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No, really. Are you Grant Ready?

Posted by on Jan 2, 2019 in Grants & Assistance | 0 comments

No, really. Are you Grant Ready?

In the middle of last week, I was scrolling through my LinkedIn feed for the latest and greatest. And then I had one of those stop everything moments to read the posted article. One of our grants instructors was offering to volunteer her services to save Claude Moore Colonial Farm. Who’s Claude and why does he have a farm? Claude Moore was the last owner of a farm that eventually ended up National Park land. A few decades ago, a nonprofit was formed to establish a farm and settlement circa 1771. Not a mansion on the site. Definitely rustic. It’s the place where you go to a festival and at least one elementary school field trip. My son brought home a dipped candle in first grade. Now my colleague’s post caused me to jerk a bit because my family had just gone to a winter market at the farm less than two weeks ago. There was no indication that this charming place was in trouble. According to the Washington Post, things had not been well for a long time. I learned for the first time that Claude Moore Colonial Farm was in operations based on a cooperative agreement between NPS and the Friends of CMCF. The NPS has agreements with similar organizations across the country. Short story: NPS terminated its agreement with the Friends of Claude Moore Colonial Farm for not complying with terms and conditions of getting Federal funds. Read the article for the details. This is an example of an organization choosing not to be grant ready nor compliant. I am frankly surprised that NPS let things go on as long as it did. I wonder how, what, when, and how much technical assistance NPS offered to bring this group towards a minimal amount of compliance. I’m even more shocked that the organization signed an agreement without asking itself internally how it was going to be successful beyond educating visitors. Let this serve as a cautionary tale that before your organization applies for a Federal grant, you must ask if you’re grant ready. Federal money has many, many strings attached that flummox the best grants manager. You have to look beyond the programs you’re diving into the depths of bureaucracy. And if you don’t have any bureaucracy, you’re going to need just a little...

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What Does the Federal Shutdown Mean for Grants?

Posted by on Dec 26, 2018 in Grants & Assistance, Uncategorized | 0 comments

What Does the Federal Shutdown Mean for Grants?

Regardless of political views or debate about the merits of a Federal shutdown, there are a few things to keep in mind with regard to grants and cooperative agreements during a shutdown. Both pre-award and post-award processes are impacted (or not). Pre-Award Federal websites continue to function during a shutdown. While there may not be as much technical support available or information may not be updated, the websites remain active. Any previously announced submission deadlines for proposals, therefore, are still in effect. There is no hall pass to excuse a late submission. Applicants should not expect an extension based on the shutdown, and should submit as planned. Grants.gov reinforces this protocol with a notice on its home page: NOTICE: During a lapse in Federal appropriations, the Grants.gov system will remain in an Operational status. Additionally, the Grants.gov Support Center will remain available to provide assistance to applicants. Award decisions, on the other hand, would be delayed until after the shutdown because the Antideficiency Act (Pub. L. 97-258, 31 USC 1341, 1501-1519) prohibits agencies from incurring obligations that are in advance of appropriations, such as during a shutdown when there is a lapse of funds. Post-Award Continuation of essential services and reimbursement payments remain the biggest concerns post-award, and it depends upon the type of award (entitlement, mandatory/formula or discretionary), and whether a particular action is required under law or would be in response to an emergency. The Constitution provides that no funds may be drawn from the treasury unless appropriated by Congress (the power of the purse). Likewise, the Antideficiency Act, enacted in 1905, also prohibits federal agencies from making payments in excess or in advance of an appropriation. The Act has been amended over time, including apportioning or dividing funds into categories and allowing for exceptions. The Act, therefore, provides that necessary and essential services continue, even during a funding lapse or shutdown. These include funding the military, law enforcement, benefit payments under entitlements, the banking system, emergency and disaster relief, medical care, border protection, power systems, air traffic control, and other essential services. If the federal award provides essential services and/or services mandated by federal statute, then those services may be covered during a shutdown. These services would need to be defined by the authorizing statute, not by the award agreement itself. Please confer with your legal advisors. Presidential Memorandum M-11-13, released during a prior shutdown, also provides specific guidance about federal grants and contracts. Routine or ongoing activities under an award such as grant or contract administration would need to cease during a shutdown. These activities include oversight and payment processing; however, M-11-13 also references the Antideficiency Act and reminds federal agencies they have statutory authority to incur obligations for essential services, i.e., services defined by a program statute or other legal requirement (not by the award agreement). If there is an emergency, those services may also be covered, but again, the emergency exception does not cover ongoing, regular or routine functions. Please confer with your legal advisors. If an unobligated balance of funding remains available from a prior period, if the award was made before the shutdown, or if it was appropriated on a multi-year or no-year basis, then the federal agency may have some discretion with respect to timing when activities may be carried...

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No Rest After #GPAConf18

Posted by on Nov 16, 2018 in Grants & Assistance, Uncategorized | 0 comments

No Rest After #GPAConf18

This was going to be a post about how wonderful the 2018 Grant Professionals Association (GPA) Annual Conference in Chicago was – meeting up with friends, finding Url the Squirrel, introducing my colleagues Vera and Lahaja to the grants community, Hamilton… but instead it’s back to regular order. Tuesday, I attended the National Grants Management Association (NGMA) monthly luncheon in DC featuring speakers from the Office of Management and Budget (OMB). Great, I thought. I’ll be able to make a few updates to my GPA presentation. It shouldn’t be that much different from any of the events I’d attended in the past 30 days. Instead, I was met with some surprises — here are my top 3. 400 Data Standards will be available for review. Data standardization is part of the long-term efforts. Think of it as the DATA Act train staying on the track. I was expecting a confirmation that the 400 data standards would be posted to the Federal Register on or about November 15. Instead, those in attendance were told that the standards would be posted to GitHub. Which made sense because the current administration rarely uses the Federal Register. What did I see this morning (after I updated my presentation and registered on GitHub)? The Public Inspection document for the Federal Register Notice.   Agencies are supposed to implement M-18-18. You know when you’re met with good news, and month’s later, you’re met with a caveat? That happened to me and a few others in the room. OMB Memorandum 18-18 increases the micro-purchase and simplified acquisition thresholds in advance of the Federal Acquisition Regulation update for grantees. I missed that agencies are supposed to implement the changes in the terms and conditions of award. If your organization has moved to these new thresholds, make sure that you get something in writing from your grants officer if your award terms and conditions haven’t been updated. Streamlining of audit requirements. You know you’re in a room of in-the-know grant professionals when there’s a gasp following, “twelve to six requirements.” From my point of view, it was well known that significant updates to the Annual Compliance Supplement (2 CFR 200 Appendix XI) are coming in 2019. That’s why OMB issued the 2018 “Skinny” Supplement. Any potential shifts in the number of Single Audit requirements was news to the room. To be fair, the OMB representatives were not the staff working directly with the CAP Goal 8 Audit Workgroup. Therefore, I’m not going to speculate what the exact parameters are on the changes to these requirements. What I am going to do is start checking for updates on this subject frequently. And the bonus surprise? I might be splitting my time tomorrow sifting through the new standards and shoveling snow. I must’ve brought winter home from Chicago....

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Is a push for more Federal Grants certifications sustainable?

Posted by on Oct 2, 2018 in Grants & Assistance | 0 comments

Is a push for more Federal Grants certifications sustainable?

The GAO released its report on the Grants Workforce last week and for me there were no surprises. Agencies are still struggling to identify who comprises the grants workforce Some agencies adopted the 1109 job series There’s a drive to a certification…but no consensus on what that should be Adoption of the Financial Assistance Career Roadmap is limited More training is needed Now you’d think that as someone whose product audience is 50%+ Federal, I’d be jumping up and down for joy. Don’t get me wrong, this report shows a lot of opportunity to fill the gaps to provide the Federal workforce with the grants knowledge they need. My concern is that the drive for certifications in grants, as well as other job series, will not be sustainable for everyone. What if you are an individual whose position requires you to: Oversee large projects Manage support contracts Implement grant programs And by the way, it’s a cyber security grant program. If you were to read the recent grants report with the GAO cyber security workforce report, PMIAA implementation guidance, and Contracting Officer’s Representative requirements, you may determine that you need to obtain and/or maintain FOUR certifications. And, you may get the training you need paid for by your employer but not the money to take the test to obtain the certification. How do you choose which one to get? When? Why? How? What is the best match for your limited training budget? Which path is going to best serve your career? We need to recognize that certification efforts may push some people into a specialist role, when really, we’d benefit from someone with a broad set of skills and capabilities. That’s why I am hopeful that we’ll see more adoption of the Financial Assistance Career Roadmap. This competency model recognizes that Federal Grant professionals need to upskill in their knowledge, skills, and abilities in analytics, leadership, and project management. This roadmap, if implemented with flexibility, could facilitate the ability for individuals to follow the model while pursuing the certification, certificate, or degree (which travels with the person, not the position) that fits individual career goals. By the way, the drive towards cross-functional capabilities is a trend across the government. The executive session discussion at the last AGA PDT centered on the need for people to do more analysis as more basic functions are automated. Looks like we all need to be a jack-of-all-trades and master of at least...

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Strengthening Federal Evaluation: Meet in the Middle?

Posted by on Jul 20, 2018 in Grants & Assistance, Workforce Management | 0 comments

Strengthening Federal Evaluation: Meet in the Middle?

Greetings from the proverbial swamp. It’s July in Washington. I’m ruing the lack of seersucker in my wardrobe – longing for the ocean breezes of Miami Beach. So how do I meet this digression? With some good ol’ Beltway insider habits. First, I check to see if Congress has at least gone through the motions of pushing the 13 appropriations bills through committee. And the answer is yes. There’s even one bill that has been passed through both houses. (Energy and Water consolidated with Legislative Branch and Military Construction-Veterans). Considering how this year has been, it’s a nice surprise to see something that should be normal occur. Second, time to check out the full version of “Delivering Government Solutions in the 21st Century,” or the Trump Administration’s proposal to overhaul the Federal Government. You might have heard about this primarily through the proposal to merge the Departments of Education and Labor into the Department of Education and Workforce (DEW). (Which leads to another tangent: Does anyone in the Administration drink Mountain Dew?) But as I push through the document, I want to learn more about these proposals as a grants professional looking at the authorization needs for these changes (potentially in appropriations bills). And frankly as someone whose career was shaped by the formation of DHS, a merger of 22 agencies. Then I happen upon the section, “Strengthening Federal Evaluation,” on page 118 of 132 in the PDF. Grants and policy gold. In two-plus pages my hopes for good government soar. The use of evaluation to inform policy making is the ideal, and often the point of grants and their subsequent management. We want to fund effective programs that work and even try programs that fail. The first two pages of this section are a true call to “Meet me in the middle.” A reach to the middle for a government designed to be inefficient? Tell me more! And then I reach the top of the third page, and an emotional pop song comes into my head. I see, “Establish and utilize multi-year learning agendas.” I hear in my head Maren Morris singing, “Meet Me in the Middle.” The middle is hard because policy making is an emotional and often reactive process. And grants, which are policy tools, are often the instruments evaluated to inform policy, effectiveness, and compliance. This section reads innocuously enough. Yet this proposal sets up a situation that what gets measured gets managed. And those who sets the measurements are a conduit of the President’s Agenda. Keep in mind that the President changes every four or eight years; the so-called learning agenda can change dramatically. This is a challenge because sometimes it takes longer than eight years to find out if something really worked. To carry out this proposal, you have to protect the policy experiments getting measured. Which could mean asking an Administration doing something from a policy standpoint is abhorrent to their stated policy positions. But what if you’re elected to do a 180 on a policy, even with data available? Do you have a temper tantrum about being dragged to the middle, using data to make decisions that contradict your policy position? And how does that trickle down to grantees who finally have a system to measure x, y, and z; but...

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The Reform Proposal’s Potential Impact on Federal Grant Making

Posted by on Jul 16, 2018 in Grants & Assistance, Workforce Management | 0 comments

The Reform Proposal’s Potential Impact on Federal Grant Making

I’ve already written about the evaluation section of “Delivering Government Solutions in the 21st Century,” the Trump Administration’s outline for reorganizing the Federal Government. Now, I’d like to focus on the potential movements of grant makers and programs. I’d like to start by stating that any significant adjustments to an organization, be it mergers or eliminations, have a significant impact on the people affected. Sitting on a client site in 2004 during years one and two of the Department of Homeland Security taught me that change management and culture considerations are as important, if not more, to the success of the change as the gained efficiencies. Back to some of the proposals. Proposed: Department of Education and Workforce (DEW) This could be the most ambitious and contentious of the Administration’s proposals and definitely requires Congressional authorization and appropriations for it to happen. But when it comes to looking at the grants part of Labor and Education’s business, there are some details to be hammered out, such as: Will Congress consolidate program authorizations for workforce education, or will DEW still have to manage the same number of assistance programs with a streamlined workforce? If this merger occurred, what would need to be done to bring the legacy Departments’ adoption of and exceptions to 2 CFR 200? Are there enough lawyers on staff to manage the requisite regulatory process? What programmatic expertise/points of view could be at risk of elimination as part of the merger? What are the potential economies of scale? These same questions apply to some of the other proposed movements, including the consolidation of food assistance programs under Health and Human Services (to become Health and Public Welfare), housing at HUD, and the long-term efforts to bring State and USAID together. Proposed: Numerous Movements of Smaller Grant Programs and Agencies Over the years, Congress has established several standalone Commissions and Agencies in reaction to meeting a specific need. These organizations manage grants to carry out their policy missions. The Administration proposes the following moves: Fold Inter-American Foundation and U.S. African Development Foundation under USAID Consolidate administration graduate fellowships under the National Science Foundation Move the Delta Regional Authority, Denali Commission, Northern Border Regional Commission, and HUD’s Community Development Block Grant program under a new Department of Commerce Bureau of Economic Growth From the back-end, what you need to make a government agency work, perspective, these proposed moves make sense. For instance, sharing IT and human capital resources. However, the proposed changes will still need to abide the Congressional intent of these commissions and programs in their authorizing statutes. This could mean that the new organization is still managing many “special snowflake” programs. Proposed: The GEAR Center The proposed Government Effectiveness Advanced Research (GEAR) Center is an organization that will be set up to fully utilize the option of fixed-amount awards. I think that this proposal will take some of the best practices and efforts in government that have occurred in the past 15 years. For example, issuing more “challenges” and improving public-private sector collaboration. Pulling “innovation” into an incubator setting could help with the conundrum of long-established agencies: “How do I innovate and meet the huge amount of compliance requirements?” Proposed: Combined Census and Statistical Agencies Experienced grant recipients and applicants know and use the information put out...

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Time to Skim the 2018 Single Audit Compliance Supplement

Posted by on May 30, 2018 in Grants & Assistance | 0 comments

Time to Skim the 2018 Single Audit Compliance Supplement

There are some things that we each find to be like the homework assignments we use to hate. For me, it’s the annual Single Audit Compliance Supplement. When it came out earlier this month, I successfully managed to finish my part for a couple of Private Group training products, watch more hockey than I ever had before (Go CAPS!), consume a beach worthy novel, and make a complex breakfast for my husband’s birthday. So, thank you Office of Management and Budget (OMB) for the burst of productivity and family time. Without a book to read on our way home from the beach Monday, I settled to read the 2018 Compliance Supplement front matter and a skim through the rest. Here are my top takeaways: Procurement. OMB discusses procurement issues in several places, especially with regards to the most recent National Defense Authorization Act’s changes to the micro-purchase and Simplified Acquisition Threshold (SAT) levels that will take effect in 2018 (likely July). There are also instructions to auditors to be mindful of any grantees affected by the 2017 Hurricane Season. Even more interesting, this is the only section from 3.1 that was significantly updated. Consider it a reminder for all non-Federal entities to double check that they have: 2 CFR 200 compliant procurement policies in place re-read the Suspension and Debarment requirements prepared to adjust micro-purchase and SAT when you can and if appropriate. Internal Controls. The directions are to use the 2017 Compliance Supplement. All in the grants community should say an internal, “hooray,” as this was a big change last year. Administration. Bookmark this site: https://www.whitehouse.gov/wp-content/uploads/2018/05/2018-Compliance-Supplement.pdf. OMB published the supplement on the Office of Federal Financial Management (OFFM) page – not the Circulars page. Make sure you review the changes and eliminations to the programs with special instructions, including those programs that are to be clustered. And finally, think about if you’re one of those people who needs to have a document like this in one source. I know some of you out there are wondering and might prefer if OMB had just swapped pages with last year’s and republished it in it’s in entirety. I’m guessing few pages to process helped speed the clearance time. Since I was a captive audience, I continued skimming through the program specific guidance. Not every agency included changes in this supplement. This makes sense as we anticipate release of the 2019 Compliance Supplement in early 2019, and many policies, regulations, and authorizing statutes have been stable during the past two years. That said, the number of programs included in the Department of Education (ED) section is striking – and reflective of the many policy changes that have been implemented since Secretary DeVos took over. Sometimes the changes are subtle. But they are there. Read carefully, especially if you have responsibility for performance and/or ED specific program reporting. I know it’s a beast, and easy to avoid, but if you’re working with Federal grants, make sure you do your annual homework and at least skim the Compliance Supplement. It’s easier to prepare for an audit if you know what auditors are looking for. And maybe, just maybe, you’ll manage your grants better,...

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What makes audit findings so Special?

Posted by on May 15, 2018 in Grants & Assistance, Workforce Management | 0 comments

What makes audit findings so Special?

It was Christmas in April at Management Concepts. At least for me. I worked with our colleague Meghan to pull down the Single Audit Clearinghouse as of March 31, 2017. So every few days I’ve started to play with the data to figure out what path I want to go down from a research perspective – or to find out what would help our students. I admit – I could play with this information all day. Which is why no one has taught me how to program our internal dashboards. This is what I’ve found so far: The most common findings in 2014-2017 are Cost Principles and Reporting. Given my last blog on the compliance conundrum, this wasn’t a surprise. The next one that popped: “Special Tests and Provisions.” What does this even mean? To the Compliance Supplement went: “The specific requirements for Special Tests and Provisions are unique to each Federal program and are found in the laws, regulations, and the provisions of contract or grant agreements pertaining to the program. For programs listed in this Supplement, the compliance requirements, audit objectives, and suggested audit procedures for Special Tests and Provisions are in Part 4 – Agency Program Requirements or Part 5 – Clusters of Programs.” Unique. There’s that word that’s an enemy of consistent reporting. And really if you’re managing multiple grants, it’s a reasonable hypothesis that the “unique” provisions are what will show up as a finding in an audit. You may not have a “unique” control in place to go with it. I’m going to continue to dig in to the data and share what I find in future posts. That said, let’s focus on what you can do now, especially since it’s the height of Federal application season. Start at the beginning. Read your Notice of Funding Opportunities (NOFO) carefully, and consider writing to and budgeting how you’re going to meet the unique requirements of specific grant programs in your applications. You need your whole team involved in this discussion. Because if it’s unique maybe it should be a direct cost. You need to get that right at the time of application and award. Plan for regular and special grant lifecycles. Manage your grants as consistently as possible. Then document any special activities you must undertake to meet those “special provisions.” That way you’ll be prepared for an auditor or site visit at any stage in the process. Triple check what you’re charging to the grant. Have I mentioned I think that Cost Principles is one of our most difficult courses? It’s because there are so many instances when the decision isn’t black or white. Remember, audit findings are preventable with good planning, management, and...

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The Compliance Conundrum With Federal Grants: National Grants Management Association 2018

Posted by on Apr 9, 2018 in Grants & Assistance | 0 comments

The Compliance Conundrum With Federal Grants: National Grants Management Association 2018

It’s always great to hear from Rhea Hubbard, Senior Policy Analyst at the Office of Management and Budget, in any setting. I can’t tell you how much I appreciate that the President’s Management Agenda Cross-Agency Priority Goal #8 is all about grants – and that we’re keeping on keeping on with the long slog of grant reform. I can confirm that agencies are already working on strategic plans, like Anna Mauldin suggested back in February. But I have had a few conversations often starting along the lines of, “How are we supposed to manage for performance, when we can’t even get the compliance right?” This combined with rumblings about the emphasis on internal controls (a.k.a., things that make it easier to be compliant), and feelings of being lost… Hopeful, but lost. I don’t know about you, but I have a really hard time wrapping my head around the promise of moving beyond compliance to performance. I want to believe. And, I see it happening. The enhancements to USAspending.gov and the Single Audit Clearinghouse are fantastic. I now have terabytes of government grant information at my fingertips. Quite frankly, it’s amazing – and yet, it’s far from perfect. Until we’ve improved our understanding and application of compliance on all levels within the grant community, we’re still going to get asked the basics: How much was expended? Was it obligated? Why haven’t these billions of dollars been drawn down? Were there any false claims made? It’s a conundrum that is consistently top-of-mind for many of us. At the individual project and program levels, sometimes we’re able to get from compliance to performance, but getting there for all $700B in annual federal grant spending is a whole new ballgame. What are the barriers to overcoming this compliance conundrum? Investment. During this year’s National Grants Management Association event, we heard a lot of tips and tricks about how to create forms and document internal controls. But when it comes to feeding the federal grants data behemoth, there must be a massive investment made into systems and technology by all participants. Additionally, once those systems are in place, another investment must be made to maintain them. Interestingly, it’s conceivable that there may be a grant program to help the recipient community with these investments but not so much when it comes to operations and maintenance. Value proposition. At the national level, the value proposition has come together – more data will lead to better grants management, reduced duplication, and earlier detection of when and how policy implementation is a success (remember, grants are policy tools). We heard from Carol Kraus from the State of Illinois that streamlining efforts have saved $106M for the state and its subrecipients. That said, I’m not sure how recipients at the end of the grant funding chain are going to see the benefits unless they’re getting millions of dollars from lots of grants. This is the value proposition that must crystalize before moving into the next phase. This is especially true for those challenged with meeting the basic compliance requirements (which aren’t easy); without a source for operational funds to meet the coming data and reporting standards, or the need for investment in grant compliant systems. On a positive note, grant reform continues to be a bipartisan effort… just...

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Choose Your Own Adventure: Certificate or Certification?

Posted by on Apr 2, 2018 in Grants & Assistance | 0 comments

Choose Your Own Adventure: Certificate or Certification?

I’m looking forward to the National Grants Management Association Annual Training that gets started this Tuesday. It’s always great getting to meet so many of you in person. One line of questioning at the conference that I’m sure to get will be “certificate or certification.” So I thought I’d share my thoughts more broadly as next week focuses on the Certified Grants Management Specialist (CGMS) and we just finished 31 Days of Certified Grant Professionals (GPC). Step back and look at where you are and where you want to go Whether you’re looking at a certificate (which I think of as yours to keep) or a certification (re-cert requirements needed), you need to consider where you want to be. Either option is an investment in your skills, knowledge, qualifications, and marketability. When I pursued my GMCPTM from Management Concepts, I was at a point in my consulting career at Booz Allen where I needed to commit deeply to a subject matter area (like grants) or get my PMP. That was the reality for me then and there. I had more opportunities on grant projects and wasn’t ready to commit to the recertification requirements. So, the certificate worked for me. And hey, I even ended up in a pretty cool role that blends grants and business acumen. Would I pursue a CGMS or GPC now? No. I love grants. But I’m also a product manager. I have some other skills on my performance plan. Besides, I feel like I should be neutral. You’re not me – you’re committed! Now if you’ve committed yourself to a career in grants, save the money and invest in the certification. Hiring managers are adding the CGMS and/or GPC as a required or preferred credential for mid to senior level grant positions. Or maybe you’re reading this post and you’re committed to another field with a certification and seeing a similar trend. Regardless, these are the questions I’d ask myself: Do the certification’s competencies support my short and long-term career goals? Which areas would I need to study to pass the exam? What are the certification’s recertification requirements? Do I need to be certified by a certain deadline? And if it’s soon, do I have enough time to study? Will my employer support my credential – in terms of time and costs? Now if you find barriers in your pursuit of a certification, reach out to the organization’s in charge. You’ll often be able to find a study resources, test cost assistance, or others who can help draft a justification for your employer’s tuition reimbursement form. But wait – you can do both One thing to keep in mind is that pursuit of a certification does not mean that you can’t pursue a certificate concurrently. For instance, I frequently suggest to students looking at the CGMS to take the core courses for Management Concepts GMCPTM. These help students prepare for the CGMS exam. After earning their CGMS credential, they can apply CPEs from Management Concepts courses, finishing up their GMCPTM along the way. In a few years after the students have advanced in their careers, I often recommend looking at complimentary certificate programs, to help drive their careers forward. So, no matter which career adventure you pursue, you need to remain committed to your professional...

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Thanks to You, the Grant Professionals

Posted by on Mar 6, 2018 in Grants & Assistance | 0 comments

Thanks to You, the Grant Professionals

It’s exciting that it’s another International Grant Professionals Week. And it’s fitting that my schedule is full of updates to our grants curriculum that I’m working on with our internal team to push out. Last Friday, I pushed out a list of eight courses that are hitting the classroom late winter/early spring. It’s about making sure you have the best content. This process also makes me appreciate our cadre of instructors even more. I have the privilege of working with people who have 10, 15, 20, and even 40+ years of experience. Whenever I have a question on a nuance reading of the Uniform Guidance, I’m usually only minutes away from an opinion. And usually several opinions. It gives me comfort that you’re in the hands of experienced practitioners and grant professionals. I also want to express my appreciation to you, our students and readers. I, like many of you, am the accidental grant professional. I saw myself going forward more in some sort of project management or marketing trajectory. Then one project assignment led to many more on various grant programs. And wouldn’t you know, those project management skills have come in handy over the years. So take a moment to appreciate yourself and your peers. The grants management specialists, program officers, and “other” professional who met the request to manage or write a grant when you were on desk duty. You’re part of a great community of collaborators making a difference in your communities all over the world. With that in mind, take a moment to see if there are grant professional meetups in your area, or other upcoming professional meetings. Visit the GPA and NGMA calendars to learn...

