceptions, however. For example, federal agency officials may asnwer questions that are technical in nature, and the communication is permissible if the federal employee initiates the contact.

But if communication does take place – including written communications – the federal employee must report it and a summary will be posted on a publicly available website.

To read the full OMB memo to agencies, click here.