330 Comments — Now What?

Now that the comment deadline on OMB’s grant reform proposal has passed, it’s time for the agency to move on to the next phase of the massive initiative: reading, analyzing, and acting on those comments.

In February, OMB released a set of draft “ideas” for reforming governmentwide grants management policies, affecting everything from how agencies announce notices of funding availability to audit requirements. The proposal is centered around two major themes: consolidating and revising the current eight circulars into one; and making that one circular applicable to all entities, regardless of their type.

More than 300 entities and individuals submitted comments on OMB’s list of ideas. As might be expected, opinions varied widely. Some supported the majority of OMB’s proposed reforms and said the changes were much needed, while others considered many of the changes to be detrimental to their grants management and federal program activities. Still others thought OMB did not go far enough in its proposal for revising the circulars.

OMB will use the feedback it received on these ideas to develop a proposed new circular (or amendments to current ones) that later this year will be published in the Federal Register for public comment.

OMB has indicated that it hopes to publish that notice in the fall of 2012, but that may be an ambitious schedule. OMB must review and prepare a response to each of those 300-plus comments. Then staff can begin to develop the specific draft reforms. Once the reform proposal has been vetted by federal agencies, OMB can then publish the notice of proposed rulemaking. That first notice will give the public 60 days to comment. After that 60-day period, the plan is to publish a final request for comments, giving another 30-day window for entities to respond to OMB’s proposed revisions.