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Federal Grants Reform – The Story Continues

Posted by on Feb 23, 2018 in Grants & Assistance | 2 comments

Federal Grants Reform – The Story Continues

One thing I’m constantly asked is, “what’s new with grants?” For those who follow Federal grants constantly, the turn of the past year has seemed slow. But part of the reason it seems slow is that we’re still recovering from the implementation of 2 CFR 200. Think about it. If you were around in February 2013, you were probably following which clauses of which circular were going where into the “new” Uniform Guidance. If you lived through that change, everything else may seem like it’s on the edges. And maybe not even reform. But anything that makes managing Federal grants better fits in line with nearly 20 years of reform efforts. That said, the Federal grants community is constantly working on ways to improve processes, performance, and reporting – all with the goal of understanding what impact financial assistance has on our communities and our country. Last month, Shane highlighted a few things to anticipate in 2018. Now that we’re really into the year, I have a few more items in the spirit of reform. Grants.gov / Workspace Implementation. For those of you actively applying for grants at the moment (or waiting for the CR to end so you can), you’re feeling the effects of using the new Workspace on Grants.gov. And hopefully it’s good. Consider it a step of reform that there’s a back end system to help you with your forms and more people have access to collaboration tools without having to buy software packages. GREAT Act Introduction. First there were the Recovery Act changes (almost 10 years ago!). Next the DATA Act. The next step is the Grant Reporting Efficiency and Agreements Transparency Act of 2018. Let’s all be thankful that improving the availability and management of grants data continues to be a bipartisan issue. Performance.gov Revamp. My colleague Anna Mauldin just posted a great overview of the changes to Performance.gov. As expected – they’re significant and in line with the policy priorities of the Trump Administration. But the underlying premise of reporting performance has largely stayed the same. If you plan on applying for a Federal grant anytime during the next few years, review these policy priorities. The Administration’s overarching performance goals should trickle into Notice of Funding Opportunities (NOFO) going forward. Of course, all of these reform steps mean that we’ve been looking at how we can share information with you in the classroom. In some cases that has meant completely revamping the content…as in the case of Applying for Federal Grants & Cooperative Agreements. For others, it means adding more virtual class options so you can access the knowledge you need without hitting the road.   Tip: Micro-purchase Thresholds in the FAR. There were changes in the 2018 NDAA. It’s going to take a bit of time for the FAR to be updated accordingly. Once that does happen, 2 CFR 200 will adjust automatically. In the meantime, make sure your procurement policies are in line with the current $3,500 level....

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2 CFR 200: What You Need to Know in 2018

Posted by on Jan 11, 2018 in Grants & Assistance | 0 comments

2 CFR 200: What You Need to Know in 2018

For the last year, the grants community has been expecting the Office of Management and Budget (OMB) to incorporate a number of grants-related laws into 2 CFR 200. OMB officials have commented that they are working on amendments, but have not provided an estimation on when the changes will be announced. In anticipation of the changes, it is important for the grants community to be aware of the legislation that may potentially be incorporated into 2 CFR 200. National Defense Authorization Act for Fiscal Year 2017 (NDAA). The NDAA for FY 2017 altered the micro-purchase threshold for procurements made under research awards. Section 217 of the law increases the micro-purchase threshold for Defense Department research awards to $10,000. Additionally, the NDAA for FY 2017 increases the micro-purchase threshold for universities, independent research institutions, and nonprofit research organizations to $10,000 or to “such higher threshold as determined appropriate by the head of the relevant executive agency and consistent with clean audit findings under chapter 75 of title 31, internal institutional risk assessment, or State law.” Federal agencies and OMB have not provided clear guidance on the impact of this provision. Digital Accountability and Transparency Act (DATA Act). The DATA Act increases government transparency and accountability by requiring the use of government wide data elements to report Federal spending. The DATA Act required a pilot program to test methods to reduce administrative burden on grant recipients. The Department of Health and Human Services (HHS) recently concluded the grants pilot program and OMB submitted a report to Congress on lessons learned from the pilot program and recommendations for future action. The DATA Act requires OMB to determine whether to apply the DATA Act requirements to grant recipients by August 2018. Grants Oversight and New Efficiency Act (GONE Act). The GONE Act requires Federal agencies to report to Congress on grant closeout activities and provide the number of grant award accounts that remain open. Buy American Laws. In June 2017, OMB released a memorandum to Federal agencies regarding the applicability of the Buy American Laws. The memorandum stated: “For Federal financial assistance awards, there is no primary law that imposes the Buy American Laws as defined in E.O. 13788, and applicability varies by the authorizing and appropriation statutes imposed on specific Federal financial assistance programs.” The memorandum direct agencies to evaluate and report on how Buy American Laws applied to Federal grants, identify guidance provided to grant recipients regarding compliance with Buy American Laws, and summarize agency compliance with Buy American Laws. Never Contract with the Enemy. Section 841 in the NDAA for FY 2015 requires revisions to 2 CFR 200 to incorporate language restricting the awarding of grants, contracts, or cooperative agreements to individuals or entities that are actively opposing U.S. or coalition forces. President Obama signed the law in December 2014. In addition to the expected amendments, 2 CFR 200.109 requires OMB to review 2 CFR 200 at least every five years after December 26, 2013. OMB has not identified what the review will consist of, or when it may be completed. Stay...

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Grant Pros + Bay Views = #GPAConf2017

Posted by on Nov 17, 2017 in Grants & Assistance | 1 comment

Grant Pros + Bay Views = #GPAConf2017

I don’t know about you, but I tend to go in to a post-conference social media coma. Something has to give between coming off the professional development high and the dive back into the day-to-day low. And if you follow me, you know that I like to live tweet my conference experiences. It’s a fun, interactive way for me to talk about notes. And I needed them to write this post. Like so many attendees, I focused on trying to fill in my knowledge gaps this year. I could have spent another week attending sessions because there was so much to choose from. For me this meant spending quite a bit of time trying to understand the recipient point of view, like: The details to and not include when submitting a budget proposal. Having worked in Federal grants for so many years, details are the norm. But I hadn’t considered what adjustments you have to make for foundation requirements, especially for capital projects. In good news for my transferrable skills – Cheryl Kester’s (@KesterGroup) advice aligned similarly to any corporate budget I’ve developed. Board responsibilities are expansive. I haven’t served on a board in a long time, so Debbie DiVirgilio’s (@Grantconsultant) session served as a reminder that board members take on fiscal responsibility for an organization. Boards also need training, preferably annually, on their responsibilities. Then I learned about a whole other level of “volun-telling” from the participants. One person shared that they had been elected by a nonprofit board – without having been asked. They found out in a passing conversation. You bring your culture with you. Of course, I attended the session on creating an individual professional development plan based on the GPC – I work for a training and solutions company! I loved the approach presented by Julie Assel (@ACgrants). I was also reminded how hard it can be to address how and when you bring your #culture with you – especially when writing or consulting for someone with a different background than you. I also had the opportunity to watch our own Scott Boozer (@leadingwithfun) deliver a session on Dealing with Conflict. I was glad that Management Concepts was able to share this know-how with such an engaged audience, committed to their own professional development. Plus – anyone working in grants has some sort of group dynamic. Conflicts are inevitable. So now that I’ve caught my breath, I can focus on finishing up the relaunch of Managing Federal Grants and Cooperative Agreements (December) and Applying for Federal Grants and Cooperative Agreements (January). That includes incorporating some of my takeaways from...

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Tales from the Classroom

Posted by on Oct 18, 2017 in Grants & Assistance | 0 comments

Tales from the Classroom

Over the last few months, I have traveled across the country teaching the full range of Management Concepts’ Grants curriculum to Federal employees and grant recipients. I view my time in the classroom as a mutually beneficial experience: Participants learn our grants curriculum and I learn from participants about their specific grants management challenges and best practices. For this blog, I want to share some of the common questions and concerns I hear regarding grants management from Federal grants personnel and recipients. Contracts vs. Subawards 2 CFR 200.330 provides guidance to grant recipients in determining which instrument should be used: A contract or a subaward. While the language in the provision provides a useful checklist, many participants in my classes have provided some tremendous examples of complex situations in which a clear answer is not readily available. I thoroughly enjoy when participants ask these questions in the classroom. Generally, I will walk the class through the language in 2 CFR 200.330 and encourage discussion for participants to reach their own conclusion. I find it fascinating when some members of the class conclude a contract should be used, and others feel a subaward is the appropriate instrument. There are definitely some gray areas in contract and subaward determination. My best recommendation to participants, if they find themselves in this situation, is to document their instrument selection decision process by using the language in 2 CFR 200.330 and provide a detailed explanation.   Awards to International Organizations and Institutions of Higher Learning If you have taken a course with me, you have heard me repeatedly say the phrase “This is how it generally works…. unless you are from a college, university, or international organization.” Research awards and international awards are, sometimes, very different creatures, and it is interesting to hear participants share their experiences in managing their specific awards. For example, research awards have a higher micro-purchase threshold, expanded authorities that waive some prior approval requirements, and use the additive method for program income. After reviewing the exceptions to research awards, multiple participants have commented that they need to find a grants management position in a university. When employees from the University of Hawaii were recently in one of my classes, quite a few of us were envisioning working in the Aloha State!   Agency Implementation and Interpretation Perhaps the most fun I have in the classroom is hearing how different agencies have implemented 2 CFR 200 and the differing interpretations of grant compliance requirements. For example, when teaching our Cost Principles course, it has been interesting to see which agencies apply the cost principles under the Federal Acquisition Regulation (FAR) to for-profit entities, and which apply the Subpart E of 2 CFR 200. This only reemphasizes the importance for grant recipients to carefully review the terms and conditions of their awards from differing agencies.   Dedication to the Public Good The most rewarding part of being in the classroom is seeing highly dedicated individuals who have the desire to learn how to better manage their grants to provide quality services to their communities. Honestly, it is inspiring to meet so many people determined to do good.   For those of you that have been in my classes, I thank you for sharing your stories, for teaching me about your practices,...

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Building Sustainability For Your Funding

Posted by on Sep 19, 2017 in Grants & Assistance | 0 comments

Building Sustainability For Your Funding

One of the questions I’ve received most often since joining Management Concepts is, “Where else can I get funding?” This question goes to one of the weakest areas in the grant community: Sustainability. In this context, I’m not talking about the triple bottom line or climate change. It’s something much more basic: The resources that will keep your grant project going once funding source A is gone. Because deep down we all know that no funding stream lasts forever. So, it was with this sustainability lens that I approached yesterday’s National Capital Region Grants Conference. I spent my professional development time outside my comfort zone: On the philanthropy track since that is where the other resources are. The day started with a condensed lesson in nonprofit success 101 with Glen O’Gilvie, CEO of the Center for Nonprofit Advancement. The lesson focused around relationship building with a dash of learning from failure. O’Gilvie emphasized how important it is to your organization’s success to take the time to know your funders before the RFP drops — and then having the confidence to ask them for debriefs after a failed application. Simply put, people fund people. This resonated with me in my role as a product manager. When I have this hat on, this relationship building with funders is called business development. O’Gilvie also provided the audience with a succinct list of where nonprofits (and others) can find funding: Foundations Individuals Corporations Government Earned income All of these potential funding streams have something in common in that they can’t happen overnight. Each funding channel requires a cultivation plan. These plans in turn require a long-term commitment, potentially taking months if not years before you take in that first dollar. The thread of O’Gilvie’s path to a diversified set of resources through relationships continued throughout the day, from the funders panel to evaluation. Sustaining sources of funding won’t appear in your checking account overnight. This focus on relationships was refreshing. But this is not to say that the data doesn’t matter. Part of your cultivation plan could very well include the production and presentation of outcomes based on results. Which can and will be one of the hardest aspects of grants management. We’re still telling the anecdotal stories that emulate our organizations’ missions. Easy, right? Not at all. The cultivation of relationships is hard enough without layering on the need for evidence of success. But that’s where you learn that you aren’t going at it alone. Ask for help – especially when it comes to ways of funding to sustain your grant-funded programs. Check out our course-by-course schedule of upcoming grants classes, and learn more about how our Grants & Assistance curriculum can help you sustain your grant-funded...

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OMB Releases 2017 Compliance Supplement

Posted by on Aug 18, 2017 in Grants & Assistance | 0 comments

OMB Releases 2017 Compliance Supplement

Last week, I was talking to Shane Jernigan (grants expert and blogger extraordinaire) about what he’d be working on before he leaves for vacation. And I correctly predicted that the 2017 OMB Audit Requirements, Appendix XI – Compliance Supplement (2017 Supplement) would come out late on Wednesday, and I’d have to write this post. The Federal Register gave me hope on Monday. But all 1,667 pages didn’t appear on the OMB website until Wednesday. So, here go my highlights of what you need to know from this year’s edition. And luckily, we have Shane’s post from last year to follow. First, like last year, there aren’t too many changes. In fact, the Federal Register Notice lists the changes so that you don’t have to hunt and peck. From there, I recommend going straight to Appendix V within the 2017 Supplement for more details. Part 1 – Background, Purpose, and Applicability was mostly administrative (like new weblinks). Pay attention to the should and musts in this part. Part 2 – Matrix of Compliance Requirements follows last year’s format. But has quite a few changes to be consistent with changes elsewhere in the document. Part 3 – Compliance Requirements still has two sections. Before the Uniform Guidance and after the Uniform Guidance. I know that December 2014 seems like an eternity ago; there are outstanding awards that will follow the “old way.” This section also reflects the recently updated FAQs and extension of the procurement requirements grace period. Part 4 – Agency Program Requirements and Part 5 – Clusters of Programs reflect numerous technical changes. Look for CFDA numbers and clusters that apply to you for details. If I were a grantee, I’d want to make sure I understood what the changes might mean in preparation for any audit. Appendix VII – Other Audit Advisories, II. Effect of Changes to Compliance Requirements and Other Clusters piqued my interest. There are instructions on how to treat a program that has been removed from the Part 2 Matrix. Auditors will know better how to translate this. But I am able to say that if there was a finding in the previous year, it needs to pull forward. Read this carefully and refer to 2 CFR 200.518. PS: Section III of this Appendix states that ARRA findings also must pull forward.The part on Addition of New Program to an Other Cluster makes me want to whiteboard. If the language always trips you up like me, scroll down to the examples. Perhaps close to a whiteboard. I know it’s confusing the way it’s written. But remember, the goal is not to audit every program, every year. Before I end this – two more things. First, Read the FAQs. There are five updates to questions for Subpart F that correspond to the 2017 Supplement. Second, keep in mind that the 2017 Supplement isn’t just about the numbers. It’s about compliance with all of an award’s requirements. Shane – wish you were here. — The 2017 Supplement wasn’t the only big thing released in the past few weeks. We’ll catch you up on the Uniform Guidance Frequently Asked Questions and the DATA Act Pilot Program Report in our next edition of eCLIPS. Not a subscriber of eCLIPS? Sign up...

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A Midsummer Summary of Changing Grants Policy, Part 2

Posted by on Aug 7, 2017 in Grants & Assistance | 0 comments

A Midsummer Summary of Changing Grants Policy, Part 2

Part one of this two-part blog post covered changes to the grants application process on Grants.gov, and also the elimination of COFAR. Now, part two takes us through even more changes to grant policy made by the Office of Management and Budget (OMB) during their busy summer. So, whether you’re about to go on vacation, or you just got back (point being: don’t miss these updates), here’s the news and what it means: OMB Issues Guidance on Buy American Laws In June, the Secretary of Commerce and OMB Director jointly issued OMB Memorandum M-17-27, Assessment and Enforcement of Domestic Preferences in Accordance with Buy American Laws. The memorandum addressed the requirements in Executive Order 13788, “Buy American and Hire American.” The purpose of the executive order was to help ensure that Federal procurement and financial assistance awards maximize the use of goods, products, and materials produced in the United States. The memorandum stated that for Federal grants, “[T]here is no primary law that imposes the Buy American Laws as defined in E.O. 13788, and applicability varies by the authorizing and appropriation statutes imposed on the specific Federal financial assistance program.” E.O. 13788 requires agencies to evaluate and report on their oversight of Buy American laws. The OMB memorandum identified three items that Federal agencies will need to report regarding Federal grant awards: 1. Agency actions to review and update relevant agency guidance to grant recipients. 2. Intended agency actions to review and update internal agency procedures to implement relevant Buy American laws. 3. Agency recommendations to strengthen and apply Buy American laws through statutory, executive, regulatory, or administrative action. Grant recipients should review the terms and conditions of their awards and awarding agency guidance to determine what requirements, if any, to comply with Buy American laws. Procurement Grace Period Extended to Three Years The OMB announced an extension to the procurement grace period. OMB published a rule in the Federal Register on May 17 providing non-Federal entities an additional fiscal year to comply with the procurement standards under 2 CFR 200. OMB explained that the grace period extends through December 25, 2017 and non-Federal entities will need to comply with the procurement standards for the fiscal year beginning on or after December 26, 2017. Non-Federal entities that opt for the grace period must indicate their decision in internal policy manuals. Failure to note this decision may result in an audit finding. Still Waiting on 2017 Compliance Supplement, 2 CFR 200 Updates, and Revisions to the FAQS While the Federal government has taken many actions affecting grants in the last few months, there are still some outstanding items that we are waiting for: 2017 Compliance Supplement. The Compliance Supplement is the annual single audit guidance. OMB generally has a target release for the Compliance Supplement in the spring. However, for the last few years, the release date has generally been delayed until the summer. The previous delayed release dates have resulted in an extension for grant recipients to submit single audit reports to the Federal Audit Clearinghouse (FAC). The FAC has not yet posted an announcement providing guidance. 2 CFR 200 Updates. OMB has discussed plans to update 2 CFR 200 to incorporate recent legislative changes. Yet, there has been no specific date given when the updates may be released....

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A Midsummer Summary of Changing Grants Policy, Part 1

Posted by on Jul 28, 2017 in Grants & Assistance | 0 comments

A Midsummer Summary of Changing Grants Policy, Part 1

While summer is generally the time for taking a long vacation from work, officials at the Office of Management and Budget (OMB) have been busy revising grant policies. This two-part blog post discusses recent actions that you, a faithful member of the Federal grants community, need to be aware of immediately… or as soon as you get back from the beach, of course. So, without further ado… Grants.gov to Retire PDF Application Package Grants.gov will retire the legacy PDF application package by the end of 2017. Once this occurs, applicants will no longer be able to download the PDF application package and will be required to complete applications through the Workspace feature. However, applicants will be able to continue to submit the PDF application package through March 31, 2018. A February 2017 update to Grants.gov began the transition to online forms by enabling users to complete over 50 individual application forms through Workspace. Grants.gov launched Workspace in October 2015 and the feature is designed to: Streamline collaboration within an applicant organization Allow users to reuse previous application forms Validate forms to reduce submission errors Provide context-sensitive help for all pages, tabs, and windows within Workspace Grants.gov is in the continual process of modifying Workspace. Release 16.0, launched in June 2017, made the following changes to Workspace: Enabling Workspace Owners to customize user access to budget forms through form-level access privileges Allowing participants from other organizations, such as outside consultants and subrecipients, to complete forms within an application workspace OMB Eliminates the COFAR On June 15, OMB released memorandum M-17-26, Reducing Burden for Federal Agencies by Rescinding and Modifying OMB Memorandum, which eliminated, modified, or paused agency requirements in over 50 OMB memos, circulars, or other guidance. Many of the rescinded requirements relate to agency compliance with information technology guidance. Three documents, however, relate to grants management: M-12-01, Creation of the Council on Financial Assistance Reform M-14-17, Metrics for Uniform Guidance (2 CFR 200) Controller Alert, Catalog of Federal Domestic Assistance (CFDA) Numbering Schematic M-12-01 created the Council on Financial Assistance Reform (COFAR). The COFAR was an interagency working group charged with streamlining Federal financial assistance, which resulted in the implementation of 2 CFR 200 (aka the Uniform Guidance, or the Super Circular). The COFAR also developed training and Frequently Asked Questions to provide compliance guidance with the Uniform Guidance. M-17-26 delegates the responsibilities of the COFAR to the Chief Financial Officers (CFO) Council. Grants guidance on the COFAR website has already been migrated to the CFO Council website. In addition to eliminating the COFAR, M-17-26 also eliminates the requirement for agencies to report the metrics measuring the impact of 2 CFR 200 and to prepare for an expanded CFDA numbering schematic. The COFAR developed the Uniform Guidance Metrics to evaluate the extent to which the new requirements under 2 CFR 200 were reducing financial risk and enhancing evidence-based outcomes. There was no indication if the attempt to quantify the impact of 2 CFR 200 would continue. In December 2016, the CFO Council issued a notice to Federal agencies detailing the changes to the numbering schematic for the CFDA. The notice stated, effective October 2018, all CFDA program numbers would be changed from ##.### to ###.###. The prefix would align with the 3-digit Common Governmentwide Accounting Classification agency code and...

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DATA Act Compliance Has Arrived

Posted by on May 31, 2017 in Grants & Assistance, Workforce Management | 2 comments

DATA Act Compliance Has Arrived

Three years of planning the implementation of the Digital Accountability and Transparency Act (DATA Act) came to fruition on May 9, 2017 as Federal agencies were required to begin reporting spending by using governmentwide, standardized data elements. Prior to the DATA Act, agencies used differing data elements and definitions to report spending. Use of the Act’s open and uniform standards is meant to improve reliability and access to the government’s financial data. Nextgov.com reported that most agencies, in varying degrees, met the deadline of submitting financial data from the second quarter of fiscal year 2017. On the same day the DATA Act came into effect, the Treasury Department released a new beta version of USASpending.gov in accordance with the DATA Act requirements. Treasury describes the website as the “new official source of accessible, searchable and reliable spending data for the U.S. Government.” The data is open and machine-readable, and users can download and search through data sets. The data includes both agency appropriations and expenditures, including: grants, contracts, loans, and employee salaries. Agency compliance with the DATA Act remains a work in progress. On May 8, the House Committee on Oversight and Government Reform sent a letter to the Office of Management and Budget (OMB) and the Treasury requesting information on how each agency is responding to the recommendations from the Government Accountability Office (GAO) to improve the implementation of the DATA Act. The Committee requested the agencies respond by May 22, which have not been released. Additional provisions in the DATA Act also provide for the following upcoming milestones: August 7, 2017. OMB must submit a report to Congress detailing the results from the Section 5 pilot programs for grant recipients and contractors. The pilot programs tested different methods and procedures to reduce reporting redundancies and recipient burden. November 8, 2017. The GAO must issue a report evaluating agency compliance with the DATA Act. August 7, 2018. OMB must decide if grant recipients and contractors must use the DATA Act standards in financial reporting. As always, it’s important to stay up to date on all things related to the legally compliant administration of Federal grants. Our Federal Grants Update course keeps you current, and covers a wide variety of developments and updates in just one day of training. Also, check out our previous blog posts on DATA Act implementation, and subscribe to this blog (using the form on the upper right!) to receive the latest compliance news and updates for all things Federal...

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Grants Legal Issues Grab Headlines

Posted by on May 9, 2017 in Grants & Assistance | 0 comments

Grants Legal Issues Grab Headlines

And grants professionals should read them. If you’ve followed me and Shane via this blog and eClips, you’ve already read, “grants are policy tools,” in some form or the other. The Federal government uses grants to drive policy goals, objectives, and outcomes. Policies change with Administrations. And Congresses. I often am so focused on the activities of the Executive Branch, its activities, and its interactions with grantees that I block out an essential part of every single Federal financial assistance – Congressional authorization. Of course, when Congress originally authorizes a grant program, its original intent can be very different from the implementation of policies in the here and now. The requirement for the Executive Branch is to follow the authorizing laws for grant programs. There’s some flexibility. However, in court, the Congressional intent (the stated purpose of the grant program) comes significantly into play. Cue the Sanctuary Cities headlines. No matter which side of the issue you’re on, if you’re working in or with Federal grants, I recommend following the President’s Executive Order (E.O.) and its path through the courts. Read news stories at the local and national levels. If you’re brave, read the Order Granting the County Of Santa Clara’s and City and County of San Francisco’s Motions to Enjoin Section 9(A) of Executive Order 13768. Below are some of the issues that the grants community will need to follow with regards to this case. They’re also issues that apply to many if not all Federal grant programs. The E.O. does not define “sanctuary jurisdiction.” The law refers to Federal, State, and local entities. As a lay-person, “sanctuary jurisdiction,” may seem like it should be obvious. As a Federal grants program manager, the lack of clarity makes determining eligibility challenging. As a pass-through entity, perhaps working in multi-city partnership, you need to know whom you can work with. This is why reading the Eligibility section of each Notice of Funding Opportunity (NOFO) is essential. Separation of Powers. The ruling to enjoin the E.O. cites one reason as the President “improperly seeks to wield congressional spending powers.” Or more simply put, the President is saying, “spend the Federal government’s money with different terms and conditions as authorized by Congress.” Since 1974, this has been against the law. This also means that even if a Federal agency has been marked for elimination or reduction in the FY 2018 President’s Budget, it must issue grants appropriated in FY 2017. Federalism. We’re a Nation based on a union of separate States. The Federal government cannot exercise too much power over the States, including coercing States or other local jurisdictions to do something against what they determine as a local community. Such as withholding funds for not complying with an E.O. or other Federal law that has nothing to do with the grant program. This should be of particular interest for issuers and recipients of Education grants – and the Administration’s intent to pull back programs that may be seen as “national.” Local Budgets and Due Process (5th Amendment). This was the most interesting part of the judicial ruling for me to read. The Counties of Santa Clara and San Francisco “are threatened with the loss of federal grants and face a present injury in the form of budgetary uncertainty.” This portion of...

