Suffering from #NGMA2019 and OMB Overload?

It has taken me a bit to write my #NGMA2019 post. To be fair, I camped out for the first time in 30 years the weekend after and the Office of Management and Budget (OMB) issued not one, but two memos the same week. More on that in a minute…

Here are my top three takeaways from the National Grants Management Association (NGMA) Annual Grants Training Program:

1. OMB really is making progress on the Cross-Agency Priority (CAP) Goals, and the continuation of grants reform. If you’re in the weeds on grants, you know that moving the SF424B to beta.SAM.gov is a big deal.
2. Updates to 2 CFR 200 are now expected in the fall via a notice for proposed rulemaking. The 2019 Single Audit Compliance Supplement will come out soon. Ergo, be patient for change.
3. The Department of Health and Human Services’ (HHS) efforts to improve grant systems through Reimagine HHS are continuing. Interestingly enough, I found Mike Peckham’s remarks to be more inclusive of other points of view across agencies than those he gave at last fall’s Grant Professionals Association (GPA) conference. I think this reflects HHS’ user-centered design method to reform.

These takeaways all came from Rhea Hubbard (OMB) and Mike Peckham’s remarks on Tuesday morning. They really have great poker faces! They did not hint that OMB was going to drop the memo on Centralized Mission Support Capabilities for the Federal Government in three days’ time – the third memo in April that I believe will affect the Federal grants community. Here are my initial takes based on the most to least obvious impacts:

• Centralized Mission Support Capabilities for the Federal Government (M-19-16). If you didn’t know it already, the CAP Goal on Shared Services is tied to grants. The Administration formalized some of its ongoing efforts in this memo, including naming HHS as the Quality Services Management Office (QSMO) for grants. When I clicked through to learn more on the General Services Administration website, I thought, “Wasn’t HHS wasn’t already the shared services provider?” As a side note, HHS issued its 2018 Data Strategy: Enhancing the HHS Evidence-Based Portfolio. This will inform how HHS fully becomes the government’s shared service for grants.
• Guidance on Compliance with the Congressional Review Act (M-19-14). OMB issued guidance to agencies about following the Congressional Review Act and how to do so. The instructions set forth by OMB do not seem, at first blush, like anything more than a reminder to agencies to follow the law. But then, you have to wonder what hasn’t been happening for this corrective action to be issued and how more items will be sent to the Office of Information and Regulatory Affairs (OIRA) for a detailed review in the near term.

Which brings me to how this could affect the Uniform Guidance. OIRA probably has to review more submissions before they are posted to the Federal Register in the near-term.

We don’t know where 2 CFR 200 is in the queue, and we can’t predict when changes will come.

• Improving Implementation of the Information Quality Act (M-19-15). This is the memo that is making my brain hurt the most. Anyone dealing in grants policy for the past two decades can attest that data accuracy and management is both a concern and a challenge. Improving adherence to the Information Quality Act (IQA) and OPEN Data Act will help this. Additionally, a colleague pointed out to me that the memo is a tool to help the government get ready for artificial intelligence (AI).

But there’s a step beyond automation or collection. Agencies are required to determine and/or verify if their data sets are “influential” based on the Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies (aka Guidelines).

Grant-funded activities are likely sources for these “influential” data, especially in the scientific arena. So, it would not surprise me if we see more terms and conditions in grant agreements about meeting the Guidelines. Which would be fine if I thought that grant managers and recipients had the capacity and capability to meet these Guidelines. This is yet another sign that grant professionals need to grow their analytics knowledge and skills.

And now, let’s all get back to waiting for the 2019 Single Audit Compliance Supplement release…