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Data and Grants: Patterns and Performance

Posted by on Apr 14, 2017 in Grants & Assistance | 3 comments

Data and Grants: Patterns and Performance

Earlier this month I checked in with my elementary school-aged son on what he’s doing in math. “Recognizing patterns,” he said. My first thought was, “Still? He’s been working on this since preschool.” A week later, I switched my thought to, “Of course they’re still working on this skill.” I had just gone back to the President’s budget seeking patterns to predict where grants are headed, especially with so many references to data pointing to a lack of success. My kid and his classmates are on to something. The ability to identify and communicate patterns—through performance measurement in grants work—is an essential skill in an environment of limited resources for policy implementation. Though it may feel like this goes without saying in our current era of accountability, a worthy point of emphasis continued by the business-meets-government mindset of the Trump administration, the patterns grants professionals are looking for are about basic and fundamental questions: Is there waste, fraud, and abuse of funds? Is reporting on time and regular? Are successes or issues being tracked and reacted to accordingly? Yet the patterns can be complex to determine without looking at the right data at the right time. But of course, we’re overwhelmed by data as grants professionals. And if you’re like me, you want to skip right to the fancy charts and dashboards. In any case, Data visualization tools and skills will make a difference in your decision making. If we want to get to those tools, we first need to make sure that we care for our data. This is why implementation of the DATA Act continues to be important. It also requires continued significant investments in systems, training, and collaboration. All of this work collecting, managing, and visualizing data will have benefits because of the patterns we will see. These patterns should help us better: Prioritize monitoring efforts Signal project risks sooner Identify trends across programs and projects (positive or negative) Fulfill the goal of linking performance and budget information So let’s roll up our sleeves and dive into the data together. We’ll all benefit, and develop our analytical and collaboration skills along the way. And if you happen to be attending NGMA in Arlington, April 18-20, stop by booth #14 and say...

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The Presidential Budget and Federal Grants

Posted by on Apr 5, 2017 in Grants & Assistance, Workforce Management | 1 comment

The Presidential Budget and Federal Grants

Why performance measures are more important than ever. On March 16, the Office of Management and Budget (OMB) released the Trump administration’s budget blueprint for Fiscal Year 2018. The purpose of the Presidential budget is to identify and explain the administration’s priorities and policy proposals. The Trump budget proposes funding decreases for nearly every Federal department, except for Homeland Security, Defense, and Veterans Affairs. Additionally, the budget proposes elimination for 19 independent agencies, including grant-awarding agencies such as the: African Development Foundation Appalachian Regional Commission Corporation for National and Community Service Delta Regional Authority Denali Commission Institute of Museum and Library Services National Endowment for the Arts National Endowment for the Humanities OMB has only released a budget blueprint, which provides a high-level statement of policy goals. OMB expects to release the full budget later this spring. Even without the line-by-line budget requests detailed in the full budget, the budget blueprint does provide significant guidance for the grants community. The budget blueprint proposes the following recommendations for specific grant programs and grant-awarding agencies: Department of Agriculture Eliminating the Water and Wastewater loan and grant program Reducing funding for Rural Business and Cooperative Service by $95 million Eliminating the McGovern-Dole International Food for Education program Department of Commerce Eliminating the Economic Development Administration Eliminating the Minority Business Development Agency Eliminating NOAA grants and programs supporting coastal and marine management, research, and education including Sea Grant Department of Education Increasing funding for charter schools, new private school choice program, and Title I Eliminating Supporting Effective Instruction State Grant programs Eliminating the 21st Century Community Learning Centers program Eliminating the Federal Supplemental Educational Opportunity Grant program Reducing the Federal TRIO and GEAR UP programs by $193 million Eliminating or reducing funding for over 20 categorical programs, including Striving Readers, Teacher Quality Partnership, Impact Aid Support Payments, and International Education programs Department of Energy Reducing $900 million from the Office of Science Eliminating the Weatherization Assistance Program and the State Energy Program Department of Health and Human Services Increasing SAMSHA funding by $500 million to expand opioid misuse prevention efforts Reducing NIH spending by $5.8 billion Restructuring similar HHS preparedness grants to “to reduce overlap and administrative costs and directs resources to states with the greatest need” Eliminating the discretionary programs within the Office of Community Services, including the Low Income Home Energy Assistance Program (LIHEAP) and the Community Services Block Grant (CSBG) Department of Homeland Security Eliminating or reducing State and local grant funding by $667 million including the Pre-Disaster Mitigation Grant Program, which is “unauthorized by Congress,” and Homeland Security Grant Program. Establishing a 25 percent non-Federal cost match for FEMA preparedness grant awards that currently require no cost match Department of Housing and Urban Development Eliminating the Community Development Block Grant program Devolving community and economic development activities to the State and local level.” Eliminating funding “for a number of lower priority programs,” such as: the Home Investment Partnerships Program, Choice Neighborhoods, and the Self-help Homeownership Opportunity Program Increasing funding by $20 million for the mitigation of lead-based paint and other hazards in low-income homes Eliminating funding for Section 4 Capacity Building for Community Development and Affordable Housing Department of the Interior Eliminating the Abandoned Mine Land grants, National Heritage Areas, and National Wildlife Refuge fund payments “[Reducing] funding for...

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Ode to Grant Professionals

Posted by on Mar 9, 2017 in Grants & Assistance | 0 comments

Ode to Grant Professionals

Have you ever had a run of unexpected events that seems to leave you knocked down? But you get up again. And again. And again. And when you get up, if you are lucky enough to be a grant professional, you’ve often got someone pushing or pulling you up. Here are my top 5 reasons why. Grant Professionals collaborate. The nature of the grants process means that you’ve got to work with at least one other person to get anything done. And even if you’re a one-person shop, you’re part of a professional network to bounce ideas around to find the right solution. Grant Professionals know when and how to ask for help. Because we have to collaborate, we know and understand that deadlines pop up, subject-matter expertise may be in someone else’s brain, and that outside editors are our friends. Grant Professionals try new things. At some point in every grant professionals career, we were something else. So when someone says, “Have you heard about this opportunity,” we’ll listen. And we’ll see if we can make it work. Grant Professionals understand that it’s in the details. So when we’re trying to figure out how to make it work, most of us are automatically thinking about the execution if we win – from reporting to staffing to the next proposal. Managing grants is a complex and often bureaucratic business. Grants Professionals are nice. I find myself reading more and more articles on the importance of employee engagement and positive workplaces. I’ve been lucky thus far to find that this is the case with grant professionals. We’re a group to celebrate the wins and learn from the losses, even when having to slog through many different projects. I hope that most of you have been enjoying International Grant Professionals Week. Please check the www.grantprofessionals.org website for more information. And if you’re reading this in time, and you’re in Washington, D.C. on Friday, March 10, meet the National Capital Area Chapter for breakfast at the Hamilton downtown at 8:30...

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The New Administration Signals Potential Changes for Grants Management

Posted by on Feb 1, 2017 in Grants & Assistance, Uncategorized | 4 comments

The New Administration Signals Potential Changes for Grants Management

Since the inauguration, the Trump administration has taken significant action, through executive orders and memorandums, which may affect Federal grants. The extent to which grants management will be impacted is still unclear; however, it is important for Federal awarding agencies and grant recipients to keep themselves informed. Here’s our rundown of what’s happened, what’s happening, and what’s on the horizon: One immediate impact for the grants community is that the Office of Management and Budget (OMB) website is currently not available. The OMB website contains grants-related documents such as the 2016 Compliance Supplement, guidance on 2 CFR 200, and required grant forms. Fortunately, the OMB website has been archived and grants-related documents can be accessed here and required grant forms can be accessed through Grants.gov or through the websites of funding agencies. For the Environmental Protection Agency (EPA), there was initially some confusion regarding an email sent to employees following the inauguration. The Washington Post reported that the email read, “New EPA administration has asked that all contract and grant awards be temporarily suspended, effective immediately.” One week later, on January 27, the Acting Administrator for the EPA announced via email that the temporary freeze had been lifted. The White House also issued a memorandum that institutes a governmentwide hiring freeze for all new and existing positions. The directive exempts positions related to the military, national security, and public safety. On January 25, OMB released a memo providing additional details regarding the hiring freeze. Federal News Radio posted a copy of the memo on its website. The hiring freeze will likely affect grants by reducing Federal personnel, which may delay making awards and reduce monitoring. Another memorandum, entitled “Regulator Freeze Pending Review,” prevents agencies from implementing new regulations until a Presidential appointee has assumed office for the agency. Additionally, any approved regulation that has not taken effect has been delayed for 60 days. OMB was currently in the process of amending 2 CFR 200, and the memorandum will likely delay the release of any changes. Finally, on January 30, an executive order was issued requiring agencies to repeal two regulations for every proposed regulation. The executive order directs OMB to issue further guidance, so the extent to which grants management will be affected is unknown. The grants community should closely follow this year’s budget. The White House is required to release the proposed budget on February 6, but, as Roll Call notes, new administrations are frequently late. The proposed budget will provide significant insight into the administration’s funding priorities. To help you stay informed of all the changes, Management Concepts Federal Grants Update Course provides training and guidance. We will also continue to update our blog page as new developments occur. Stay tuned and stay informed—subscribe to our blog, and keep the discussion going by commenting...

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How a Member of the Grants Community Prepares for 2017

Posted by on Jan 5, 2017 in Grants & Assistance | 2 comments

How a Member of the Grants Community Prepares for 2017

What a year. And I’m not just talking about what you’re reading in your Facebook and Twitter feeds. We managed to launch or revise six grants courses, including Internal Controls for the Federal Grants Community. These were a labor of love, and I’m excited to see how you like what we did in the classroom. But it’s early January, and it’s time to make my top 5 New Year’s resolutions for work. Feel free to share yours with me – because as we know in the grants world, crowd-sourcing is essential. 1. Figure out what the impact of the NDAA language is. Did you read Shane Jernigan’s December post? Did you see this: The first bill that may impact the research community is the National Defense Authorization Act (NDAA) for Fiscal Year 2017. Section 217 of NDAA: Increases the micro-purchase threshold for basic research programs and activities under the Department of Defense; and Adjusts the micro-purchase threshold for universities, independent research institutes, and nonprofit research organizations by: Increasing the micro-purchase threshold to $10,000; or At a higher threshold as determined by an agency and consistent with clean audit findings, internal institutional risk assessment, or state law. Say what? As a reminder, the NDAA often has language that makes changes to the Federal Acquisition Regulation (FAR), which in turn can affect grants. When I read this, it seems like some very specific grantee (and contractor) entities have a micro-purchase loophole. But I have no idea how this is going to work in practice. Is this going to vary by agency? Or is an entity going to be able to request a higher threshold from their cognizant agency, and then say that’s it? What if the entity is a subawardee receiving pass-through funds from an entity still held to the $3,500 threshold? Please comment if you have thoughts on this. 2. Check the Federal Register for anticipated changes to 2 CFR 200. We’ve seen some talk during the past few weeks that OMB is working on updates to bring some consistency with the DATA Act. Hopefully this will be something we can celebrate. 3. Continue to learn more about data management and visualization. After decades of relying on Excel, I think it’s time to update my skills and know-how when it comes to organizing data and sharing what I learned. But before I take one of Management Concepts Analytics courses, I should start with the data chaos that is my messy desk. 4. Work on another webinar. I really enjoyed working with my colleagues on the “Get Your DATA Act Together” webinar last summer. If you have an idea for a topic you’d like to know a bit more about, please let me know in the comments section. 5. Think about my 35-year plan. I know – what happened to the five-year plan? But in all seriousness, I’ve got to be honest with myself that I can’t imagine not working. That and I’ve got to be able to recover from my son’s college tuition. So that means learning from those who have had not one, but two or three long-term careers like our colleague, Chuck Williams. He provides our team with not only knowledge about our students and business, but inspiration that you can keep learning and growing for the long...

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2 CFR 200 Turns Two: The Research Community Seeks Greater Independence

Posted by on Dec 20, 2016 in Grants & Assistance | 0 comments

2 CFR 200 Turns Two: The Research Community Seeks Greater Independence

It seems like just yesterday that I was spending my vacation frantically reading the interim final rule for 2 CFR 200. As other members of my family were making final preparations for our holiday, I was busy trying to decipher the new personal compensation requirements and attempting to figure out how best to update Management Concepts grants curriculum. As the Uniform Guidance turns two, the grants community is entering that familiar developmental stage known as the “terrible twos.” To borrow from the Mayo Clinic’s explanation of this phase, “The terrible twos is a normal stage in which toddlers begin to struggle between their reliance on adults and their desire for independence. One minute your child might be clinging to you, and the next he or she is running in the opposite direction.” I think this is a great description for the current stage of the Uniform Guidance. With the implementation of 2 CFR 200, the Office of Management and Budget (OMB) sought to bring uniformity to grants management. What we are now beginning to see is the desire by some non-federal entities to begin exerting their independence and to have more flexibility with their federal awards. This strive for independence is particularly apparent with the research community, as the research community faces challenges in managing federal awards not common to other entities In December, Congress passed two bills that would provide the research community with specific exceptions to the requirements under 2 CFR 200. The first bill that may impact the research community is the National Defense Authorization Act (NDAA) for Fiscal Year 2017. Section 217 of NDAA: Increases the micro-purchase threshold for basic research programs and activities under the Department of Defense; and Adjusts the micro-purchase threshold for universities, independent research institutes, and nonprofit research organizations by: Increasing the micro-purchase threshold to $10,000; or At a higher threshold as determined by an agency and consistent with clean audit findings, internal institutional risk assessment, or state law. President Obama has not yet signed the NDAA into law. The 21st Century Cures Act, which President Obama signed into law on December 13, also contains multiple provisions in Section 2034 related to the research community, including: Establishing a research policy board to make recommendations “[r]egarding the modification and harmonization of regulations and policies having similar purposes across research funding agencies” and to minimize recipient burden; Directing the Director of the National Institutes of Health (NIH) to implement measures to reduce the administrative burdens related to monitoring of subrecipients of grants, including a potential exemption from subrecipient monitoring requirements; Requiring the Secretary of Health and Human Services (HHS) to collaborate with the NIH Director to “evaluate financial expenditure reporting procedures and requirements for recipients of funding” from NIH and to minimize recipient burden; and Mandating that HHS clarify the applicability of the requirements under 2 CFR 200 “regarding documentation of personnel expenses, including clarification of the extent to which any flexibility to such requirements…applies to entities receiving grants” from HHS. Any actions from HHS to implement the law’s requirements will take some time to come to fruition. Based on the success of the research community in obtaining greater independence, it will be interesting to see if other non-federal entities will also begin to seek entity-specific exceptions to the Uniform Guidance. For example,...

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Five Months Until the DATA Act Deadline: An Implementation Update

Posted by on Dec 12, 2016 in Grants & Assistance | 0 comments

Five Months Until the DATA Act Deadline: An Implementation Update

The deadline for agency implementation of the Digital Accountability and Transparency Act (DATA Act) is just five months away. By May 8, 2017, all Federal agencies must comply with the DATA Act, which requires agencies to report spending data using the governmentwide data standards. The DATA Act is designed to increase transparency of Federal spending by publishing all Federal spending on USASpending.gov. Additionally, the DATA Act will, for the first time, track Federal spending throughout the entire Federal spending lifecycle. Since President Obama signed the DATA Act into law in May 2014, Federal agencies have been developing plans, instituting new information systems, and testing their ability to meet the law’s requirements. Implementing the law has required a tremendous governmentwide undertaking to compile and validate data from hundreds of non-integrated computer systems across the Federal government. On December 8, 2016, the House Subcommittee on Government Operations held a hearing entitled “DATA Act Implementation Check-in.” The Subcommittee heard from representatives from the Government Accountability Office (GAO), the Office of Management and Budget (OMB), and three Federal agencies. On the same day as the hearing, the GAO released a new report, “DATA Act: OMB and Treasury Have Issued Additional Guidance and Have Improved Pilot Design But Implementation Challenges Remain,” which examined the government’s progress to meeting the law’s requirements. At the Subcommittee hearing, the GAO testified that significant steps have been taken “toward implementing the act’s various requirements,” but significant challenges remain to meet the May 2017 deadline. Based on their review of the 24 Chief Financial Officers (CFO) Agencies’ implementation plans, GAO identified the following challenges: Systems integration – Nineteen agencies reported difficulties related to systems integration, including: systems limitations, modernization efforts, and timing. The GAO stated that the “lack of properly integrated systems increases the risk that agencies may have difficulty in compiling and validating the information they are required to report under the DATA Act by May 2017.” Resources – The 24 CFO agencies reported that they need a total of $202.4 million in funding to complete the implementation process. Reporting – Thirteen agencies expressed concern regarding the DATA Act’s reporting requirements and their ability to report all the required data elements in the initial DATA Act submission. Guidance – 11 agencies cited as a hindrance the ongoing changes to OMB policy and Treasury Guidance. OMB stated that “because of the lack of timely and consistent guidance, agencies may need to continuously update or change their processes, which could adversely affect their ability to meet the DATA Act requirements.” To mitigate these problems, GAO identified seven strategies that agencies are currently using: Making changes to internal policies and procedures Leveraging existing resources Using external resources Continuing communications Employing manual and temporary workarounds Monitoring and developing guidance Enhancing current systems During the Subcommittee hearing, OMB testified that “significant” progress has been made and highlighted steps that have been taken to further the implementation process, including: Issuing additional guidance Continued monitoring of agency implementation through individual agency visits Establishing a governing structure for USASpending.gov data standards Creating the Data Standard Committee, composed of representatives from across the government, to maintain and further enhance the data standards Officials from the Treasury Department and the Small Business Administration (SBA) highlighted their respective agency’s successes and achievements. David Lebryk testified that the “Treasury is...

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#GPAConf16: Good Times and IDC Dreams

Posted by on Nov 16, 2016 in Grants & Assistance | 0 comments

#GPAConf16: Good Times and IDC Dreams

I had such a good time at the 2016 Grant Professionals Association National Conference that I think I need a week to recover. I enjoyed meeting and reconnecting with colleagues from around the country who are dedicated to making the world a better place through grants. But there is a dark side to going to events like this—you might go to a session on a topic that causes you to look at things from another perspective. And this perspective interrupts your dream cycle with scenarios and spreadsheets on indirect cost (IDC) rates. As the person responsible for our grants curriculum, I think that it’s important to check in on what the others are saying about topics covered in our classes, like indirect costs. So, I think that I have a good handle on the underpinnings of what indirect costs are at any organization—those things that require financial resources to do business, and can’t be charged directly to a project. Think health insurance (hey, it’s open enrollment season). Like most things, indirect costs through the lens of Federal grants get a bit more complex. For instance, taxpayers don’t want to pay for fundraising costs, even indirectly. In other instances, a program’s authorizing statute might limit indirect cost recovery to something like 8%. Note: there is a reason we offer a two-day course on this subject. And then I learned that many foundations only allow direct costs or cap the IDC rate at 10-20%. So, if an organization is savvy and lucky, it has multiple streams of grants revenue. And it’s conceivable that each award has a different rate. Let’s look at a hypothetical situation, represented in the table below, of a recipient organization with four IDC rates from four different funders. Looking at this situation, I think you’d agree that: This is a complex situation You don’t know the organization’s overall IDC rate I heard many insightful questions posed to experts on whether or not to pursue a negotiated IDC rate with their Federal cognizant agency, to use the de minimis rate allowed in 2 CFR 200, or to seek recovery of IDCs at all. Managing all of the variety of IDC rates is complex—and costly. That said, I am of the opinion that avoiding the complexity and cost creates long-term risk in many cases. At the strategic level, when you don’t recognize the total cost of carrying out your mission, you may inadvertently signal to your funders a gap in your organization’s business acumen. Tactically, you may miss the opportunity to recover some of the real costs of maintaining insurance, making payroll, and promoting your organization’s mission. I want to close out with my most recent IDC dream: I win the lottery and then set up a foundation that funds the establishment and maintenance of IDC rates. I could be a winner. I’d like to credit Dr. Richard Redfearn from the University of Arkansas and the participants who peppered him with questions for inspiring this...

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Open Data: Your Future, Your Now

Posted by on Sep 30, 2016 in Analytics, Grants & Assistance | 0 comments

Open Data: Your Future, Your Now

I spent a lot of time this summer focused on our curriculum for pass-through entities (PTE) and recipients alongside implementation of the DATA Act. This past Wednesday, I took the opportunity to reflect on  these topics while I attended the Data Transparency 2016 + White House Open Data Innovation Summit. I approached my day from the perspective of what can I share with non-Federal entities (NFE). Here are my key takeaways: Open Data in Ecosystems. The question of the day seemed to be, “we have the data, now how do we use it.” From the White House Chief Technology Officer to the most junior participant, there was a strong understanding that open data has to be made and used in ecosystems.  We know that ecosystems are made of people and it’s a good reminder that data by itself is worthless unless it’s used. That means you need to seek ways to share your data, and find users. It also shows how important leadership, communication, and collaboration skills are in this space. NFEs can (and should) participate in DATA Act implementation efforts. In case you didn’t know, gov is in beta testing now.  I was able to add my small suggestion of what I want changed and then I had a great conversation with some members of the USAspending.gov team. I found out that I could help with some of the beta testing….and so can you. Think about what you’re not getting out of the data now, log onto the beta site, and be an active stakeholder.You also still have time to participate in the Section 5 Pilots. The HHS DATA Act Program Management Office (DAP) continues to seek feedback on the proposed improvements on the Federal Financial Report, Single Audit, Center for Drug Evaluation and Research library, Notice of Award, and Learn Grants. So if you have any issues with definitions or forms, speak up. So many resources are available to use now. One thing that I have found hard is figuring out what to do about the DATA Act now, besides keeping up-to-date and participating in pilots, if you’re a NFE. Part of the impact of the DATA Act and the open data movement in government is already available in the form of publicly available information. NFEs need to learn more about these data sets. Many of us know that the Census Bureau has many data sets available for you to use in your grant applications and project approaches. Or if you’re a pass-through entity, information to help inform your subrecipient risk assessments. Here’s some of what I found just by walking around the information tables: gov – 200K+ searchable data sets (start here) Global Innovation Exchange – Brings together information on funders, innovators, and resources in the development area; and not just US sources EPA Environmental Dataset Gateway – Information on climate change resources, maps and other information supportive of research and environmental justice Transportation Secure Data Center – Wide range of transit, energy, and homeland security information in one place With so much data available and crisp fall air moving in, pour yourself a nice cup of tea and explore visualization tools and resources to increase your knowledge of the varied uses of...

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Federal-Wide Research Terms and Conditions

Posted by on Sep 6, 2016 in Grants & Assistance | 0 comments

Federal-Wide Research Terms and Conditions

Last October, the National Science Foundation (NSF) published proposed Research Terms and Conditions (RTCs) for Federal awards. The proposed RTCs update the current RTCs by implementing the requirements under 2 CFR 200. In some instances, the proposed RTCs modify the requirements under 2 CFR 200 to address the unique nature of research awards. The Federal Register notice stated that the “use of RTCs is envisioned as a streamlined approach that supports the implementation of the Uniform Guidance by providing clarification, supplementary guidance, and, where appropriate, selected options, while meeting the spirting and intent of a uniform implementation.” The NSF developed a crosswalk that identifies the differences between 2 CFR 200 and the proposed RTCs. All provisions in 2 CFR 200 would apply to research awards unless identified on the crosswalk. Upon final completion and approval of the RTCs, the Federal research awarding agencies will release three appendices to the RTCs: Appendix A, Prior Approval Matrix Appendix B, Subaward Requirements Matrix Appendix C, National Policy Requirements Matrix The NSF is the lead agency on developing the RTCs. Others Federal agencies participating in the development process include: Department of Commerce – National Institute of Standards and Technology (NIST) Department of Commerce – National Oceanic and Atmospheric Administration (NOAA) Department of Energy Department of Health and Human Services – National Institutes of Health (NIH) Department of Homeland Security Department of Transportation – Federal Aviation Administration Environmental Protection Agency National Aeronautics and Space Administration (NASA) National Science Foundation U.S. Department of Agriculture – National Institute of Food and Agriculture The NSF has not announced when the RTCs will be finalized. In the Federal Register Notice, the NSF wrote: “After obtaining and considering public comment, the [Interagency Working Group] will prepare the format for final clearance.” The public comment period closed on December 14, 2015 and the NSF received two comments. The Government Accountability Office (GAO) released a report in June 2016 entitled Federal Research Grants: Opportunities Remain for Agencies to Streamline Administrative Requirements. The GAO report provides extensive background to the development of the RTCs and made recommendations to reduce recipient administrative...

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The DATA Act: Expanding Open Data and Transparency

Posted by on Aug 29, 2016 in Grants & Assistance | 0 comments

The DATA Act: Expanding Open Data and Transparency

Last week, I had the opportunity to present Management Concepts’ “Get Your DATA Act Together” webinar. The Digital Accountability and Transparency Act (DATA Act) is designed to enhance transparency of Federal spending by making all public spending, throughout the entire spending lifecycle, available to the public in a searchable and downloadable format. In the webinar, we looked at how the DATA Act will affect the roles and job functions for anyone involved with awarding or reporting Federal spending. Federal employees will need to ensure spending data is accurate, consistent, and complete Federal financial officers will need to develop data analytic tools to synthesis their agency’s spending data and verify adequate controls are in place to guarantee the accuracy of submitted data Federal managers need to take the proper steps to train employees on the new spending data standards and that all employees understand their responsibilities under the DATA Act Grantees and contractors should review the 57 governmentwide financial data standards to understand the information that Federal awarding agencies will be collecting regarding their awards Starting on May 8, 2017, all Federal agencies must begin reporting their spending data using the governmentwide financial data standards. In preparation of this deadline, the Government Accountability Office (GAO) provides frequent updates on implementation of the DATA Act. In the past month, GAO issued two reports: DATA Act: Improvements Needed in Reviewing Agency Implementation Plans and Monitoring Progress (GAO-16-698) The GAO examined agency DATA Act implementation plans and found none of the 42 plans agencies submitted to OMB and the Department of the Treasury addressed all  51 plan elements found in implementation guidance. GAO recommended additional documented internal controls and processes to ensure agency implementation. DATA Act: Initial Observations on Technical Implementation (GAO-16-824R) The GAO examined the implementation of the IT infrastructure to integrate Federal systems in accordance with the DATA Act. The GAO did not make recommendations in the report. On August 12, 2016, Chief Financial Officers (CFO) Act agencies submitted their latest implementation plans to the Office of Management and Budget (OMB). The implementation plans discussed: Recent agency progress and milestones Anticipated additional costs to implementing the DATA Act Updated risks and a risk mitigation strategy Hopefully the new implementation plans will alleviate the GAO’s concerns. We also need to keep our eye on Congress. In addition to the DATA Act, Congress continues to look at ways to further expand open data requirements across the Federal government. In May 2016, the Senate Homeland Security and Governmental Affairs Committee approved the Open, Public, Electronic, and Necessary Government Data Act (OPEN Government Data Act). This legislation would codify Executive Order 13642, Making Open and Machine Readable the New Default for Government Information. The bill would require Federal agencies to: Make their enterprise data inventories available to the public in an open format on Data.gov Designate a point of contact to assist the public and respond to complaints about adherence to open data requirements An identical bill has also been referred to the House Oversight and Government Reform Committee, which has not taken any action yet. The concepts of open data, accountability, and transparency are not new to the Federal government. These concepts have been a driving force for the Federal government for the last decade, and the DATA Act is an extension of those...

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DATA Act Implementation Impact

Posted by on Aug 8, 2016 in Grants & Assistance, Workforce Management | 1 comment

DATA Act Implementation Impact

If you’ve already read the two DATA Act reports issued by the GAO since late July, you already know that the government watchdog has documented its concerns about DATA Act implementation. It’s only eight months away. One of the things that surprised me is that OMB still does not have a complete list of the Federal agencies that will need to be DATA Act compliant. I understand the approach of starting with the 24 CFO agencies – but what about the goal of having transparency on every Federal dollar spent? Between this lack of clarity and the release of the DAIMS just in May 2016, it makes sense why we’re hearing, “I know about the DATA Act. But how is it going to affect me?” And if you haven’t, looking at data schema and dictionaries in an effort to understand what’s happening may make your eyes roll back into the back of your head. If you fall into this group, I recommend taking these initial actions: Keep the “So What” in mind. The Public, Congress, and Federal government should know who receives Federal funds from contracts and grants. In our day-to-day work of processing transactions and reports, it’s easy to lose sight that these funds are part of large investments in government services and policies to benefit the public. Find out more. Participate in our complimentary webinar on August 18. We’ll share with you the essential information you need to get started on your DATA Act journey, and share resources so you can keep current. Expect to use data more – because you’ll have more of it. The congressional team that drafted the DATA Act did so with the intention and expectation of receiving more and more accurate information on the government’s fiscal activities. We all need to increase our abilities to analyze and present data in support of our organization’s mission and goals. Ask around. The DATA Act won’t be successful unless all Federal agencies work together. Ask your colleagues if they’ve heard about this important law. If yes, inquire if they are working on implementation efforts and how they’re going. If you’re ready to go to the next step, I’d start with the data definitions. Why? Because for the DATA Act to work, we need to start speaking the same language (and ensure our systems do as well).  I like to think of this as we all understand what personal income is thanks to the fact we all complete our Federal income tax returns. It doesn’t matter what our background is or where we work. Using the same terms has the additional benefit of making it easier to discuss the impacts as the government continues to plan and execute the implementation. This is especially important as agencies work to catch up from earlier delays. It’s going to be a long journey.  Better information to base decisions on will be worth the...

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OMB Releases 2016 Compliance Supplement and the Revised SF-SAC Form

Posted by on Aug 3, 2016 in Grants & Assistance | 1 comment

OMB Releases 2016 Compliance Supplement and the Revised SF-SAC Form

Last week, I wrote about my daily disappointment in waiting for the release of the 2016 Compliance Supplement and the revised SF-SAC Form. Well, good news, both documents are now available. On Monday, the Office of Management and Budget (OMB) published the 2016 Compliance Supplement on the Office of Federal Financial Management Single Audit webpage. This year’s Compliance Supplement is currently not available through the Federal Register or on the OMB’s Circulars webpage, as in previous years. Fortunately, with all the recent changes to grants management, this year’s Compliance Supplement does not present too many changes! As I read through it, I highlighted the following items: Part 1 – Background, Purpose, and Applicability: The Compliance Supplement has been updated with the appropriate usage of the words should and must under 2 CFR 200, provisions and statements using “should” represent a recommended or best practice, and statements using the word “must” indicate required actions. Part 2 – Matrix of Compliance Requirements: On this year’s matrix, OMB now indicates with a “Y” or an “N” which of the 12 compliance requirements are applicable to each Federal program. In previous years, OMB used a gray box to indicate a requirement’s applicability. Part 3 – Compliance Requirements: OMB retains the 12 compliance requirements for Federal programs and provides guidance on how to audit awards made before December 14, 2016, located in Part 3.1, and for awards subject to the provisions under 2 CFR 200, located in Part 3.2. OMB has also revised Part 3 to indicate the effect of additional Frequently Asked Questions that may be published within the next year. Part 3 also highlights that the micro-purchase procurement threshold was increased to $3,500 last year. Part 6 – Internal Controls: This year’s Compliance Supplement provides guidance on internal controls. Last year, OMB removed this section due to time constraints. Part 6 provides suggestions to both auditors and non-Federal entities on implementing and evaluating internal controls based on the principles found in the “Standards for Internal Control in the Federal Government” (Green Book) and the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission. Under 2 CFR 200.303, a non-Federal entity’s internal controls should be in compliance with these principles. Appendices: Appendix II, Federal Agency Codification of Governmentwide Requirements and Guidance for Grants and Cooperative Agreements, provides a useful table indicating the location of each agency’s implementation regulations Appendix VII, Other Audit Advisories, provides additional audit guidance. I found the discussion in Part I, Effect of Implementation of the Uniform Guidance on Major Program Determination, insightful. OMB has identified a significant transition issue regarding major program determination that could potentially increase the audit burden for some non-Federal entities in the third fiscal year under 2 CFR 200. To alleviate this potential problem, OMB gives auditors leeway to audit some low-risk Type A programs as additional major programs in the first and second fiscal years. Grants administrators and auditors should also carefully review Appendix V, List of Changes for the 2016 Compliance Supplement, to identify any compliance requirement changes for specific grant programs. The Federal Audit Clearinghouse (FAC) has published the revised SF-SAC Form to be used for all audits conducted under 2 CFR 200. As with the Compliance Supplement, OMB has not yet published a notice in...

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Anticipation Builds for OMB Audit Guidance

Posted by on Jul 26, 2016 in Grants & Assistance | 0 comments

Anticipation Builds for OMB Audit Guidance

For the last few weeks, the first thing I do after making my first cup of coffee is to frantically check the Federal Register. I open my browser, click on the “current issue” link, and hold my breath. Then, as is becoming all too familiar, severe disappointment sets in — there’s nothing new from the Office of Management and Budget (OMB). OMB is scheduled to release two important documents relating to audits of Federal grants: the 2016 Compliance Supplement and the revised SF-SAC form. The annual compliance supplement is guidance designed to assist auditors conducting single audits and to determine recipient compliance with applicable Federal laws and requirements. The SF-SAC form is the data collection worksheet auditors complete which summarizes audit results. The three portions of the compliance supplement that will be fascinating to see this year are: Part 3 – Compliance Requirements. Last year, Part 3 contained two subparts; Part 3.1 applied to audits for awards issued before December 26, 2014, and Part 3.2, which discussed audit requirements for awards made under 2 CFR 200. I am interested to see what additional guidance OMB provides regarding this bifurcated audit process and if any additional guidance or insight is provided regarding audits under 2 CFR 200. Part 6 – Internal Controls. Part 6 is designed to assist auditors test a recipient’s internal controls and can also be used by grant recipients to develop and implement effective control over their Federal awards. 2 CFR 200.303 requires non-federal entities to develop and implement internal controls and suggests the use of either the COSO Internal Control-Integrated Framework or the Standards for Internal Control in the Federal Government, known as the “Green Book.” In 2015, OMB was unable to update Part 6 in a timely manner and removed it from the compliance supplement. According to rumors, the 2016 Compliance Supplement will contain updated internal control guidance. Appendix 5 – List of Changes. This appendix provides all updates and revisions from the previous compliance supplement and is first item I review each year. The SF-SAC form is a required element of the single audit reporting package under 2 CFR200.512(b)(1). OMB is currently revising the form to align the data elements with 2 CFR 200. OMB published a notice and request for comments regarding the new form in the Federal Register on December 9, 2015. On April 22, 2016, OMB published a second notice and request for comments. The proposed SF-SAC can be viewed here. Without the approved SF-SAC, auditees are unable to submit a single audit reporting package to the Federal Audit Clearinghouse (FAC). As a result of the delayed approval process, OMB has provided an extension for submitting the single audit reporting package until September 19, 2016.  This is the second extension OMB has granted. The original extended deadline was July 31, 2016, but OMB recently provided a further extension. It is important to note that the extension is for submitting the audit, not for conducting the audit. Auditees should also be aware that the extension is for single audits conducted under 2 CFR 200, and A-133 single audits must still be submitted on time through the FAC. OMB previously announced the 2016 Compliance Supplement would be released in “mid-July” and based on the deadline extension for submitting the audit reporting package to...

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Sustainability – Looking Beyond Federal Funding

Posted by on Jul 18, 2016 in Grants & Assistance | 0 comments

Sustainability – Looking Beyond Federal Funding

Last week, I had a generational difference moment during the week’s Grant Chat – using virtual reality as a method of communicating and demonstrating grant recipient performance. Not only was I searching for the tools called out by my colleagues (Fyuse, anyone?), but I also was struck by the thought that staying current with technology options is one aspect to sustaining an organization’s mission and projects. But maybe not the most important aspect for a grant-funded organization. During the past few months, I’ve seen and heard more people asking about project sustainability. I see this as a natural outcome of increased competition for Federal funds, uncertainty in the Federal budget process, and recognition that grants can and do end. So where to begin? Let’s start with the concept that project sustainability ties to performance. Thanks to 2 CFR 200, FAPIIS, and SAM.gov, we now live in a Federal grants world where consideration of past performance is the expectation. Non-Federal Entities (NFE) that want to continue to seek and receive Federal grants therefore need to (continue to) apply all of their grants management and administration know-how on a regular basis. This includes managing a project’s schedule, scope, and cost as well as submitting financial and performance reports on time and accurately. Fortunately, demonstration of good performance for a Federal grant can be used as “evidence” when seeking non-Federal funding. At the same time, NFEs should build sustainment into their internal grants processes. For example, a university could add sustainment elements to their internal review criteria when considering which applications and projects to submit for Federal funding. This would force the primary investigator or applicant to think about their long-term prospects and plans for their project or effort. Consider this the change from “if” to “when” Federal funding streams will end. I also recommend expanding a project’s scope beyond the parameters of a Federal grant award to include things like: Stakeholders representing future budget streams (ex. Operating Budget Office) Documented risks for activities without sustainment funds and resources Milestones for budget transfer and fundraising goals For instance, when a fire department is applying for a new cache of radios based on the current state-of-the-art technology, it needs to factor in the anticipated maintenance and operations that are often ineligible for Federal funds.  Does the department have support from their city council to use tax dollars to cover those costs? What about making sure the new equipment is interoperable with the 5-year-old 911 system?  Can virtual reality capabilities be added to the radios? Is the equipment usable if funding for maintenance and operations doesn’t come to fruition? Of course, finding and applying for additional sources of revenue takes a lot of time and effort. For instance, 93% of respondents to the Spring 2016 State of GrantseekingTM Survey received one award when submitting at least three applications. That means that NFEs need to include their leadership to: Educate their governing bodies on their institutional long-term needs and goals with aggregated information on funding, performance, and risk Reinforce understanding that Federal funding is discretionary Build capacity to find, secure, and manage new funding streams This is only a start on ways NFEs can improve how they factor in long-term project sustainability. Please share your success stories in the comment...

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It’s About Control

Posted by on Jun 20, 2016 in Grants & Assistance | 0 comments

It’s About Control

I had the opportunity to spend two days with a local agency and our instructor Patrick Smith. We had a good time tackling the issues of 2 CFR 200 implementation. But we know that this agency has identified a lot of follow up tasks. Some are small, while others will require full project and communications plans. By the time we arrived for the training, these local agency officials had taken the most important step – informing their leadership that they need to make policy, procedure, and systems changes to become fully compliant with 2 CFR 200. As Patrick said throughout the two days, “management sets the tone” for how well an organization’s internal controls will be adopted and followed. Here are some of my other takeaways: Non-Federal Entities (NFE) taking advantage of the procurement policy grace period need to make sure they’ve documented this with their awarding Federal agencies. You may remember last fall, the Office of Management and Budget extended the deadline for incorporating applicable 2 CFR 200 procurement provisions into NFE policies. Adoption of the current micropurchase and Simple Acquisition Threshold levels require more than policy changes. You need to think about the impact of the changes in terms of volume (i.e., lower micropurchase level means more transactions needing more than one bid), and procedure change (e.g., certain purchases can no longer be done with a purchase card). Not to mention, how you’re going to communicate changes to all staff. The FAIN (Federal Award Identification Number) should go everywhere. The FAIN is a small detail, but essential for achieving transparency. That means if you are a Pass-Through Entity (PTE), you need to make sure that you mark all subaward documents with your FAIN. Remember, a key tenet of grant reform is transparency – the public should be able to follow the money. Finally, I don’t think I could do the subrecipient vs. contractor exercise enough. Even when it seems clear after a review of the Federal Grant and Cooperative Agreement Act‘s delineation between a grant and a contract, I think you need to take a look at each individual transaction. It’s essential that PTEs choose the right instrument…otherwise you may miss flowing down the appropriate Federal requirements. Uniform Guidance implementation is hard – and if you’re an NFE, your to-do list probably remains long. Remember you should tackle issues one step at a time and ask for help when needed. I continue to challenge anyone to show me an NFE that is fully compliant with 2 CFR...

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Grants.gov: Applying for Grants Made Easier

Posted by on Jun 15, 2016 in Grants & Assistance | 3 comments

Grants.gov: Applying for Grants Made Easier

As most grants applicants have experienced, applying for a grant is a team effort. Individuals may be tasked with separate responsibilities, such as developing and completing a budget worksheet, writing the project narrative, and collecting supporting documentation. In the final hours before a deadline, team members may find themselves frantically editing, searching for, and collating each part of the application package for submission. In October 2015, Grants.gov launched a new feature, Workspace, designed to promote the ease of team collaboration. Workspace is a platform that enables multiple team members to simultaneously access, edit, and upload forms associated with a grant application. When submitting an application through Workspace, the separate forms and files are automatically combined into a single package. A workspace must be created for each grant application; however, organizations may reuse saved Workspace forms to apply for other grant awards. Grants.gov identifies four reasons why organizations should utilize Workspace: Collaboration is streamlined and made easier Forms can be reused, saving applicants time Forms are validated when uploaded, which helps reduce submission errors Context-sensitive help is provided for all pages, tabs, and windows within a workspace By using Workspace, organizations can assign roles to determine the level of access for each team member. Grants.gov created the following graphic to depict the workflow in Workspace. To assist users in creating and managing Workspace, Grants.gov has published multiple instructional videos on YouTube. Has your organization used Workspace? Share your thoughts and experiences in the comments below.   Save...

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Federal Grants in 2016 – Pulse Check

Posted by on May 11, 2016 in Grants & Assistance | 0 comments

Federal Grants in 2016 – Pulse Check

We’ve reached that point in the year when we start thinking about next year’s Federal Grants Update (FGU) course. This process starts with reviewing our FGU 2016 comments and looking at the ways we have already updated the content of this course. Here’s what stands out to me right now: Still getting to know 2 CFR 200. As expected, our students have a wide range of familiarity with the Uniform Guidance, resulting in a wide range of comments. Whether you and your organization have fully implemented 2 CFR 200, or you’re just now beginning to tackle this challenge, you can benefit from a refresher on the requirements. Know that we’re tracking 2 CFR 200 every day, and will update our FGU instructors when something changes. FAPIIS – you can do it. A few students have noted how the FAPIIS section of the course has helped them wrap their head’s around how to navigate this requirement. We recognize that many of you have heard about the risk of debarment and suspension with regard to the FAPIIS and other disclosure requirements under 2 CFR 200. So it’s great to hear that our presentation of FAPIIS as a manageable requirement resonates with you. Transparency reforms may seem cloudy. This is a bit of a strange year for the Federal grants community. First, we’re hard at work putting the policies and internal controls in place to comply with the transparency requirements in 2 CFR 200. Conflict of Interest Policy? Check. Performance measurement tying to budget and cost data? Working on it. First 2 CFR 200 Single Audit? Monitoring the clearinghouse on the submission deadlines.Then there’s that thing called the DATA Act looming in the background. This is something that continues to frustrate those of us who understand that it’s coming, but wonder what to do now. That makes it cloudy – and necessary to continue to track the progress and outcomes of the Section 5 pilot. So what’s next (in my opinion)? First, I’m going to take a look with Shane at the pending legislation at Congress. If you are tracking DATA Act implementation, you may have noticed that there are active bills that go beyond the DATA Act. We’ll add these into our course materials accordingly. Keep in mind that efforts to increase transparency on the use of Federal funds are bipartisan, and have a chance at passing. In particular, keep an eye out for the Open, Public, Electronic and Necessary Government Data Act (OPEN Act). This bill would codify Executive Order 13642, Making Open and Machine Readable the New Default for Government Information and could potentially prevent the Federal government’s use of the DUNS Number. Second, I’m going to watch for the Supreme Court decision on the potential for the False Claims Act to apply to almost every bill and invoice submitted by a government contractor. The decision in Universal Health Services, Inc. v. Escobar has the potential to increase the scrutiny of all payments made by the government. This case shines the light on the need for all recipients of Federal funds (grant or contract) to ensure they have the internal controls in place for all the terms, conditions, and regulations – like for personnel in this case. Speaking of internal controls, the 2016 Single Audit Compliance Supplement is coming...

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Grant and Cooperative Agreement Selection Reviews Matter

Posted by on Apr 18, 2016 in Grants & Assistance | 2 comments

Grant and Cooperative Agreement Selection Reviews Matter

One of our main themes in our Federal Grants Update 2016 is risk mitigation. One of set of standard procedures every Federal grant and cooperative agreement manager should have is for the application selection process. Another is for delineating between grants and contracts. We recently had the opportunity to update our Federal Assistance Law course with a legal decision. Because it is one the most significant recent legal decisions for the Federal grants community, we wanted to share this review with the broader Federal grants community. In January 2016, the United States Court of Appeals for the Federal Court (CAFC) overturned the United States Court of Federal Claims’ decision in Jay Hymas, d/b/a Dosemen Farms, v. United States,__ F.3d __, Fed. Cir. No. 2014-5150 (2016 WL 158470) (Jan. 14, 2016). The Appeals Court’s decision may limit the ability of plaintiffs to challenge an agency’s decision to award a cooperative agreement or grant award when, in the plaintiff’s opinion, the award was in essence a procurement contract. The case was based on cooperative agreements awarded by the United States Department of the Interior’s Fish and Wildlife Service (FWS). The FWS entered into Cooperative Farming Agreements (CFAs) with individual farmers to grow crops on public lands in two wildlife refuges. Under the terms and conditions of the CFAs, the farmers, termed cooperators, were able to farm specific parcels of public land with corps specified by FWS. Cooperators were able to retain 75 percent of the crop yield for their efforts and the remaining 25 percent of the crop was left to feed migratory birds and other wildlife. The FWS advised the cooperators on crop selection, farming methods, pesticide and fertilize use, and crop harvest. In 2013 and 2014, Mr. Hymas unsuccessfully sought a multi-year CFA. When awarding the CFAs, the FWS did not use formal procurement procedures nor solicited cooperators using full and open competition. Rather, the FWS relied upon its priority selection system that gave preference to previous cooperators with a successful record of farming designated areas within the refuge. Under the Tucker Act, Mr. Hymas filed a bid protest in the Claims Court alleging that the FWS violated Federal procurement laws and the Administrative Procedure Act (APA). The Claims Court determined that the FWS service erred in treating the CFAs as cooperative agreements when the CFAs were procurement contracts and that the agency violated the Competition in Contract Act (CICA) by failing to use formal procurement procedures to obtain full and open competition. The Claims Court also determined the priority selection system violated the Federal Grant and Cooperative Agreement Act (FGCAA). The Claims Court ordered the FWS to terminate awards made in 2013 and 2014 and prevented the agency from awarding any additional awards unless the selection process complied with the CICA, the FGCAA, and the APA. The agency appealed the decision to the CAFC. The CAFC determined the CFAs were indeed cooperative agreements and that the lower court erred in applying the CICA. The CAFC applied the definition of cooperative agreements found in the FGCAA. Under the FGCAA, an agency may award a cooperative agreement when: The principal purpose of the relationship is to transfer a thing of value to the recipient to carry out a public purpose, and Substantial involved is expected between the executive agency and...

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#NGMA16 Wrap Up

Posted by on Apr 11, 2016 in Grants & Assistance | 0 comments

#NGMA16 Wrap Up

Pshew! I hope all of this year’s National Grants Management Association (NGMA) Annual Training Conference (#NGMA16) attendees have recovered. I know that many of us were in the midst of proposal responses….grants.gov has been busy, no? So, what did I learn at NGMA? First, as a community we need to improve our communication that the Uniform Guidance is requirement, especially to those who may not be on board with compliance yet. I heard several of my grants colleagues ask the question, “how do I explain to my [insert leader] that we have to do [X] because of this part of 2 CFR 200?” I agree with Tiffany Winters’ comment that we should use 2 CFR 200 more often – because “Code of Federal Regulations” does sound much more official than the Uniform Guidance. Second, time and effort reporting requirements continues to cause some confusion. Since I’ve been working for companies who serve as Federal contractors, it’s natural for me to fill out a timesheet each day, with multiple project codes. It was good for me to get the reminder that filling out a timesheet is not normal for a good portion of the grants community. I also find it interesting that this is one thing that the Council on Financial Assistance Reform (COFAR) wanted to make easier for the community to use existing reporting systems to comply. Generally, I’d follow the advice to keep doing what you’ve been doing in terms of time and reporting if you’re getting clean audits. If you need transition from “no system” to “some system,” reach out to your fellow NGMA members for assistance. There are a lot tools out there. Third, as I mentioned in my pre-conference post, indirect costs (IDC) are definitely a challenging area. I think that as more of us increase our understanding and application of IDCs, we will become more comfortable and confident in this area. I appreciate that more people understand that organizations – government, nonprofit, or private – need to fully cost the cost of managing our grants. Finally, I would be remiss if I did not ask you to save-the-date for April 18 – 20, 2017. I can’t wait to see the agenda for next year’s NGMA...

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Understanding the Federal Budget Process for Grants

Posted by on Mar 25, 2016 in Grants & Assistance | 0 comments

Understanding the Federal Budget Process for Grants

The Federal budget process can be a difficult concept to comprehend. I am in the (extreme) minority when I say that I find the budget process fascinating. For four years, I served as Congressman Brad Carson’s Grants Director and my responsibilities included briefing the Congressman on the Federal budget and its impact on Federal grant programs. Understanding the process can be critical in determining when Federal awarding agencies may make funds available for grant programs and the level of funding that may be available. For this week’s blog, I want to simplify the process so you can be better informed. The first major step in the process begins with the President releasing his proposed budget for the upcoming fiscal year. This generally occurs by the first Monday in February. The President’s budget outlines his agenda and is used to begin the budget process. For the grants community, the President’s budget provides insight into potential funding priorities for Federal agencies in the upcoming year. Next, the House and Senate budget committees prepare the budget resolution. The annual budget resolution is a framework for Congressional spending and tax priorities and establishes the spending thresholds for the appropriations bills. Federal awarding agencies and non-Federal entities can review the budget resolution to identify allocated funding amounts and to review any Congressional policy statements. Finally, Congress begins the appropriations process. This process authorizes spending for specific programs. Congress must pass 12 individual appropriations bills, each for a specific government function. Grants officials should review the applicable appropriations bills to determine how much funding their programs will have in the upcoming fiscal year. Congress may eliminate funding for certain programs, and non-Federal entities should be prepared to locate other funding sources. Congress must pass, and the President must agree to, each appropriations bill by September 30, as the new Federal fiscal year begins on October 1. When agreement cannot be reached before the start of the new fiscal year, Congress must pass, and the President must sign, a Continuing Resolution (CR) to fund government operations until final spending is approved. CRs provide short-term funding, generally at current funding levels. Failure to pass a CR results in a government shutdown, as happened in 2013. To expedite the process, Congress generally combines all outstanding appropriations bills into an omnibus bill to avoid this. For the grants community, CRs generally delay the new grant competitions. Funding the Federal government is a time-consuming process that requires a consider amount of resources. In recent years, members of Congress have proposed creating a biennial budget that would add a greater level of stability. However, Congress has yet to act on any of these proposals. For FY 2017, Congress is currently at the beginning phase of the process. Last week, the House Budget Committee approved the budget resolution; however, it remains unclear when the House will vote on the resolution. Congress.gov provides an Appropriations and Budget Resources page that provides relevant documents and developments relating to the budget process. The grants community can use this resource to stay informed of potential implications to their grant programs. By understanding the budget process, the grants community can be bettered prepared for the upcoming year....

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NGMA 2016 – Agenda Reflects Grants Community Challenges, Concerns

Posted by on Mar 23, 2016 in Grants & Assistance | 0 comments

NGMA 2016 – Agenda Reflects Grants Community Challenges, Concerns

When NGMA released its final conference agenda last week, my gut reaction was, “Yep. These topics are spot on. This is where many of my colleagues in the Federal community.” Several themes standout: Risk Assessment. Implementation of the Uniform Guidance (2 CFR 200) has brought this issue to the forefront for many organizations with its new requirements, and incorporation of the final rule for FAPIIS. As a community, we’ve known for a long time that we need to assess and manage risk better. It’s just really hard. Indirect Costs. Having supported grants from the Federal agency point of view, it has been eye opening for me to realize how complex this can be for large institutions. And how challenging it is to wrap your head around when you don’t have a negotiated rate. Performance Measurement. Or the thing we all need to do better and only gets harder as we learn how to do it. Who knew when we got into this field that defining and measuring outcomes can be as demanding as rocket science? Project Management. Several presenters will share their best practices for applying project management principles to grants management. Remember, if you are a grants manager, you are a project manager by default. Now I know that most attendees won’t want to miss Mr. Grants himself, Gil Tran, from the Office of Management and Budget, talk about the sophomore year of Uniform Guidance implementation. However, I’ve got my eye on the closing session – ‘Ask a Grants Expert.’ Participants can ask questions of a panel that includes Federal executives from OMB, DHS, and GAO. If you’re attending the conference, I recommend staying for this closing if you can. If you have a burning question, but can’t be there, post it to our comment section below. I’ll bring it with me and report back in early April. I hope to see you there. We’ll be at booth 14 with information on our grants management courses, raffles, giveaways, and resources to help you in your grants career. Be sure to stop by and introduce...

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IGPW: Grant Professionals – Leading at All Levels

Posted by on Mar 15, 2016 in Grants & Assistance | 0 comments

IGPW: Grant Professionals – Leading at All Levels

Management Concepts is proud to sponsor once again this year’s International Grant Professionals Week (IGPW). We’d like to take a moment to recognize the impact of grant professionals in our communities, and at all levels of government. Grants fund billions of dollars of activities we have deemed important through our governments, corporate and family foundations, and community organizations. For those of you outside of the grants world, imagine a complex relationship web of projects and resources. Behind each project and resource stands at least one person – often a grant professional who has dedicated their career to matching resources to projects and causes. And these professionals lead in many different ways. Here are two examples: Project Managers. The best grant professionals treat each aspect of a grant as a project, even when the resources for planning and managing aren’t there. They set schedules and internal deadlines for each application. They determine processes for review and evaluation of each proposal and funded project. They work together to develop corrective action plans when projects go off track. Influencers. Grant professionals influence others on a daily basis. Often they have to find resources and people to help them follow the myriad of rules and regulations for each grant program and award. That can mean changing internal systems and controls in large organizations, or starting from scratch. I know from my experience supporting Federal program offices, the desire to fund activities usually did not come with sufficient resources needed to effectively support information collection. My influencing skills were certainly tested. On the recipient side, grant professionals – or more recognizable to you as state and local governments, education, or nonprofit workers – strive to connect people to create new partnerships on a daily basis. These are the relationships that can take support of a new play and turn it into a theater festival that provides a boost to the local economy. Or brings police, fire, and EMS officials together to purchase interoperable communications technologies to enhance public safety. As grant professionals who lead all the time, we can and should take time to hone our leadership and management skills – just like anyone else. I know that I personally benefit from opportunities to reset. It’s amazing how helpful an outside observer or mentor can help you catch and address flaws, including the new ones that come with new roles and experience. Learning opportunities in leadership are especially important for grant professionals in “non-manager” roles. While I personally think all of us are managers in some way, your employer may not share my recognition. When you find one of those leadership learning opportunities, remind your supervisor that as a grants professional, you’re managing projects up and across your organization, and often into your community. When you’re a more effective leader, your organization becomes more effective, too. March 15 is IGPW Chapter Day! Check with your Grant Professionals Association Chapter to learn more about activities close to you. If you’re in DC, join us at McCormick & Schmick’s on K Street tonight at 5:00 p.m. for a networking happy hour with the...

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Developing and Evaluating Performance Measures

Posted by on Feb 22, 2016 in Grants & Assistance | 2 comments

Developing and Evaluating Performance Measures

The implementation of 2 CFR 200 has required Federal awarding agencies and pass-through entities to revise and revaluate processes for grants administration. Perhaps one of the most consequential changes under the Uniform Guidance is the change in focus for accountability of Federal awards from compliance to performance. One of the goals of the Uniform Guidance is to “more effectively focus Federal resources on improving performance and outcomes while ensuring financial integrity of taxpayer dollars in partnership with non-Federal stakeholders.” As a result, Federal awarding agencies and non-Federal entities must not only ensure Federal awards adhere to financial and administrative requirements, but they must also evaluate the effectiveness of Federally-funded projects. To meet this requirement, grant programs and Federally-funded projects must develop and analyze performance measures. Three weeks ago, I had the opportunity to attend the pilot course for the new Performance Measurement for Federal Grants Under 2 CFR 200 course. It is designed to assist Federal awarding agencies and non-Federal entities in developing performance measures, addressing requirements under 2 CFR 200, and evaluating project outcomes. The participants were employees from Federal agencies, pass-through entities, and recipient organizations and brought diverse experiences and viewpoints working with performance measurement. The wide variety of backgrounds provided an exciting insight on how some Federal agencies are addressing the requirements under 2 CFR 200. Most interestingly was hearing about the increasing number of agencies requiring logic models for grant applications and how recipients are adapting their application processes. A common situation among the participants was the difficulty their organizations faced in effectively developing and measuring outcomes for their projects. As a group, we were able to address these concerns. In one activity, we evaluated the performance of a grant recipient and developed proposals on how to address the recipient’s problems in meeting performance goals. As the grants community enters the second year under 2 CFR 200, the expectations for grant projects to meet performance goals are increasing. Federal awarding agencies can expect Congress and Offices of Inspectors General to more carefully examine how grant programs are aligned with governmentwide goals. In turn, Federal awarding agencies will be holding recipients accountable in meeting project outcomes. Hopefully, this will result in improved performance for grant programs and increased benefits for the American...

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President Obama Signs the GONE Act

Posted by on Feb 3, 2016 in Grants & Assistance | 0 comments

President Obama Signs the GONE Act

On January 28, 2016, President Barack Obama signed the Grants Oversight and New Efficiency Act (GONE Act) into law. Congress designed the GONE Act to hold Federal awarding agencies accountable for timely closeout of grant awards. The purpose of the law is to reduce costs associated with maintaining bank accounts of expired grants that contain undisbursed funds or a zero balance. The law requires Federal awarding agencies to submit a report to Congress and to the Department of Health and Human Services (HHS) that: Identifies each Federal grant that has not been closed out two years after the end of the award’s period of performance Describes the challenges leading to delays in grant closeout Explains why awards have not been closed out Within one year of the initial report, Federal awarding agencies are required to provide a follow-up report that specifies which of the identified grant awards have been closed out and those that remain open. The law also requires: The Inspector General (IG) for Federal awarding agencies with more than $500,000,000 in annual grant funding to conduct a risk assessment of the agency’s grant closeout process The Director of the Office of Management and Budget (OMB) and the HHS Secretary recommend to Congress legislation to improve the accountability and oversight of grants management Under the Uniform Guidance, Federal awarding agencies and pass-through entities should complete all closeout activities within one year. 2 CFR 200.343(g) states: The Federal awarding agency or pass-through entity should complete all closeout actions for Federal awards no later than one year after receipt and acceptance of all required final reports. It is important to note that the Uniform Guidance uses the word “should” and not “must” when detailing closeout requirements. Thus it is an expectation, and not a requirement, that closeout occurs within one year. The law does not require agencies to complete closeout activities within one year. However, agencies will be required to explain to Congress why closeout has not occurred within the one-year time frame. The GONE Act is in response to a 2013 Washington Post article that found that the Federal government spent at least $890,000 on service fees to maintain empty bank accounts of expired grants. The Government Accountability Office (GAO) found that 13,712 such accounts existed in 2012. “Our taxpayer dollars should be spent on programs and grant opportunities that actually support the American people, not on administering empty grant accounts that help nobody.” – Senator Joe Manchin (D-WV), GONE Act Co-Sponsor The following timeline identifies the key dates for the required actions under the law. By July 18 2016, the OMB Director must instruct Federal awarding agencies to prepare a report on expired grant awards By December 31, 2017, Federal awarding agencies must submit the initial report to HHS and Congress By December 31, 2018: Federal awarding agencies must submit the follow-up report to HHS The IGs of select agencies must conduct a risk assessment of the agency’s closeout process By March 31, 2019, the HHS Secretary must compile agency follow-up reports and submit a report to Congress By September 30, 2019, the OMB Director and HHS Secretary must provide to Congress any recommendations to improve oversight of grants...

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Performance Measurement in the Pre-Award Phase

Posted by on Jan 26, 2016 in Grants & Assistance | 0 comments

Performance Measurement in the Pre-Award Phase

In the last year, the grants community has had to adapt many new practices and processes to implement the requirements found in 2 CFR 200 (Uniform Guidance). One area of concern for Federal awarding agencies, non-Federal entities, and pass-through entities is how to adequately report, monitor, and evaluate a grant project’s performance. As stated in the preamble to 2 CFR 200, the Federal government seeks to shift the focus of accountability for Federal awards from compliance with requirements to the actual performance and results of Federally-funded projects. As a result, agencies and recipients are being held accountable for how well a project achieves its intended results through the use of performance measurement. Performance measurement is the ongoing monitoring and reporting of a project’s accomplishments and is a key analytical tool used to hold agencies and recipients accountable for the administration of Federal awards. 2 CFR 200 greatly expands the use of and reliance on performance measurement in all aspects of the grant lifecycle. Successful implementation of a grant project requires significant planning and development during the pre-award phase. For Federal awarding agencies, this includes: Reviewing authorizing statutes and appropriations for Congressionally-mandated performance measurement requirements Where appropriate, aligning grant program goals, objectives, and performance measures to agency goals and priorities, as required under 2 CF 200.202(b)(1) Identifying a grant program’s performance measurement requirements in the notice of a Federal financial assistance program published in the Catalog of Federal Domestic Assistance (CFDA) Describing the performance measurement requirement for recipients in the Notice of Funding Opportunity (NOFO) Before applying for a grant, non-Federal entities should carefully review a grant program’s CFDA notice and NOFO. Non-Federal entities should ensure the application addresses all performance measurement requirements. Grant applicants should be aware that an increasing number of Federal grant programs are requiring applicants to submit a logical model. Logic models identify a projects’ inputs, activities, outputs, and expected outcomes. In essence, a logic model explains how a project will achieve its intended goals and identifies the performance measures used to evaluate a project’s performance. Applicants may have to devote significant resources to successfully develop a logic model. Additionally, grant applicants have to develop a data collection plan to identify how the organization will obtain the necessary data to measure the project’s performance. In a grant application, non-Federal entities should clearly identify what data will be collected, the method to collect the data, and how that data will be used to measure a project’s performance. What concerns do you have about performance measurement requirements? Let us know in the comments section below....

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Federal Grants Update 2016 – Learning from Experience

Posted by on Jan 15, 2016 in Grants & Assistance | 6 comments

Federal Grants Update 2016 – Learning from Experience

Because 3,500+ of you completed Federal Grants Update in 2014 and 2015, we realized that we had the opportunity to go a bit deeper into the key issues surrounding Uniform Guidance implementation. And there have been enough changes to 2 CFR 200 that we want you to come back to make sure you’re up-to-date (thank you, OMB, for FAPIIS). So what’s new for FGU in 2016? First, we centered on these core themes of grants management to help you delve into difficulties your organization may have had in implementing 2 CFR 200: Transparency Risk Mitigation Accountability Monitoring Next, we designed Federal Grants Update 2016 to include more interaction. This will allow instructors and students to share their experiences and challenges that have begun to stand out as Federal agencies, pass-through entities, and recipients implement the Uniform Guidance – such as evaluation and internal controls. Our goal is to help you focus on the important things that you and your organization still need to do to be compliant as well as share your successes. Finally, we wanted to make sure that you have the opportunity to participate according to your schedule and ability to travel. So we added a few opportunities for you to participate via the Remote Student Experience, in addition to our Classroom and Virtual Live Classroom modalities. That said, we want to assure you that there are certain things that we hold dear with Federal Grants Update: You will receive a refresher on the Uniform Guidance as well as FAPIIS, the DATA Act, Inspector General Reports, and potential Congressional actions We track all of the content for changes – coming and unforeseen – so we can make sure the information you receive is as fresh as possible The bottom line is that we truly care about Federal Grants Update being your go-to annual refresher course as a grants professional whether it’s your first class with us or your tenth. We look forward to seeing you – whether in-person and...

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What to Expect in 2016?

Posted by on Jan 7, 2016 in Grants & Assistance | 2 comments

What to Expect in 2016?

Last month, one of my blog posts examined some of the significant developments for grants administration in 2015. Last year was, to put it mildly, a very busy year. In addition to implementing and complying with 2 CFR 200, the grants community also had to prepare for the implementation of the Digital Accountability and Transparency Act (DATA Act) and the Federal Awardee Performance and Integrity Information System (FAPIIS). Adding to the workload were multiple amendments to the Uniform Guidance and a host of proposed rules affecting Federal grants. So, what does 2016 have in store for the grant community? Here’s a look at some of the key events I’m keeping an eye out for: Final Agency Implementation of 2 CFR 200 To date, only about half of the Federal grant making agencies have adopted a final rule implementing 2 CFR 200. While all new Federal awards must be in compliance with the Uniform Guidance, it will be beneficial once all agencies have adopted a final rule. This will enable grant recipients to know of any agency-specific exceptions or additional requirements. Internal Control Guidance In the 2015 Compliance Supplement, the Office of Management and Budget (OMB) removed guidance on internal control. In Part 6 of the 2015 Compliance Supplement, OMB indicated that there was insufficient time to develop new guidance and that non-Federal entities and auditors should refer to the “Internal Control-Integrated Framework” or to the “Green Book” for guidance. OMB plans on incorporating internal control guidance, compliant with 2 CFR 200, in the 2016 Compliance Supplement. This guidance will be an important resource for non-Federal entities to ensure internal business systems meet 2 CFR 200 requirements. FAPIIS Guidance In July 2015, OMB published final guidance to implement FAPIIS for grant awards. As of January 1, 2016, Federal awarding agencies are required to review FAPIIS before making a grant award over the simplified acquisition threshold. It will be interesting to see the extent in which the new FAPIIS requirements affect the grants community. Additionally, it will be important to review any agency guidance discussing agency-specific implementation. Audit Reports The audit requirements found under Subpart F of 2 CFR 200 apply during a non-Federal entity’s first full fiscal year after December 26, 2014. This means for entities with a fiscal year beginning on January 1, their single audit for fiscal year 2015 will be conducted under the new requirements. Under 2 CFR 200, single audit reporting packages will be publicly available on the Federal Audit Clearinghouse, and this will provide the grants community a first look at some of the findings auditors are reporting under the Uniform Guidance. Additionally, audit reports from Offices of Inspectors General should also begin to reflect compliance concerns under 2 CFR 200. This information will be valuable for the grants community to identify common problems and to develop mitigation plans. 2 CFR 200 Metrics The Council on Financial Assistance Reform (COFAR) established metrics to evaluate the extent to which the Uniform Guidance is achieving its goals of easing administrative burden and strengthen oversight over Federal funds to reduce risks of waste, fraud, and abuse. OMB Memorandum M-14-17 identifies the metrics that OMB and the COFAR will use to “gauge the success of [2 CFR 200] and the performance of the Federal government’s work in the management...

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Resolve to Make 2016 a Great Grants Year

Posted by on Jan 4, 2016 in Grants & Assistance | 0 comments

Resolve to Make 2016 a Great Grants Year

Happy first workday to the 2016 grants community! If you’re like me, I have given up on making New Year’s resolutions at home. I like chocolate, wine, and enjoying life too much. But I usually do for work. There is something about the deadlines, personal development plans, and the recognition that I can’t do it all that makes the office a better “resolution” environment. So I present my proposed grants resolutions – feel free to adopt. Make sure I really know 2 CFR 200. Did you see Shane’s 2015 review post last month? So much changed last year, with more likely to come. It’s definitely a good time to peruse the COFAR FAQs and go deeper into the themes of transparency, risk mitigation, accountability, and monitoring. Learn how to use at least one data source better. Last week I sat with our market research guru to pull out some customer data in excel. A pivot here, click there, and voila – three salient points from a source already at my finger tips. Made me feel empowered and a bit rusty.Excel not your thing? How about demographic data that could show how your organization’s program will serve particular populations in a target community. Go to the U.S. Census website this week to see what you can learn. Document three internal processes. I truly enjoy the conversations with people who tell me that they are the only person in their office that does everything. This may work for you now. But eventually, someone will come to doing a monitoring visit or conduct some other oversight activity. That’s the moment when you don’t want to have it all in your head.Keep it simple, especially if you are one of the do-it-alls. For example, next time you complete a Federal financial report, keep a list of all the steps you take from sending a request, to accounting, to taking a screen shot showing you uploaded the report on time. Like the one you’re with. During the last two months I have had at least five conversations with grants professionals stating that they can’t get X thing done because the staff in Y office is so uncooperative. And yes, three involved examples of the grant program versus budget office scenario.Why? Not just because working together is better for stress levels, the sake of good management, etc. Because the Uniform Guidance requires it. This crystalized for me during development of the latest version of our performance measurement course. If we need to report, let alone understand how grants build capabilities at a unit cost level, we need to work together better.Maybe this involves setting up a regular coffee break with your counterpart from the “other” office. Or maybe your organization formally recognizes that more than one office makes up the grants team. Consider ways that you can collectively share accountability. Follow the DATA Act. The actions the government will take in the next year will make for an interesting 2017. Keeping up-to-date will help you be prepared. Now back to work. Or take a moment to share your resolutions...

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A Year in Review for the Grants Community

Posted by on Dec 18, 2015 in Grants & Assistance | 0 comments

A Year in Review for the Grants Community

December 19 marks the one year anniversary of the Office of Management and Budget (OMB) releasing the interim final rule for the Uniform Guidance. In the last year, the grants community has spent considerable resources in understanding the new requirements and ensuring compliance. In addition to the implementation of 2 CFR 200, there have been other notable developments that will affect grants administration in 2016 and beyond. Let’s take a look back at the significant developments in the last year. December 26, 2014: 2 CFR 200 became applicable to all new Federal awards and existing awards that receive modified award terms and conditions February 18, 2015: OMB opened a public survey to gather feedback from non-Federal entities regarding implementation of 2 CFR 200. The survey closed on March 17, 2015. March 31, 2015: The Treasury Department updated USASpending.gov. May 8, 2015: OMB and the Treasury released 57 standardized data elements to implement the Digital Accountability and Transparency Act (DATA Act) May 27, 2015: The Chief Acquisition Officers Council (CAO) opened the National Dialogue and Pilot to Reduce Reporting Compliance Costs for Federal Contractors and Grantees. This dialogue allows the grants community to provide feedback on ways the Federal government can reduce compliance requirements. July 14, 2015: OMB released the 2015 Compliance Supplement, which modified the existing Matrix of Compliance Requirements, provided guidance for performing audits for awards under 2 CFR 200 and previous requirements, and removed guidance for internal controls. July 22, 2015: OMB published final guidance to implement the Federal Awardee Performance and Integrity Information System (FAPIIS) for Federal grant awards. Beginning on January 1, 2016, Federal awarding agencies will have to review FAPIIS to evaluate an applicant’s qualifications. OMB amended 2 CFR 200 to reflect the new FAPIIS requirements. August 6, 2015: Multiple agencies, including the Department of Education and Department of Justice, released proposed rules to modify existing requirements regarding grant awards made to faith-based organizations. August 31, 2015: OMB and the Treasury finalized the standardized data elements required under the DATA Act. September 10, 2015: OMB made technical corrections to 2 CFR 200. In addition to making editorial corrections to 2 CFR 200, OMB amended the Uniform Guidance to provide non-Federal entities a two-year grace period to comply with the new procurement standards. The Council on Financial Assistance Reform (COFAR) also released updated Frequently Asked Questions (FAQs) for 2 CFR 200. September 29, 2015: The COFAR released the 2014 Administrative Metrics to establish a baseline for evaluating the implementation of 2 CFR 200. September 30, 2015: The mandate for the Recovery Accountability and Transparency Board expired. October 1, 2015: The micro-purchase threshold increased from $3,000 to $3,500. October 8, 2015: OMB released the final Agency Priority Goals under the Obama Administration. expired. October 14, 2015: The National Science Foundation (NSF), on behalf of multiple Federal awarding agencies, released the proposed standardized Research Terms and Conditions for Federal research awards made under 2 CFR 200. November 9, 2015: OMB made correcting amendments to 2 CFR 200 regarding FAPIIS implementation. November 10, 2015: The Treasury released USASpending.gov, which is a preview of how USASpending.gov will eventually function to comply with the DATA Act. December 9, 2015: OMB published a notice in the Federal Register seeking public comments on the revised SF-SAC form. This timeline of some of the...

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Show Me the Data?

Posted by on Nov 24, 2015 in Grants & Assistance | 0 comments

Show Me the Data?

If there is one theme I have tattooed in my brain as a result of all the conferences I’ve attended this quarter, including the Grant Professionals Association (GPA) National Conference (#GPAconf15) in St. Louis, it’s evidence. As in evidence that – The 57 data elements will achieve the goals of the DATA Act The grant-funded fleet of state patrol vehicles has been inventoried It makes sense to buy my son a video game system over another device for his birthday You can tell by that last bullet that I’m really taking this evidence theme to heart. The strongest voices in the evidence conversation I’ve heard during this time are definitely those in the education space. If there is one thing that comes through in Department of Education (ED) Notices of Funding Opportunity (NOFO) is the need for applicants to show evidence to support the success of a proposal, before the project has even started. In fact ED has a Federal Register Notice on its intent to require all recipients awarded direct competitive grant funds to openly license all copyrightable intellectual property created with grant funds. All of this begs the question for how an organization, like a school district, can build evidence-based proposals for untested ideas. While we want to believe that our society wants to fund innovation, as a society, we often don’t want our grant dollars funding said innovation. Chicken? Egg? Anyone? Given that innovation is an incremental process, perhaps your organization can create an internal grant program to foster an evidence-driven culture. Yes, the grantees can become the grantors. Full disclosure – this is not my idea. Instead I want to share what Dr. Marcella Zipp, Director of Grants and Special Programs for District 214 in suburban Chicago, shared on the last day of the GPA Conference. Essentially, Dr. Zipp worked with her District 214 colleagues to create an internal grant program to fund special projects requested by teachers. Dr. Zipp structured the program as a means to introduce teachers and other stakeholders to the skills they need to be successful grantees. Applicants complete a standard form online, submit financial reports, and report on project milestones and outcomes. Yes – project milestones and outcomes that can serve as evidence for external grant applications! Of course this evidence did come at a cost. District 214 identified funds for this program from its existing budget. We have to recognize that this was an accomplishment in itself. However, the investment has paid off. Not only has the program supported the underlying goal of building an evidence-driven grants culture, the internal grant program also has: Provided a positive point of relations between the District and the local teachers’ union Increased teachers’ understanding of what grants can fund (projects) versus what should come from operational dollars (stuff) Identified several innovative projects that had enough evidence from the first year to obtain second year funding through the District program to repeat or expand The lesson for all of us is that we should not let the mere existence of the “evidence” requirement prevent us from pursuing an opportunity. We just may need to think our way around it rather than through...

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Congress Approves Two-Year Budget Framework

Posted by on Nov 13, 2015 in Grants & Assistance | 1 comment

Congress Approves Two-Year Budget Framework

Last month, President Obama and Congress agreed to a two-year budget. The budget increases Federal discretionary spending by $80 billion over the two year period, which will be equally divided between defense and domestic programs. The agreement also suspends the debt ceiling through March 2017. The budget agreement only establishes spending levels. Congress must still approve an omnibus bill to authorize spending for the next two years. The omnibus bill must be signed into law by December 11, 2015 in order to prevent a government shutdown. A two-year budget greatly enhances the ability for Federal awarding agencies to develop long-term plans. Instead of preparing contingency plans for a government shutdown, agency personnel can devote additional resources into administering Federal programs. The budget agreement is consequential for the grants community. Federal awarding agencies will know the extent of available funding for grant programs well in advance of grant competitions. This will enable agencies to begin the pre-award phase for grants programs earlier than in past years. The two-year budget also removes some uncertainties for grant recipients. Recipients with continuing awards will have a better grasp of how much funding might be available in future years, which should make budgeting and program planning easier. Additionally, after years of sequestration, increased funding for grant programs will improve success rates for applicants. The budget agreement has renewed discussions for adopting a two-year budget cycle for the Federal government. Senator Mike Enzi (R-WY) has introduced bipartisan legislation that would create a biennial budget cycle for Federal domestic spending. However, even with this year’s agreement, Congressional approval of the legislation seems remote. In a recent interview with Federal News Radio, Senator Johnny Isakson (R-GA), a co-sponsor of the legislation, indicated that convincing members of Congress to change the budget cycle is a...

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Meet me in St. Louis #GPAConf2015

Posted by on Nov 3, 2015 in Grants & Assistance | 0 comments

Meet me in St. Louis #GPAConf2015

It’s hard for me to believe that I’m getting on a plane next Wednesday morning for St. Louis for the Grant Professionals Association (GPA) 17th Annual Conference. Maybe it will become more real once I tick “Don’t forget to vote” off my checklist this evening. Last month I started my prep for GPA National by attending the first Virginia GPA Conference. On the bus ride home I had the opportunity to reflect on what I heard and observed. First, I was struck by the increasing collaboration needed to secure Federal funding in large (and small) competitive program pools. From a policy perspective, one could see this as progress. We want our Federal task dollars funding the “best” proposals possible. From the grant recipient proposal, one could see this as another barrier to funding the good work they support in their community. This has led me to think all throughout October about how grant-seeking organizations cope with the myriad of strings that come with each grant award. It really becomes an intricate web, especially when it comes to reporting progress and milestones (not to mention the dollars). It’s also a web that more organizations need to spin as they diversify their funding portfolios. I also continue to track the conversation on the establishment and implementation of internal controls in accordance with the Uniform Guidance. How does relate to the complex funding web above? The concept that the Council on Financial Assistance Reform (COFAR) meant to recognize these complexities, and move towards industry standards, such as those found in the COSO Report. I interpret this as the intent of one organization having a single set of “rules” for how it runs its business. This is an excellent goal – one set of rules should mean less complexity and variety on your internal operations, and thus more efficiency. A singular approach should also make it easier for leaders and auditors to ensure compliance with internal controls and policies. However, I understand that implementation of a singular approach might be a challenge for anyone (i.e., recipients) who wants to make their customers (i.e., funders) feel and be special. Many of us are wired to instinctively say, “Yes,” when asked to meet an individual, one-off requirement, even when that diverts precious time and resources away from the mission-driven project. Before I assume too much on what grant funded organizations do and should do, I want to hear from you. Please come find me at the Management Concepts booth in St. Louis, or start the conversation in our comment section below. It’s important for us to hear from you, our students and partners, on how the information we provide in our grants curriculum can cross-apply to multiple aspects of your...

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2 CFR 200: A Living Document

Posted by on Oct 23, 2015 in Grants & Assistance | 3 comments

It has almost been a year since 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) became effective for Federal grants. The implementation process has provided some challenges to the grants community, such as complying with the new performance measurement requirements or understanding the new time and effort provisions. One key lesson the grants community has learned in the past year has been the need to remain informed of Federal actions affecting grant awards. The grants community should view 2 CFR 200 as a living document that can, and does, evolve. For example, in the last few months: The Office of Management and Budget (OMB) released final rules implementing the Federal Awardee Integrity and Information System (FAPIIS) that altered the requirements found in 2 CFR 200 The Council of Financial Assistance Reform (COFAR) updated the Frequently Asked Questions (FAQs) document, which extended the procurement grace period The micro-purchase threshold was increased from $3,000 to $3,500. Beginning January 1, 2016, Federal awarding agencies are required to verify an applicant’s qualifications in FAPIIS before making an award. In addition to the new requirements, OMB amended multiple sections in 2 CFR 200 to implement the FAPIIS requirements. As a result of the changes to 2 CFR 200, the grants community needs to ensure that policies are accurately referencing the correct provisions in the Uniform Guidance. There have also been important changes to procurement policies. In September, the COFAR updated the FAQs to 2 CFR 200. In the FAQs, the COFAR announced that non-Federal entities now have two full fiscal years to implement the new procurement requirements. 2 CFR 200.110 was amended to reflect the change from a one year to a two year grace period. Another procurement change affects the micro-purchase threshold. On October 1, 2015, the Federal Acquisition Regulation (FAR) increased the micro-purchase threshold from $3,000 to $3,500. 2 CFR 200.67 directly ties the micro-purchase threshold in the Uniform Guidance to the FAR by stating “the micro-purchase threshold is set by the Federal Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions). It is $3,000 except as otherwise discussed in Subpart 2.1 of that regulation, but this threshold is periodically adjusted for inflation.” While the threshold has not yet been amended in 2 CFR 200, the $3,500 threshold is now applicable to procurements under Federal grants. Non-Federal entities should update internal procurement policies to reflect this change. The grants community needs to remain aware of changes to 2 CFR 200. As we have seen in the last year, 2 CFR 200 is a living document, which requires the grants community to frequently review and update internal policies and ensure compliance. Management Concepts is committed to bringing you the most current information through our training courses, Grants Blog, Twitter feed, and E-Clips newsletter. By working together, we can ensure a smooth transition to the Uniform...

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Check Your Stakeholders’ 2 CFR 200 Knowledge

Posted by on Oct 9, 2015 in Grants & Assistance | 4 comments

Check Your Stakeholders’ 2 CFR 200 Knowledge

This is a bit of a mea culpa. At the end of the summer, I checked in with you on your Uniform Guidance implementation. One thing I asked you to do is, “Don’t assume that everyone knows the Uniform Guidance.” In that post, I took for granted that there is a baseline of knowledge out there. I should have stated, “Don’t assume that everyone knows about the Uniform Guidance.” If you are reading this blog that means you’ve opted-in to expanding your grants knowledge. You can chat about 2 CFR 200 at dinner parties. You may have watched all of the YouTube videos on the COFAR website. You potentially have even signed up for next week’s Get Ready for FAPIIS webinar. But have you shared this knowledge with your grant stakeholders? You may have – but it can’t hurt to check again, or try another method. One way that Federal agencies reach their constituents is through training symposiums. These in-person or virtual events provide fantastic opportunities for grantees to connect with program officers, network with fellow recipients, and receive technical assistance. Last week, the Management Concepts grants team had the opportunity to participate in the 1st Annual Outreach Partners Networking Symposium for USDA’s 2501 program. During the symposium, we had the opportunity to exchange knowledge outside of the classroom on the Uniform Guidance. We wanted to share some of the Q&A from this session in case you or someone you know hasn’t asked yet. Why was the Uniform Guidance developed? In response to Executive Orders, the Council on Financial Assistance Reform (COFAR) was established in October, 2011. COFAR has steered efforts to improve Federal grants and cooperative agreements management and accountability, and their work included development of 2 CFR 200. What are some key points from the Uniform Guidance that are important for Federal agencies to take note of? The Uniform Guidance requires all Federal agencies to perform risk assessments on all entities receiving Federal awards The Uniform Guidance also expands upon previously established requirements for Federal agencies to build upon previous audits prior to commencing any new audits The raising of the Single Audit Threshold to $750,000 allows agencies to better target larger amounts of at-risk funding What are some key points from the Uniform Guidance that are important for pass-through entities to take note of? Pass-through entities are required to evaluate a subrecipient’s risk Pass-through entities must accept previously negotiated Indirect Cost rates, negotiate with sub-entities to establish an indirect rate, or accept the sub-entity election to incorporate the new 10% de minimus rate into their award All pass-through entities must comply with reporting requirements to report all sub-awards What are some important takeaways from the Uniform Guidance for all recipients of Federal awards? Conflict of interest provisions have been strengthened; the Uniform Guidance requires non-Federal entities to disclose all relevant conflict of interest or criminal violations and provide appropriate certifications. The Guidance provides Federal awarding agencies with strong non-compliance remedies for violations The Single Audit Threshold has been raised from $500,000 to $750,000 There is a clear distinction in the Uniform Guidance regarding non-Federal entity determination of who is a subrecipient and who is a contractor; the treatment of each under the Uniform Guidance is determined by the substance of the award The Uniform Guidance provides...

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Grants at Home

Posted by on Sep 29, 2015 in Grants & Assistance | 0 comments

Grants at Home

My Sunday morning ritual includes a walk with my son to our neighborhood farmers market. It’s a mix of the donut truck, county council candidates, and farmers and ranchers. My son buys the eggs, green bars, and donuts while I make my way down the line, checking out stalls from the orchard, to the couple with the elephant garlic, to my rancher, to the veteran who somehow has greens year round, and more…hungry yet? This weekend I’m going to add some “shop talk” to my hellos because I found out about a grant program that could be helping them. The USDA Outreach and Assistance for Socially Disadvantaged Farmers and Ranchers and Veteran Farmers and Ranchers (2501) program could be helping farm enterprises like Biggs Rigg’s – run by an Iraq war vet. And that helps me get healthy greens on my table every week. It’s in my interest to eat well while supporting my community. This USDA program is an example of how a policy (i.e., supporting farmers and ranchers in need) is put into action through grants. Not too surprisingly – I had not heard of this program until last week when I learned of it from one of our GMCPTM graduates who supports this program. With only $9.1M in available funding in 2015, the 2501 program is not going to create headlines inside the beltway. I think of small programs like these as the work horses that provide monies to our communities – our homes – in small yet impactful amounts. Learning about this program also reminded me that basically everyone in your community could receive directly or indirectly Federal financial assistance funds. That of course goes beyond the mandatory programs like Medicaid. Last month I asked about how Uniform Guidance was going for your organization. Maybe you didn’t respond because it you thought, “my organization? It’s me, myself, and I managing my grant.” Fair enough. So if you find yourself in this situation, remember that in your community, you are probably not the only de facto grants professional. Consider finding out who among your network close to home touches grants. This might allow you to form a “community of grants” practice, share smart practices on grants compliance, get recommendation on auditors, learn about FAPIIS, etc. Just know that you’re not alone in this multi-billion dollar grants world. Even at home. On October 1, 2015, the micropurchase threshold increases to $3,500 due to a change in the FAR. The Uniform Guidance ties this level to the FAR at 2 CFR...

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Wrap it Up – Grant Closeouts

Posted by on Sep 21, 2015 in Grants & Assistance | 0 comments

Wrap it Up – Grant Closeouts

Today I had the opportunity to preview some of the initial work for our upcoming FAPIIS webinar. It’s exciting to work on something new and informative. Then my brain went on a bit of a “why” tangent. I know that these new requirements stem from Section 872 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009. But really – why? Yes, FAPIIS stands for the Federal Awardee Performance and Integrity Information System. We want the assurance that Federal funds invested in grants perform and are managed by good people. We even think that past performance should matter. However, we should also keep in mind that our system of government is designed to be reactive. So what was Congress reacting to when it instructed the Executive Branch to implement FAPIIS? Passed the DATA Act? Introduced the Grants Oversight and New Efficiency Act (GONE) Act? Perhaps some of the members read reports from the GAO detailing the need to improve the grants closeout process. And those members want these issues fixed. I believe that with smart planning, agencies and recipients alike can improve the reporting and tracking of Federal funds going forward. But we also need to look at our past and current grants portfolios to make improvements now, especially with regards to closeouts. We need to wrap it up. Let’s review a few steps you can take. Review the Uniform Guidance on closeouts. The Uniform Guidance’s section on closeout spells out the responsibilities and requirements for Federal awarding agencies and pass-through entities. Between this section and the award agreement itself, you can make an administrative checklist for the award based on your role. Budget for “after the grant” activities. Recipients and subrecipients should ensure that they have sufficient resources in place for reporting and accounting that takes place within 90 -180 days of an award’s end. Some research grants may have long-term tracking and evaluation requirements for particular objectives or outcomes. Make a project plan and identify the estimated costs for these activities. Then work with your leadership to ensure that the associated funding is in place.Federal awarding agencies need to also plan and cost closeout activities for each grant program. While grant program managers and officers may not lobby directly for funding, they can document post-grant responsibilities and estimate the funding needed for corresponding activities and systems. This information could inform administration budget requests. Share the news that “it’s” over. Rather than viewing closeouts solely as an administrative burden, seize the opportunity to let your stakeholders know that you ended something successfully. You could make your final report public with appropriate revisions. You could report that you completed all closeout requirements on time as part of any past performance statements for future grants. You could feed in the success stories from grant A into the proposal for grant B, and the next phase of your long-term project. Keep in mind that every closeout completed quickly and efficiently will have an impact on your time and resources. It means fewer reports long after the last drawdown. In some cases it could mean avoiding continued bank fees for grant-specific accounts with no expected revenue. If we as a community improve just this one aspect of grants management, maybe Congress won’t notice so many discrepancies during its oversight. Maybe...

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Risk Assessments Under 2 CFR 200

Posted by on Sep 1, 2015 in Grants & Assistance | 0 comments

Risk Assessments Under 2 CFR 200

The grants community is under increasing scrutiny and pressure to protect Federal funds from waste, fraud, and abuse. 2 CFR 200 (Uniform Guidance) establishes protections at each part of the grants lifecycle to protect Federal funds from risk. The Uniform Guidance also defines the responsibilities for Federal awarding agencies, pass-through entities, grant recipients, and auditors to guarantee grant funding is used for its intended purposes. One key provision in the Uniform Guidance is 2 CFR 200.205 – Federal Awarding Agency Review of Risk Posed by Applicants. 2 CFR 200.205 requires Federal awarding agencies to develop and implement a risk assessment framework. Under this provision, Federal awarding agencies are required to evaluate the risk posed by applicants before making an award. The Uniform Guidance provides agencies with the flexibility to develop an agency-based risk assessment framework; however, agencies are required to verify applicant eligibility through the SAM Exclusions Extract and evaluate applicant qualifications through the Federal Awardee Performance and Integrity Information System (FAPIIS). In addition to those two requirements, agencies may evaluate an applicant’s: Financial stability Quality of management systems History of performance Audit reports Ability to comply with program requirements 2 CFR 200 requires Federal awarding agencies to describe the risk assessment framework in the Notice of Funding Opportunity (NOFO). For example, the Corporation for National and Community Service (CNCS) explains in the NOFO for the FY 2015 Training and Technical Assistance program that the agency may, in addition to the criteria previously identified, also review an applicant’s: IRS Tax Form 990 Annual report Website The Uniform Guidance also requires pass-through entities to conduct a risk assessment. Unlike Federal awarding agencies; however, pass-through entities do not have to conduct the risk assessment prior to making an award. 2 CFR 200.331(b) explains that pass-through entities may consider the subrecipient’s: Prior experience in administering similar awards Audit reports Personnel Management systems Results from Federal agency monitoring Federal awarding agencies and pass-through entities should use the results of the risk assessment in developing an appropriate monitoring plan for each award. If the identified risks to Federal funds are significant, Federal awarding agencies and pass-through entities may place specific conditions on the award. 2 CFR 200.207 identifies the conditions that may be placed on a recipient and explains the responsibilities of Federal awarding agencies and pass-through entities when applying specific conditions. Grant applicants should carefully each agency’s risk assessment framework. Most agencies have information published on their website. Additionally, grant applicants should review a program’s NOFO for the specific risk assessment criteria. It is important that grant applicants are fully aware of how an agency will evaluate an application and to address any issues in their application. What has been your experience with the new risk assessment requirements in 2 CFR 200? Leave your comments...

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So, How Is Uniform Guidance Implementation Going?

Posted by on Aug 27, 2015 in Grants & Assistance | 0 comments

So, How Is Uniform Guidance Implementation Going?

Some of you might be thinking, “It’s only four months until Christmas.” I’m thinking, “wow, only four months until the Uniform Guidance first anniversary. So how are things going?” It’s an important question that we need to ask of ourselves in the Federal grants community. Certainly we have peppered you with information about all of the things Federal agencies, pass-through entities, and recipients need to do related to the Uniform Guidance through this blog. With that in mind, it is probably time to take a step back to make sure you and your organization have taken the necessary steps to fully implement 2 CFR 200. Document the changes your organization has made to-date. Knowing that an underpinning of the Uniform Guidance is increased transparency, it will be to your organization’s benefit to document the changes made to comply. This way if an auditor comes knocking, you can demonstrate what changes to a system or internal policy were made, when, and who approved the change if appropriate. Check those changes made against your original “2 CFR 200 to-do” list. It is possible that your organization has not made all of the necessary changes yet. This is also an opportunity for you to document when a particular item will be changed. Keep in mind that there could be good reason for holding off on the change (i.e., waiting until your new fiscal year before making audit requirement adjustments). You can also raise any red flags with your team on additional changes to policies and processes need to be made. Don’t assume that everyone knows the Uniform Guidance. If you work with Federal grants day in day out, then it’s probably reasonable that you know of 2 CFR 200. But do you and your team really know it? I think it’s reasonable that not everyone needs to log onto to eCFR.gov and read every section of Title 2. However, if you are working with the Uniform Guidance regularly, you do owe it to yourself to take the time to familiarize yourself with the changes and the structure of the rules. You also may need to take the time to ensure that you and your colleagues know and understand the nuances of how Federal agencies may have implemented 2 CFR 200 a bit differently. We are nearing the point when we can stop referring to the “new” 2 CFR 200. These are the rules we must follow as the Federal grants community. We also need to be aware that the these rules are subject to change over time, and staying up to date. We are also at the point where we can start identifying case studies, best practices, and lessons learned about Uniform Guidance implementation and impacts. Please continue to share your stories and examples in our classes and in the comment section...

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Corrective Action Plans: Opportunities for Improvement

Posted by on Aug 11, 2015 in Grants & Assistance | 0 comments

Corrective Action Plans: Opportunities for Improvement

Wouldn’t it be wonderful if all of the billions in Federal Financial Assistance were spent without any violations, overpayments, or nefarious actions? While the Uniform Guidance provides a framework with checks and balances, it’s an impossible task. Why? We’re human. Fortunately, Federal agencies, pass-through entities, and auditors can put corrective action plans in place to address any issues discovered along the way. Most often corrective action plans follow a “problem-action-desired result” format, setting clear expectations between the government and grantee on what needs to be fixed. Now, corrective action plans and corresponding follow-up reports will likely play a greater role in the risk assessment review process for all Federal grants. Someone looking at an application will be looking at your corrective action plans as part of their risk assessment of your capability to handle Federal funds. On the Federal side, how well your office handles corrective action plans could be reviewed and flagged by a congressional oversight committee or the Government Accountability Office (GAO). So what can you do? Rather than load up your sad songs play list, try to make things better. Here are some suggestions: Own your corrective actions. For grantees, assign someone the responsibility of addressing any corrective actions identified through monitoring activities or your annual audit. Treat each corrective action as a mini-project until the issue is resolved.On the Federal side, ensure that you include the criteria for when a corrective action plan is required, how you will track these plans, and how you will report progress as part of your monitoring procedures. Keep in mind that you may need to carry on this monitoring past the period of performance. Avoid corrective actions in the first place. We’ve all experienced situations where the best laid plans go awry. Whether you are on the receiving or granting side, if you find a problem, don’t wait to address it. For recipients, if you are run into hurdles with your project, ask for technical assistance. Many Federal grant programs build in technical assistance services into their programs for just this reason. Keep in mind that this assistance could be for programmatic or administrative issues.Federal grants personnel should follow their program and agency’s monitoring protocols to help identify issues before they warrant a corrective action plan. For instance, if a grantee submits incorrect financial reports two quarters in a row, have your budget person talk to the grantee’s budget person to work it out. Or if you notice that a group of grantees has requested the same, unallowable purchase, schedule a conference call or webinar to review your grant’s allowable cost list. Stay up-to-date. Whether it’s through training, or reading blogs like this, you need to learn and share information on changes within the Federal grants space. For instance, what if you didn’t already know that the purchasing thresholds changed in the Uniform Guidance? You could easily make a decision that could show up in your regular audit, and in a future grant review. Finally, you should document when and how you solve problems with managing and executing your grant. First, everyone likes a turnaround story. If you can move from having 10 corrective action plans to zero within a short period of time that might be a great story to share. Second, we all want to know the...

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Unique Federal Grants Challenges for Tribal Entities

Posted by on Aug 5, 2015 in Grants & Assistance | 1 comment

Unique Federal Grants Challenges for Tribal Entities

This week we’ll focus on some of the particular issues that arise, both in general and under the Uniform Guidance, when a grant recipient is a tribal entity. Indian tribes occupy a unique place in the Federal grants environment, and they face a distinctive set of challenges throughout the grant process. First, one of the key characteristics of many Indian tribes – their remote location – creates a number of disadvantages. Lack of business opportunities, minimal Internet access, and high travel costs can contribute to slow, limited communication between awarding agencies and recipients. Furthermore, limited opportunities for and awareness of financial management education exist in Indian Country. As a result, many tribal entities will qualify as high-risk recipients and need additional monitoring in order to achieve program goals. What constitutes a tribal entity? The Uniform Guidance defines the term “Indian tribe” as: “Any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village… which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians.” (2 CFR §200.54.) However, not all Indian tribes are Federally recognized. While the official Bureau of Indian Affairs list currently contains more than 560 Federally recognized tribal entities, and new entities are occasionally added, many more tribes are only recognized by the governments of their home states. As many grants are reserved solely for Federally recognized tribes, many potential recipients will not even have the ability to apply for these programs. Another challenge in the grant application process occurs when a disparity exists between the supply of Federal grant funds and the number of eligible recipients. Sometimes, due to the high amount of political pressure surrounding Indian Affairs issues, Congress will make more funds available for a given program than can reasonably be awarded to capable recipients. As a result, funds may be awarded to entities that cannot manage them properly. Not only does this hurt the recipient, but it means that program goals go unaccomplished. Turning to grants management, one of the main issues for tribal entities that I see with the advent of the Uniform Guidance is the greater amount of oversight responsibility no placed on non-Federal entities. Pass-through entities in particular now have increased responsibility with regard to risk assessment and monitoring. Furthermore, all grant recipients must have strong internal controls, as well as policies for procurement and avoiding conflict of interest. Some particularly small or disadvantaged tribes may have trouble implementing these requirements. The small size of many tribes, often less than several thousand people, means that there may be only a few individuals in the community with the necessary education and experience to manage grants effectively. Some tribes choose to hire consultants to fill this skills gap. Unfortunately, bringing on outside help, such as a consultant or partner, occasionally leads to predatory business practices. I have seen several situations where a non-tribal entity such as a corporation teamed with a tribe or its members with the ulterior motive of taking advantage of Federal funds available only to Indians. Legal and political issues also arise frequently in this unique Federal assistance environment. For example, frequent turnover in tribal governments, which, depending on the tribe’s election cycle, may occur as often as every two...

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Funded or Perish

Posted by on Jul 30, 2015 in Grants & Assistance | 2 comments

Twenty years ago next month, my family and I boarded a plane bound for Baltimore and my freshman year at Johns Hopkins. While I never set out to be a researcher, I did have that fleeting semester that I thought about an academic career in the humanities. Once I realized that I’d have to write and publish so much, I was out. Of course, many of my classmates and friends from my time at Hopkins have dedicated their working lives to teaching and research in the natural and social sciences. What I’ve observed among these talented individuals is not only dedication, but also frustration. It’s challenging for these masters of their fields to design sound analyses of the economic impact of building stadiums or to separate specific genes in pancreatic cells in search of a new cancer treatment. The frustration kicks in when it comes to the constant stress of finding the funding to support the research to serve as the basis for the paper or doctoral thesis to get you that tenure track position you’ve spent 20+ years pursing. So you don’t perish. What none of us realized then is that the recognized and notable scientists are masters of the grant funding process. If you thought sending funding through states to localities was complex, then university research projects might blow your mind. Collaboration happens across labs, sometimes with private companies in the mix, not to mention subrecipients and contractors who might be all over the world. So how can we start developing grants mastery earlier in the process to help keep more people on the bench and in the field? We need to find ways to mix in awareness and capabilities of the funding process with the organic chemistry, differential equations, and applied statistics. Here are a few things to consider: Publicize institutional resources to undergraduates. Many universities have robust research administration departments, often focused on faculty and graduate students. These offices hold a lot of knowledge and can provide a lot of guidance for someone just starting out. Incorporate grant making into the undergraduate curriculum. Based on what I could find in the Hopkins online course catalog, there were only seven courses in fall 2015 on finding, applying, and winning grants. All were focused at the graduate level. If your institution can’t figure it out how to do this, consider sponsoring high-potential undergraduates’ attendance in a non-university grants course. Encourage opportunities for leadership and management in the classroom and lab. Recognize that not everyone is going to be president of the drama club or treasurer for their class on top of completing their degree. I know that I benefited from practicing how to work on a team when my study group had to submit a single problem set for economics in business school. This in turn has helped me in the highly collaborative and coordinated grants field. Let’s spread instructional techniques across other disciplines more often. If you have more ideas on how to build up the next generation of researchers’ grants mastery, I’d like to hear from you in our comments section or at our NCURA booth next week. As the premier industry provider of Federal grants management education, we look forward to meeting you at our booth (#316) next week.  We want to hear from...

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FAPIIS is Here – What You Need to Know

Posted by on Jul 24, 2015 in Grants & Assistance | 2 comments

FAPIIS is Here – What You Need to Know

On July 22, 2015, the Office of Management and Budget (OMB) released the final rule to implement the Federal Awardee Performance Integrity Information System (FAPIIS) for Federal grant awards. FAPIIS is a system designed to ensure Federal awards are issued to reliable and qualified recipients by providing award officials with information pertaining to the past performance of applicants. The final rule is implemented by amending 2 CFR 200 and 2 CFR 180. Beginning on January 1, 2016, Federal awarding officials are required to review FAPIIS as part of a pre-award risk assessment before making a grant award greater than $150,000. During the FAPIIS review, agency officials will determine if an applicant is “qualified” or “not qualified” to receive an award. Federal awarding agencies will be required to notify grant applicants if they have been deemed “not qualified” for an award. The “qualified” and “not qualified” designation is award-specific. The Federal Register notice explains: It is possible for a Federal awarding agency to determine that a non-Federal entity is not qualified for one award and, depending on the reasons for that first determination, qualified for another award. For example, a Federal awarding agency may determine that a non-Federal entity is: (1) Not qualified for a Federal award for a large and complex program, due to information in the designated integrity and performance system indicating an unsatisfactory record for performing under Federal awards for programs of that level of complexity; and (2) qualified for a second Federal award to carry out a simpler program. Further, Federal awarding agencies may make a Federal award to a recipient who does not fully meet these standards, if there are specific conditions that can appropriately mitigate the effects of the non-Federal entity’s risk in accordance with § 200.207. It is important to note that in addition to reviewing FAPIIS, Federal awarding agencies must still verify recipient eligibility through the SAM Exclusion Extract. FAPIIS is a publicly accessible website. Grant applicants should review the information in FAPIIS about their entity before submitting an application. Grant applicants have the opportunity to submit a response about any information about their entity contained in FAPIIS. As a result of the final rule, 2 CFR 200 has been amended in multiple places, including: 2 CFR 200.205 has been revised to require Federal agencies to review FAPIIS as part of the pre-award risk assessment before making an award in excess of the simplified acquisition threshold. 2 CFR 200.212 now details the reporting requirements for agencies when a grant applicant has been determined to be “not qualified” for a Federal award. 2 CFR 200.213 contains information regarding suspension and debarment which was previously found at 2 CFR 200.212. 2 CFR 200.339 and 2 CFR 200.340 provide information regarding an agency’s responsibility to the termination of an award to FAPIIS. Appendix XII has been added to 2 CFR 200 to explain the award term and condition for recipient reporting on integrity and performance matters. The new requirements are not applicable to pass-through entities. However, since FAPIIS is publically available, pass-through entities may want to review the system before making a subaward. OMB and Federal awarding agencies are expected to provide additional information in the coming months before FAPIIS becomes a reality for grant awards. Stay tuned for additional information! Do you have any...

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OMB Releases the 2015 Compliance Supplement

Posted by on Jul 8, 2015 in Grants & Assistance | 3 comments

OMB Releases the 2015 Compliance Supplement

The Office of Management and Budget (OMB) released the long-awaited 2015 Compliance Supplement this week. The Compliance Supplement is annual guidance designed to assist auditors conducting single audits and to determine recipient compliance with applicable Federal laws and requirements. It has always been an important resource for the grants community, however, the 2015 Compliance Supplement has additional significance as it provides guidance on implementing 2 CFR 200. Appendix V of the Compliance Supplement identifies the list of changes from the previous year. Important changes to the 2015 Compliance Supplement include The name of the guidance has been changed from the A-133 Compliance Supplement to the Compliance Supplement The compliance requirements for the Davis-Bacon Act and Real Property Acquisition and Relocation Assistance have been removed Additional audit advisories, including updated coverage of low-risk auditee criteria Updated references to 2 CFR 200 The grants community should pay particular attention to the two sections in Part 3. Section 3.1 identifies compliance requirements for awards issued before December 26, 2014. Section 3.2 identifies compliance requirements for awards that adhere to 2 CFR 200. It is important to note that the audit requirements under 2 CFR 200 – Subpart F do not apply until a non-Federal entity’s first full fiscal year after December 26, 2014. The following table identifies the applicable audit requirements.   Fiscal Year Dates Guidance for Audit Requirements 7/1/2014 – 6/30/2015 OMB Circular A-133 10/1/2014 – 9/30/2015 1/1/2015 – 12/31/2015 2 CFR 200 7/1/2015 – 6/30/2016 10/1/2016 – 9/30/2016   The grants community will find Part 6 of the Compliance Supplement disappointing. In the past, OMB has identified internal control requirements in Part 6. This year, however, Part 6 reads: In 2013, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) updated the “Internal Control – Integrated Framework,” and, in September 2014, the Government Accountability Office (GAO) issued an updated “Standards for Internal Control in the Federal Government,” commonly referred to as “The Green Book.” Due to the need to update other parts of this supplement for the Uniform Guidance in 2 CFR Part 200, OMB was unable to also update Part 6 for the revisions to COSO and The Green Book without delaying the issuance of this supplement. Since the 2014 version of Part 6 is out of date, it was not carried forward to this supplement. Non-federal entities and their auditors should look to the COSO and Green Book for guidance on internal controls until Part 6 is updated. OMB plans to update Part 6 for the 2016 Compliance Supplement. Until OMB updates Part 6, it will be critical for the grants community to review both the Green Book and the COSO Integrated Framework. 2 CFR 200 does not require non-Federal entities to adopt either guidance, however, each contains best practices that would be beneficial to protect Federal funds from waste, fraud, and abuse. The Compliance Supplement also noted that Federal agencies are expected to publish their final implementing rules for 2 CFR 200 in 2015. OMB notes that agencies “may include changes to their interim final regulations.” What are your thoughts on the 2015 Compliance Supplement? Are you disappointed that OMB did not include information about internal controls? Leave your thoughts in the comment section...

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Tell Me How It Ends Before It Begins

Posted by on Jun 24, 2015 in Grants & Assistance | 0 comments

Tell Me How It Ends Before It Begins

If you’re like me, you may love a good set of data, but sometimes it’s nice to curl up with a good novel instead. We live in a nation of storytellers – and like it or not, sometimes the data isn’t going to make the headlines. What does this have to do with grants? Quite a bit when it comes to performance measurement. A former colleague once captured it with this question: What would the leader of your organization say during a speech on what this grant accomplished? Not only is it a great question, it’s also noteworthy for when she asked: during the preaward stage of a grant program. So let’s break it down on how to apply it at the program and project levels. Agency officials should answer this question before setting fingers to keyboard to write the Notice of Financial Opportunity (NOFO) – or updating it for a subsequent year. Consider this part of the conversation you should be having on performance measurement. While these can be tedious discussions, you could insert a bit of levity by working through a Mad Lib exercise. When Congress appropriated funds [X] years ago, our team at [Agency] developed this grant program as part of our efforts to implement [policy objective(s)] as part of our [Mission]. Since making the first award in [Month, Year], we’ve funded [Y items] that are now in place in our communities. As a result, we are now better [adjective related to a capability] to do [Z]. While this example might not work exactly for your program, you can see how this “speech” includes quite a few of the details that program officials need to cite and determine during NOFO design, including: Statutory, policy, and mission alignment Anticipated maximum period of performance Target award date Allowable costs Desired outcomes With a couple more examples of expenditures-building capabilities, you have a decent sketch of a speech to a stakeholder group, introduction to Congressional testimony, or final grant program report executive summary. More importantly, you can use this exercise to make sure that you keep the scope of the program’s desired outcomes to what you can manage. You need to make sure that your agency has the capability to capture the underlying performance data to support these outcomes. Let’s move onto the project view. Potential recipients should read the NOFO, or other materials made available by a Federal awarding agency or pass-through entity, well before the application deadline. Your Mad Lib session will likely take place as part of a proposal planning meeting. In addition to discussing how and who will build the budget, you might walk through something like this: When we submitted our proposal for [Project Name], we were at [Describe Baseline]. The [Grant Program Name] allowed us the opportunity to improve our ability to [Activity]. Now we are able to [Describe Target Capability/Outcome(s)]. With this grant, we funded [A items], which supported our project’s goal to do [B activity]. We also funded [C] to [D]. We are proud that our organization was part of the national effort to [cite program goal(s) from NOFO]. More importantly, this project supported our core mission to [describe mission]. Now that the grant is complete, we have identified [Funding Source] to carry out the next phase of the project. In...

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What’s DUNS (Still) Got to Do with It?

Posted by on Jun 17, 2015 in Grants & Assistance | 0 comments

What’s DUNS (Still) Got to Do with It?

One of the most common questions our instructors have been receiving in our classes in 2015 is, “Does my organization still need a DUNS number?” The short answer is yes. My colleague, Shane Jernigan, summed this issue up nicely in our May eClips – so nicely that I want to share it again: The Office of Management and Budget (OMB) published the joint interim final rule implementing 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In the joint interim final rule, OMB made dozens of technical and editorial changes to the Uniform Guidance. OMB made these edits to correct typographical errors and to provide additional clarification regarding the new requirements. One editorial correction potentially signals a dramatic change for the grants community — OMB removed all references to the Data Universal Numbering System (DUNS) Number. In place of the DUNS Number, the joint interim final rule refers to a “unique entity identifier,” defined at 2 CFR 25.315 as “the identifier required for SAM (System of Award Management) registration to uniquely identify business entities.” The change in terminology has created some confusion. Currently, SAM.gov still identifies the DUNS Number as the required unique identifier that all non-Federal entities must have in order to apply for, receive, and report on a Federal award. Therefore, all non-Federal entities are required to continue using the DUNS Number for all grant-related documents. OMB’s removal of all specific reference to the DUNS Number may be foreshadowing a change to grants management. Recently, leading trade associations have begun a “Dump DUNS” movement. This campaign is designed to encourage OMB to stop requiring the use of the DUNS Number and develop new data elements. Supporters of this movement believe the use of the proprietary DUNS number, owned by Dun & Bradstreet, Inc., restricts open and free data and limits transparency. Due to the technical change in the interim joint final rule, the term “unique entity number” will begin to appear on grants-related documents. Non-Federal entities should not confuse this term for the unique Federal Award Identification Number (FAIN), which applies to the specific award. Until OMB provides further guidance, non-Federal entities should continue to use their DUNS Number for the unique entity number requirement. Of course, Dun & Bradstreet is still working to maintain its footprint in government acquisition and grants systems. For example, Dun & Bradstreet was a sponsor of last week’s DATA Summit. It’s also worth noting that the Government Accountability Office (GAO) 2012 recommendation to the General Services Administration “[t]o ensure that government agencies have improved access to information needed to effectively fulfill their missions, the Administrator of GSA should initiate discussions with Dun & Bradstreet on ways to reduce current restrictions on the use of DUNS numbers,” remains open. So at least for now, it seems that the change in the Uniform Guidance requiring a “unique entity identifier” is just an initial step in breaking up this...

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DATA Act Implementation Underway

Posted by on Jun 3, 2015 in Grants & Assistance | 0 comments

DATA Act Implementation Underway

Last month saw a significant uptick in implementation activities for the DATA Act. On May 8, 2015, the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) released information on the implementation of the DATA Act. OMB and the Treasury published: A list of 57 governmentwide standard financial data elements Memorandum M-15-12: Agency guidance on implementing the DATA Act A DATA Act Playbook that identifies eight key steps for agencies In May 2014, President Barack Obama signed The Digital Accountability and Transparency Act (DATA Act) of 2014 , which is designed to enhance the transparency of government spending. Once fully implemented in 2018, the DATA Act will require agencies to publish all Federal spending on USASpending.gov. The DATA Act impacts the grants community by requiring all grant expenditures to be available to the public. Federal Spending Data Elements OMB and the Treasury released a list of 57 Federal spending data elements designed to fully implement the DATA Act. Under the DATA Act, all Federal agencies will be required to use the data elements on financial award documents and to upload the information to USASpending.gov. The public has the opportunity to comment on some of the proposed data elements, as only 15 of the 57 data elements have been finalized. Many of the data elements were previously required under the Federal Funding Accountability and Transparency Act (FFATA). The DATA Act, however, requires Federal awarding agencies to report on account level information. Therefore, new data elements include information related to specific appropriations accounts. Agency Guidance on Implementing the DATA Act To assist agencies in implementing the DATA Act, OMB released Memorandum M-15-12 Increasing Transparency of Federal Spending by Making Federal Spending DATA Accessible, Searchable, and Reliable. M-15-12 supersedes all previous guidance from FFATA and agency reporting requirements to USASpending.gov. Under M-15-12, agencies must: Appoint a Senior Accountable Official responsible for the agency’s implementation of the DATA Act Develop an implementation framework that identifies timelines, possible challenges, and available resources Follow existing reporting procedures through May 9, 2017 Continue to assign a unique Federal Award Identification Number (FAIN) for all financial assistance awards Report specific programmatic information about all financial awards greater than the micro-purchase level of $3,000 to USASpending.gov by May 9, 2017 DATA Act Playbook In conjunction with M-15-12, the Treasury developed a DATA Act Playbook designed to assist agencies in implementing the DATA Act. The Treasury did not publicly release the Playbook, but did make available a summary of the Playbook’s contents. The Playbook recommends agencies: Create a DATA Act work group Review the list of standardized data elements Perform an inventory of agency data, processes, and systems Identify necessary changes to systems and business processes Implement a broker, a virtual data layer that complies with the DATA Act Schema Test the broker implementation Update other systems as necessary Update and refine processes to submit agency data OMB Announces Pilot Program The DATA Act requires OMB to test the implementation of the law with a pilot program. To meet this mandate, OMB selected the Department of Health and Human Services (HHS) to conduct that pilot to facilitate the development of the standardized data elements, identify and recommend the elimination of unnecessary duplication in financial reporting, and propose measures to reduce the compliance cost for recipients...

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Tracking Timesheets under 2 CFR 200

Posted by on May 27, 2015 in Grants & Assistance | 26 comments

Tracking Timesheets under 2 CFR 200

One of the most important, and often misunderstood, change under 2 CFR 200 the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) is the new reporting requirements for employee compensation, found at 2 CFR 200.430. For many reasons, this provision has created much confusion in the grants community. The first difficulty comes from just trying to read the multiple subsections. I have sat in many Management Concepts classes where students have spent time just debating where one subsection ends and another begins! To clarify, 2 CFR 200.430 has nine subsections: 200.430(a) General 200.430(b) Reasonableness 200.430(c) Professional Activities Outside the Non-federal Entity 200.430(d) Unallowable Costs 200.430(e) Special Considerations 200.430(f) Incentive Compensation 200.430(g) Nonprofit Organizations 200.430(h) Institutions of Higher Education (IHEs) 200.430(i) Standards for Documentation of Personnel Expenses In 2 CFR 200.430(a) through (f), The Uniform Guidance retains the framework found in the previous cost principles for charging personnel costs to Federal awards. 2 CFR 200.430(g) and (h) are entity-specific provisions for nonprofit organizations and IHEs that relate to unique circumstances for each entity type. For the most part, non-Federal entities should be familiar with the requirements found in these subsections. The fun, and head-scratching, begins at 2 CFR 200.430(i). This subsection outlines documentation requirements for paying employees with Federal funds, and the Uniform Guidance significantly revises these requirements. One notable omission in this subsection is the phrase “time and effort reporting.” This has led some non-Federal entities to believe that they no longer need to keep timesheets. This may be true for some, but not for all, and this is where the real confusion begins. Officials from the Office of Management and Budget (OMB) have said that non-Federal entities with strong internal controls do not need to provide personnel activity reports; however, 2 CFR 200.430(i) still requires non-Federal entities to maintain records that “accurately reflect the work performed.” These records must: Be supported by a system of internal control which provides reasonable assurance that the time being charged is accurate, allowable, and properly allocated Are incorporated in the official records, such as payroll records Reasonably reflect the employee’s total activity Provide a time or percentage breakdown on all activities, both Federally funded and non-Federally funded, for the employee Comply with the non-Federal entity’s pre-established accounting practices and procedures As stated at 2 CFR 200.430(i)(8), non-Federal entities that cannot meet the aforementioned conditions may be required to submit personnel activity reports. Even though the Uniform Guidance does not require a non-Federal entity to keep timesheets, a non-Federal entity still must account for the time an employee spends on each job-related activity. It may not be called a timesheet, but it sure sounds like one. OMB has said the purpose of this revision is to reduce the administrative burden on non-Federal entities. Unfortunately, OMB has not provide detailed guidance, so non-Federal entities that attempt to design a new personnel system might expend substantial resources only to conclude their current system is adequate. In addition, changing a personnel system without proper guidance from OMB has the potential for audit findings. What Does This Mean for You? Our recommendation is that non-Federal entities should continue to use their current personnel systems, as long as there have not been previous audit findings. Non-Federal entities that have had audit...

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Gratuity Violations Under 2 CFR 200

Posted by on May 22, 2015 in Grants & Assistance | 0 comments

Gratuity Violations Under 2 CFR 200

Federal and non-Federal entities (NFEs) should be well into the process of finalizing internal policies that conform to the new requirements under 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance allows NFEs to adopt entity-wide changes to internal policies and systems for all awards, both existing and new, without penalty. Therefore, a NFE may apply the new requirements found in 2 CFR 200 to all awards. The Uniform Guidance contains more than 60 new and modified requirements for grants administration. Many NFEs have focused their attention to the more significant changes under 2 CFR 200. For example, the grants community has spent considerable time focused on the new procurement methods and internal control requirements. As a result, NFEs may miss developing new internal policies for seemingly less significant requirements. One possible overlooked new requirement is found at 2 CFR 200.113 Mandatory Disclosures. This section reads: “The non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Failure to make required disclosures can result in any of the remedies described in §200.338 Remedies for noncompliance, including suspension or debarment. (See also 2 CFR part 180 and 31 U.S.C. 3321).” This means NFEs will need to adopt and implement internal policies that comply with 2 CFR 200.113. The policy should indicate: Who is responsible for identifying violations that may potentially affect a Federal award Who is responsible for notifying the Federal awarding agency or pass-through entity of violations How the NFE will provide written notification to the Federal awarding agency or pass-through entity A definition of “timely manner” in which the NFE will notify the Federal awarding agency or pass-through entity A list of applicable Federal laws involving fraud and bribery A definition of “gratuity violations” When drafting this policy, a NFE should work closely with their legal counsel. Under 2 CFR 200.113, a NFE must notify a Federal awarding agency of pass-through entity of a “violation” of Federal criminal law, and not just when an arrest, indictment, or conviction has occurred. This requirement could potentially present legal consequences for a NFE, therefore it will be critical that legal counsel is involved. Another potential difficulty for NFEs is developing an adequate definition of a “gratuity violation.” 2 CFR 200.318(c)(1) provides guidance to NFEs in crafting a policy. The section reads, in part: “The officers, employees, and agents of the non-Federal entity may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. However, non-Federal entities may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. The standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-Federal entity.” Therefore, an adequate internal policy must: Explicitly prohibit NFE employees from soliciting or accepting “gratuities, favors, or anything of monetary value from contractors or parties to subcontracts” Explain when an “unsolicited item of nominal value” may be accepted Detail the consequences for employees that violate this policy...

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NGMA Recap: Moving Forward

Posted by on Apr 28, 2015 in Grants & Assistance | 0 comments

Thank you to everyone who stopped by our booth at the National Grants Management Association (NGMA) 2015 Annual Grants Training Program held in Arlington, VA, last week. With nearly 600 in attendance, it was a rousing success. In line with current trends, the NGMA speakers and sessions reflected the shift from describing the Uniform Guidance, to the challenges associated with implementation. All of the sessions incorporated more advanced topics. One key theme that emerged among the Management Concepts team in attendance was how to cope with risk. For example, participants had the opportunity to learn about the prevention methods and tips for identifying fraud, waste, and abuse. Questions you may want to ask yourselves in the future include: Have you ever noticed an employee with a set of timesheets with no sick leave or vacation? Expert presenters cited examples when this situation resulted in the discovery of a phantom employee, and associated finding. Do you monitor the purchase of diesel fuel, especially by foreign entities? Monitors often overlook this line item and may miss a quantity that fails tests of allowability, allocability, and reasonableness. We also heard from several pass-through entities on the challenge of developing subrecipient risk assessment tools and processes to comply with the Uniform Guidance. Some of these are based on low-cost spreadsheet tools. We are keeping an eye on these examples to learn and identify smart practices and methods to share with you in our curriculum. Balancing the costs of risk assessment against compliance requirements will certainly be an increasing and ongoing challenge as the grants community absorbs the impact of the Uniform Guidance. Tied to the theme of risk management was performance. After several of the sessions I had conversations centered on the shift from simply making sure grants are compliant to actually performing well. As a community, we will need to balance the need for transparency of information with enough context to demonstrate how grant funds support policy goals. According to Andrea Brandon of DHS, this starts with asking the right policy questions, and tying it to grants operations and management. This can work when you have the opportunity and resources to build and implement new business processes. But in the din of the exhibitor hall I heard several comments on how much harder it is to do when “remodeling” existing systems. By the end of the conference and after many hallway conversations like those mentioned above, I can say one thing for sure: the depth and breadth of issues in our community make it an exciting time to be a grants professional. Thanks to Shane Jernigan and Molly Kubiak for inputs to this...

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De Minimis for IDC Rates

Posted by on Apr 24, 2015 in Grants & Assistance | 2 comments

De Minimis for IDC Rates

“But how do I get a Federal agency to negotiate an indirect cost rate with me?” If I had started collecting quarters a dozen years ago for every time I heard that question, I’d have a hefty retirement fund. Now, with the Uniform Guidance, I’ll have to find a new retirement plan. The years of backlogs in negotiating rates have led the Office of Management and Budget (OMB) to make a necessary and welcome concession: Every grant recipient has indirect costs, and the Federal government doesn’t have time to negotiate with all of them. Small entities should be rejoicing. Any grant recipient who has ever felt “cheated” by their lack of a Negotiated Indirect Cost Rate Agreement (NICRA) should be jumping on the furniture. Because now, without having to elicit any response at all from your cognizant agency, you can collect an indirect cost rate of 10% of Modified Total Direct Costs (MTDC), just by writing “de minimis” in the indirect cost line on your application budget! (Well, you do actually have to win the award.) The sun is shining and it’s a beautiful day in the grants world. You could always directly allocate even minimal costs to every cost center, but it often required more in manpower costs than it was worth. Did anyone really want to sort through the phone bill, allocating long distance calls to each grant? Or charge by the light bulb? Or divvy out the time of the lawn-mowing services? Now common sense has prevailed. And the little guys can keep pace with the big guys. Of course, you’ll need to understand how indirect cost rates work to make sure you’re applying the de minimis rate correctly, make sure you qualify for it, and know when it’s time to graduate from de minimis to NICRA. This means checking both the Uniform Guidance and awarding agencies’ policies. For instance, the National Science Foundation issued guidance stating that proposal budgets with indirect cost rates below the 10% de minimis rate are not acceptable. Because your organization has unique characteristics that may affect the type of indirect cost rate method you select now and in the future, make sure you keep up to date in understanding how to navigate these changes. Why? Because an educated recipient is the best...

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Survey Says: Take Federal Grants Update 2015

Posted by on Apr 14, 2015 in Grants & Assistance | 0 comments

Survey Says: Take Federal Grants Update 2015

Thank you to everyone who took the time to respond to our 2015 survey. The Management Concepts team is combing through the results now as part of our continuous update process for our Grants & Assistance curriculum. One thing that stands out to me is that 42 percent of respondents indicated they are planning on taking Federal Grants Update 2015. (And that doesn’t include the 11 percent of respondents who indicated they had already attended this class.) Six Reasons to Sign Up for Federal Grants Update in 2015 You haven’t kept up-to-date with the exceptions made by OMB when the Uniform Guidance went into effect You’re managing multiple awards, issued before and after December 26, 2014, and need to understand how to keep the “rules” straight during performance You don’t know which internal policies you need to update to be compliant You know that other things have changed in the grants world, but aren’t sure what those things are You didn’t take Federal Grants Update 2014 You did take Federal Grants Update 2014 but need to know how to implement Uniform Guidance changes. This tells me that the grants community feels it needs to know, as one student wrote, “how to put ‘the Supercircular in context’ of implementation.” It also points to the value of committing to your personal grants education annually. There will always be enough changes in the financial assistance landscape that if you took Federal Grants Update last year, you should enroll this year. When designing the 2015 version of the course, we shifted from the Federal Grants Update 2014 focus on the what, to the how, of your organization’s coping with the Uniform Guidance (2 CFR 200) as reality and not theory. For instance, in the 2015 version, you practice updating a policy to help you understand how to structure a game plan on best ways to approach making changes at your organization to comply with new performance measures and procurement requirements. Of course taking a day to travel, even locally, to a course can be difficult. We know that you are actively applying, reviewing, and monitoring grants every day. That’s why we offer virtual sessions for Federal Grants Update. You get the same level of interaction with your colleagues as in the classroom setting without having to leave your desk. Here’s a personal point of view from one of our instructors, Rex Porter on the value you receive during each iteration of Federal Grants Update: “I have come to love instructing a group each year in the Update course. Whether it’s the Instructor-Facilitated Virtual or Live Classroom version, I really appreciate how all the students come ready to be caught up and how the course design keeps everyone accountable, or actively involved. In less than a day I feel good that each student knows what they need to take away to be successful in the coming...

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Procurement Policies and the Uniform Guidance

Posted by on Mar 25, 2015 in Grants & Assistance | 0 comments

In a previous blog post, we discussed changes to procurement policies in the 2 CFR Part 200 – Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). We explained the five procurement methods and other new requirements to which non-Federal entities (NFEs) need to tailor their policies. I’m going to go into more detail about what policies your organization may need to create or change and how to make those adjustments. If you work for a state government, you will have an easier adaptation to the new regulations. According to 2 CFR 200.317, states should use the same procurement procedures on Federal projects that they use for non-Federal funds. One small exception is that states must endeavor to procure goods made with recovered materials, in accordance with 2 CFR 200.322. Other NFEs will have a bit more work to do to ensure compliance with the Uniform Guidance procurement requirements. Luckily, OMB has allowed a one-year grace period for these entities to adjust their policies. NFEs other than states must use their own documented procurement procedures which must comply with all applicable local, state, and Federal laws. You should review the Procurement Standards section of Subpart D of the Uniform Guidance, especially 2 CFR 200.318, for all the important provisions you will need to cover in your policies. Two of the key requirements from this section are avoiding conflicts of interest and ensuring competition. In the Uniform Guidance, a conflict of interest occurs when an “employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.” (2 CFR 200.318(c)(1).) One of the most important elements of your updated procurement policy will be the provision regarding conflicts of interest. The Uniform Guidance requires every NFE to have “written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts.” Your policy must ensure that employees will not participate in procurements where there is a real or perceived conflict of interest. Your organization will need to define and document some important determinations, such as the limit for when an item has substantial financial value. Finally, your policy must include disciplinary procedures to be followed in the event that a conflict is discovered. Make sure that you read 2 CFR 200.318(c) thoroughly to understand the full extent of these new requirements before revising your current policy. You may also wish to consult your organization’s attorney. Secondly, OMB requires in 2 CFR 200.319 that all organizations to have a fair and well-documented procurement policy will ensure that “all procurement transactions must be conducted in a manner providing full and open competition.” This means that your organization may not allow contractors who contributed to a request for proposal in any way to bid on that particular project. You may not make the qualifications for a successful bid unnecessarily burdensome, nor may you give geographical preference in your award of a contract, except as required by Federal law. Make your contract solicitations clear, accurate, and thorough, so that...

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Grants Professionals Appreciation Week

Posted by on Mar 19, 2015 in Grants & Assistance | 0 comments

Grants Professionals Appreciation Week

Management Concepts is a proud partner of this year’s International Grant Professionals Week. I especially appreciate that the Grant Professionals Association (GPA) recognizes the breadth of professions that our community encompasses. Last week I had the opportunity to see this diversity during a class visit in DC. Each time I am able to sit in with our students, I come away inspired by their daily work assignments. In this particular class, I met Federal employees in audit, programmatic, investigation, and administrative roles; State and local agency representatives managing all aspects of their grants; and a nonprofit grants specialist dealing with the intricacies of passing through funds to international entities. We were brought together not just because we need to know the Cost Principles detailed at 2 CFR 200, but also by a professional commitment to allocate and administer Federal financial assistance fairly to support our communities. I continue to be amazed by the number of people who choose to remain within the grants world once they’ve entered. By the researchers and scientists who spend days and weeks away from the lab to write and manage grants and serve on peer review boards. By the first responders who begin second careers as Federal grants analysts, building upon their experiences managing awards at their local department. By the Federal executives who regularly testify on the strengths and weaknesses of Federal financial assistance programs to Congress. And by the founder of the boot-strapped nonprofit that just won their first $20,000 award to address needs in their community. Part of the reason that so many of us come into grants and end up staying in the field is because these are not easy transactions. There is something satisfying about building a grant program’s funding opportunity so that it is compliant with myriad statutes and the Uniform Guidance, engaging the program managers, administrators, budget officials, and IT specialists along the way. Grants professionals thrive at meeting the challenge of developing successful proposals and achieving a project’s goals and objectives upon award. With successful grant programs, we are able to serve and better our communities and nation. It’s precisely because of this complexity that we all need to take a day or five away from the churn to keep ourselves up-to-date as grants professionals. It’s also why we develop our annual Federal Grants Update, and constantly review our entire grants curriculum. We recognize that as grants professionals our training time and investment must be worth the time away from the office. With that in mind, I hope you will take a few moments to tell us about your training plans and needs to keep you up-to-date. Our Grants Professionals Survey is open now through March 25 – we want to hear from you!...

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Grants Update for Pass-Through Entities

Posted by on Mar 4, 2015 in Grants & Assistance | 0 comments

As part of our in-depth analysis of the Uniform Guidance on our blog, we are diving deeper on some of the important provisions we’ve highlighted – especially those we’ve received questions on during our classes. Today I’d like to talk about new responsibilities for a specific and sometimes overlooked group: Pass-Through Entities (or PTEs.) While the Uniform Guidance greatly increases the amount of accountability for PTEs, it also provides them with more detail than previous guidance in OMB Circular A-133. Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.” (2 CFR 200.74.) For example, in the past, many PTEs have been confused about whether to classify a particular expenditure of Federal funds as a subaward or a contract. OMB addresses this gray area in 2 CFR 330, a specific provision regarding the difference between subrecipients and contractors. Simply put, a subaward is “for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient,” while a contract is “for the purpose of obtaining goods and services for the non-Federal entity’s own use and creates a procurement relationship with the contractor.” More information on this distinction is listed in 2 CFR 200.330. More importantly, PTEs need to study 2 CFR 200.331, Requirements for Pass-Through Entities. OMB clearly lays out what PTEs must take on in this new era of grants management. In many ways, PTEs will behave like Federal awarding agencies by evaluating subrecipients, monitoring subawards, and taking action when noncompliance occurs. First and foremost, PTEs must “[e]nsure that every subaward is clearly identified to the subrecipient as a subaward,” and that each subaward includes all the necessary identifying information in its documents. Within this list is probably the most important new responsibility for PTEs – the risk assessment. All PTEs must now perform a risk assessment on their subrecipients before expending award funds. The risk assessment mirrors what’s done by Federal agencies for their recipients and will help the PTE to develop an appropriate monitoring plan for the subaward. The Uniform Guidance includes a number of factors that PTEs should consider when assessing a subrecipient, which include, but is not limited to: Prior experience with similar subawards Results of any prior audits Whether the subrecipient has new personnel or “new or substantially changed systems” Relevant information from any previous federal agency monitoring Once the subaward is made, the PTE must monitor the subrecipient’s progress and compliance with award terms and applicable regulations. PTEs will review periodic financial and performance reports, perform site visits when necessary, and make suggestions for corrective actions in the event of deficiencies or noncompliance. Like Federal awarding agencies, PTEs also have the authority to put specific conditions in place for subrecipients it deems high-risk. Such conditions may include payment by reimbursement or more frequent progress reports. PTEs must also ensure that qualifying subrecipients obtain a Single Audit, and should issue management decisions in the event of any audit findings. If necessary, PTEs should follow up on corrective action plans and adjust their own records as necessary to account for the actualities of the subaward’s progress. Updated information on subawards with the Uniform Guidance is also available here. What do you think about subaward information...

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Cybersecurity Requirements for the Grants Community

Posted by on Feb 9, 2015 in Grants & Assistance | 0 comments

Last week’s headlines about the cybersecurity breach at Anthem, one of the largest healthcare providers, may have some of us taking steps to ensure that our identities are not at risk for exposure.  Aside from any personal concerns related to Anthem, leaders in the grants community should consider this breach a reminder to examine their own internal controls, ensuring that their organizations have policies and processes in place to protect their systems. One of the many changes included in the Uniform Guidance (2 CFR 200) implemented in December 2014 is the provision at 2 CFR 200.303 to safeguard Personally Identifiable Information (PII) or other sensitive information.  When I first saw this clause in draft form, I was struck that this cybersecurity provision is highlighted.  The rest of the internal controls clause reads like a catch-all for abiding by all “statutes, regulations, and the terms and conditions” that could not be included in the Uniform Guidance.  This focus on protecting PII reflects the importance that the Federal government has put on addressing cybersecurity issues affecting all aspects of our lives. What is PII? PII means information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. (2 CFR 200.79) Protected PII means an individual’s first name or first initial and last name in combination with any one or more of types of information, including, but not limited to, social security number, passport number, credit card numbers, clearances, bank numbers, biometrics, date and place of birth, mother’s maiden name, criminal, medical and financial records, educational transcripts. This does not include PII that is required by law to be disclosed. (See also §200.79 Personally Identifiable Information (PII)).  (2 CFR 200.82) If you and your organization have not already put safeguards in place to protect PII and other sensitive information, or you’re just not sure what’s been done, start with the following: Set up a meeting with your IT team.  Depending on the size and scale of your organization, this could be the Chief Technology Officer or a tech-savvy volunteer.  In either case, you should have a frank discussion on the cybersecurity measures already in place, if any. Develop an internal controls document.  Since this provision falls under internal controls, you should document the policies and actions for safeguarding Protected PII and other sensitive information for your organization.  This internal control document should include the mitigation activities your organization would take should a breach in your safeguarding measures occur.  Your internal controls should also include a procedure for notifying your Federal awarding agency of any breaches to avoid noncompliance issues. Increase awareness.  The first step of becoming cyber-aware is often taking the time to be reminded of what many will consider common sense.  Fortunately, there are many free resources available for those without the ability to do their own in-house training.  The U.S. Computer Emergency Readiness Team (CERT) maintains an extensive resources page.  The Texas A&M Engineering Extension Service (TEEX) offers several free introductory courses as well. We will continue to highlight specific provisions in the Uniform Guidance during the coming months.  Detailed Uniform Guidance update information is also found in Federal Grants Update...

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Looking into Your Grants Performance Measurement Portfolio

Posted by on Jan 29, 2015 in Grants & Assistance | 0 comments

The grants management community has been dealing with the challenges of performance measurement for a long time. While the desire for accountability on how organizations spend Federal dollars is not a recent development, the new Uniform Guidance (2 CFR 200) seeks to enhance the answers to questions such as: Was that project worth funding? Did the project achieve the stated policy goal? Management Concepts Shane Jernigan explored these issues while the Uniform Guidance was in its proposal stage in “Grants Management in the Era of Accountability.” This whitepaper, along with our Accountability for Federal Grants course, provides a good starting point for your understanding of performance measurement. Perhaps you have a good sense of what you need to do for a single program or award. But have you stepped back to look at all the performance measurement activities in your organization’s grants portfolio? You might identify potential investments to help you work smarter, not harder. Here are some suggested steps to help you start the necessary conversations needed to look at your portfolio of grants and programs. The experience will vary based on your organization’s structure and function as well as whether you are a grantor, recipient, pass-through entity, or a mix of all three. Be inclusive. Many individuals, offices, and responsibilities may touch your grants portfolio – ranging from your workers in the field to the person filing your financial reports on time. Each is likely to have their own insights on the challenges of performance measurement and compliance with the Uniform Guidance that you may not experience in your day-to-day work. Take inventory of existing, required, and desired performance measures, objectives, goals, and mandates in your organization’s grant portfolio. This inventory will help you understand your organization’s data collection and reporting requirements.  As you take the inventory, you should also note if your organization is meeting these requirements as well as collecting and reporting processes. The information will inform the conversations you and your colleagues need to have to improve your organization’s performance measurement and reporting capabilities. Identify gaps and opportunities for improvement. Once you have your inventory, you may be able to lay everything side-by-side and determine whether you are doing things right. You might find that you are collecting metrics on grant-funded purchases that do not match up to all the goals and objectives. That’s fine. This information should inform how and what you and your team will do to invest in improvements in the efficiency and accuracy of your collection methods and processes. Recognize the costs associated with performance measurement within your organization. In a recent report on implementing a performance-based approach for Department of Transportation programs, the Government Accountability Office (GAO) included a finding on how implementation costs could vary and be a significant challenge for some states and non-Federal entities. Keeping in mind that the requirements are not going away, organizations need to ensure that the costs of performance measurement are factored into budgets. This applies not only to recipients and sub-recipients, but also to the Federal agencies charged with collecting and analyzing data. These suggestions are geared toward ensuring your organization’s adherence to the accountability, transparency, and risk management requirements of the Uniform Guidance. You’ve got to do it. But these requirements are not just busywork: keep in mind that demonstrating...

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Federal Grants Update 2015 – Implementing the Uniform Guidance

Posted by on Jan 23, 2015 in Grants & Assistance | 0 comments

Since the Uniform Guidance went into effect in December, several people have asked me how things are going with implementation.  My answer is always, “it depends.” To someone outside of the grants community, the flurry of releases surrounding the Uniform Guidance going into effect may make it seem like everything is good to go.  After all, we’ve known that this change was coming for a long time. If only things were that easy. I joined Management Concepts just in time to participate in a session of our Federal Grants Update 2014 course.  Following the class I was first struck by how much I learned and reviewed in terms of the “what” in the Uniform Guidance.  Then our conversation turned to the challenges associated with the “how’s” of implementation.  With this in mind, Management Concepts team of grants experts has shifted the focus of Federal Grants Update 2015 to help members of the grants community tackle these implementation challenges.  Participants in the course will complete exercises to identify the steps needed for compliance, such as reviewing solicitations and updating policies.  We recognize that the impact of Uniform Guidance does indeed depend on the size and complexity of an organization’s financial assistance portfolio.  The information presented in Federal Grants Update 2015 will help these changes be more manageable. In addition, we continue to keep our grants curriculum up-to-date with the Uniform Guidance and other grant reforms, including adding a course dedicated to developing and monitoring Indirect Cost Rates Under 2 CFR 200.  Keep an eye out for additional blogs in the coming weeks. We will be highlighting some of the topics highlighted in our previous blogs, Top Ten Important Items to Know about the Uniform Guidance and Supercircular New Year’s...

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Career Resolutions for You and Your Staff

Posted by on Jan 22, 2015 in Acquisition, Coaching & Mentoring, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management, Workforce Management | 0 comments

Career Resolutions for You and Your Staff

Each January, we all make resolutions with varying degrees of sincerity and dedication. As we get further and further from New Year celebrations, life has a way of creeping in. Achieving lifestyle changes is not solely about exercise or dieting; it should also be about improving your professional competence and positioning yourself and/or your staff for future success. This year, why not try a different resolution? Are you an individual trying to manage your career? Resolve to focus on your career. Ask for the stretch assignment. Explore mentorship opportunities. Challenge yourself to hone current skills or learn new ones. Go for that promotion. Ask for training and professional development. Be ambitious! Get out of whatever rut you may find yourself and commit to creating and fostering a personal path to career success and an environment of learning and advancement. Perhaps you are more seasoned, and at a more advanced place in your career development. Why not investigate a certificate program; successful completion can demonstrate your knowledge and dedication.  Another possibility is getting a leadership coach or mentor.  If you’re lucky, your organization may have a formal mentorship program, but you can do it informally too.  Ask for over-the-shoulder coaching, stretch assignments, or simply discussing your career aspirations with a trusted co-workers can also make a huge difference. Are you a supervisor?  Maybe your resolution is to bolster the skillset of your direct reports.  I’m sure someone took an interest in your development—pay it forward. As the President’s FY15 Budget noted, steps are in place to “restore cuts to Federal employee training to help train, retain, and recruit a skilled and effective Federal workforce, targeting investments in employee training to common, but high-impact areas such as customer service or information technology.” This statement announces a hopeful and positive change, a return to the time-proven practice of investing in people.  Feds are again able to focus on seeking the learning and development that keeps them – and their staffs – efficient, productive, up-to-date, and effective. Career development for your personnel will enhance productivity and morale.  Smart investments in quality learning solutions will help deter the loss of high-performing Federal employees to the private sector. Identify the stepping stones that will take you – and your staff – to the next level. Recognize and reward your dedicated employees and groom them for future success in positions of greater responsibility. Don’t wait for your staff to ask for training. Identify the development opportunities that will lead them to successful performance. As a professional development and performance improvement company, clearly we value formal training. It is important to remember, however, that remaining professionally competitive doesn’t necessarily entail only classroom training. Career development is a broad mix of mentorship, coaching, challenging work assignments, support, industry association, and professional certifications that together enhance the skillsets of Federal employees. Abraham Lincoln once said “I will prepare and someday my chance will come.” Don’t leave your career or the development of your staff to chance.  Positive developments result from intentional steps toward a goal. I love to hear stories about a team finishing a challenging project or a student getting promoted.  We succeed when you succeed because we are dedicated to unleashing the potential of people, teams, and organizations.  Now, what is your resolution? Tom Dungan,...

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2015 Starts Now for the Grants Community

Posted by on Dec 29, 2014 in Grants & Assistance | 0 comments

Earlier this month, we shared the Management Concepts Top Ten Important Items to Know about the Uniform Guidance. Now, we present our Supercircular New Year’s resolutions! Update your regulation bookmarks. Since the Uniform Guidance combines and replaces the eight existing regulations into one, you will want to make sure that you have both handy. You should bookmark any agency’s “adopted and amended” at eCFR.gov as well. Understand that it’s not just the rules.  During their October 2 webcast, OMB representatives emphasized that the FAQs available on the COFAR website (and to be released as Appendix XI to Part 200 – Compliance Supplement) provide context to the Uniform Guidance. Identify and implement the adjustments you need to make to comply with 2 CFR 200.  With 60+ grants management changes, you’ll need to review your programs, policies, processes, and systems to make sure you’re in compliance. This could be as simple as a Federal program manager coordinating the public release of awards greater than $25,000 on USAspending.gov. Or, it could be developing an understanding of how and when to renegotiate your organization’s Indirect Cost Rate. Map out when each part of the Uniform Guidance takes effect for your entity, by award.  Given that the grants community has been driving towards December 26, 2014, as “the day,” it’s easy to think that everything changes in one fell swoop. Take a look at the December 15 post on some of the nuances, like deadlines for audit requirements and updated non-federal entity procurement policies. Then make sure those within your organization concur with the timeline, and that it’s documented. Remember that Federal grants officers and program managers often manage large grant award portfolios. Taking this small step can make sure your award is monitored and audited according to the “right” timeline. Keep up-to-date on DATA Act implementation.  Issuing the Uniform Guidance is just one part of grants reform. Additional changes are coming with the Federal Government’s implementation of the DATA Act during the next three to five years. As with 2 CFR 200, your organization will likely need to make changes as the Federal Government releases and implements new requirements. Be sure to sign up for our Federal Grants Update 2015 course to learn how to best implement the new...

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And the Supercircular is Here

Posted by on Dec 19, 2014 in Grants & Assistance | 0 comments

2 CFR 200 26 Dec 2014 The Office of Management and Budget (OMB) published the interim joint rule implementing the Uniform Guidance (2 CFR 200) in the Federal Register today.  This action ensures that the Supercircular takes effect on schedule on December 26.  OMB did not indicate any surprises in its release – the bulk of the announcement includes agency implementing regulations.  However, Federal managers, pass-through entities, and non-federal entities will need to review the OMB-approved exceptions included today.  These exceptions are often driven by a Department or Agency’s authorizing statutes or other congressional mandated items. A list of all agency exceptions is found here. A few important items we noted during our initial review: Procurement Grace Period Included (200.110). 2 CFR 200 provides non-profit organizations and institutions of higher education (IHEs) a one-year grace period to implement the new procurement standards. OMB will include additional information in the 2015 Compliance Supplement. DUNS references updated to “Unique Entity Identifier.”  This change signals that OMB moving away from using DUNS in Federal awards – in line with DATA Act implementation efforts. New Suspension and Debarment section added (200.212).  Non-federal entities and contractors must also ensure they do not use Federal funding to do business with “certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Please note that eCFR.gov will be updated once the regulations go into effect on December 26. We will continue to review the full publication to make sure that our upcoming 2015 Federal Grants Update sessions are up to...

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The Supercircular is Coming, the Supercircular is Coming!

Posted by on Dec 15, 2014 in Grants & Assistance | 0 comments

In less than two weeks, the much discussed planned changes to Federal grants administration become reality. On December 26, 2014, 2 CFR 200 – Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements – will apply to all new Federal awards.  The Office of Management and Budget (OMB) and Federal awarding agencies are expected to release implementing regulations and additional guidance on or around the same day. To help you and your entity prepare for this exciting day, we created the Management Concepts Top 10 Important Items to Know about the Uniform Guidance.                   The Uniform Guidance, sometimes referred to as the “Supercircular or Omni Circular,” is found online at the electronic Code of Federal Regulations. The administrative requirements and cost principles in the Uniform Guidance will only apply to new awards issued on or after December 26, 2014 – or – to any funding increments made with modified terms and conditions. Grant recipients should always consult the Federal award document when in doubt to which requirements apply to their awards. All Federal awarding agencies will need to implement a pre-award risk assessment and comply with the merit review process outlined in 2 CFR 200. The recipient’s fiscal year drives when the Uniform Guidance for audits takes effect.  The table below shows a few examples of when your auditors will start following the updated rules. Fiscal   Year Dates Guidance   for Audit Requirements 1/1/2014   – 12/31/2014 OMB Circular A-133 7/1/2014   – 6/30/2015 10/1/2014   – 9/30/2015 1/1/2015   – 12/31/2015 Uniform Guidance 7/1/2015   – 6/30/2016 10/1/2015   – 9/30/2016 You should carefully review the changes to procurement procedures, compensation for personnel services, and indirect (F&A) cost rate policies. 2 CFR 200 makes significant changes to each! The Uniform Guidance provides a list of specific responsibilities for pass-through entities. Non-Federal entities will have a full fiscal year grace period to implement the new procurement policies and practices under 2 CFR 200. Non-Federal entities will need to revise internal policies to define “gratuity violations” that could affect Federal awards. Non-Federal entities with awards under both 2 CFR 200 and previous guidance may, as of December 26, 2014, implement entity-wide system changes for all awards to comply with the Uniform Guidance. 2 CFR 200 requires non-Federal entities take reasonable measures to safeguard personally identifiable information (PII).  It’s certainly an exciting time for the grants community!  Management Concepts looks forward to assisting with all your training needs, including delivery of our Federal Grants Update for 2015. Stay tuned for our Supercircular New Year’s...

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This Week in Grants News

Posted by on Nov 3, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Hatch Act Do’s and Don’ts For Federal Employees The Washington Post provides a refresher on the allowable and illegal activities under the Hatch Act  for the Federal workforce.   COFAR Webinar The Council on Financial Assistance Reform (COFAR) conducted a roundtable discussion on the Uniform Guidance. Specifically, panelists discussed the internal control responsibilities of recipients under 2 CFR 200 and new procurement requirements. COFAR posted a recording of the presentation on YouTube.   Grants.gov Maintenance Outages Calendar Beginning in March, Grants.gov will be offline the third weekend of every month. Recipients and grant applicants should review the calendar and plan accordingly. Technology, Innovation Key to OMB’s Management Agenda Beth Cobert, Deputy OMB Director, addressed a leadership conference last week and explained how OMB is implementing the administration’s management agenda. Read more here. Why Agency IGs Are More Bark Than Bite FCW examined the role of agency inspectors general (IG) and identified proposals to strength the ability of IGs to conduct meaningful and effective...

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This Week in Grants News

Posted by on Oct 20, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. OMB Official Speaks to the Grants Professional Association (GPA) Gil Tran from the Office of Management and Budget (OMB) spoke to the GPA annual conference in Portland, Oregon last week. Tran discussed how the Uniform Guidance (“Supercircular”) will transform grants management for Federal awarding agencies and grant recipients. Tran explained that the primary goals of the Uniform Guidance are to enhance performance, transparency, and oversight of grant awards.   Feds Should Keep an Eye on the Race to Replace Issa The House Oversight Committee has jurisdiction over many issues affecting Federal employees and grants management. Due to committee term limits, the current chairman of the committee, Rep. Darrel Issa (R-CA), must relinquish his gavel at the end of the 113th Congress. GovExec looks at the behind-the-scenes campaign to become the next chairman of the committee . A Conversation with OMB Controller David Mader The Association of Government Accountants (AGA) recently interviewed OMB Controller David Mader. In the interview, Mader discussed the DATA Act, the need to improve government transparency, and challenges facing OMB. Read the interview here. Watchdog’s View: An Interview with the DOE Inspector General The Washington Post interviewed the Inspector General for the Department of Education, Gregory Friedman. Friedman discussed the operations of his office, the challenges facing IGs, and the differing leadership traits of past Energy Secretaries. Read the interview here. DATA Act Implementation Underway to Standardize Federal Financial Data Reporting The National Association of Counties (NACO) provides an update on the implementation of the Digital Accountability and Transparency Act (DATA Act).  The DATA Act requires OMB and the Treasury Department to develop standardized financial reporting elements for all financial transactions. OMB is expected to release additional guidance next spring on this effort....

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Countdown to the Supercircular: The Latest Information about the Uniform Guidance

Posted by on Sep 29, 2014 in Grants & Assistance | 0 comments

On December 26, 2014, the Uniform Guidance will be applicable to all new Federal grants. The Uniform Guidance, sometimes referred to as the “Supercircular” or “Omni Circular,” contains nearly 100 changes to grants administration and audit requirements for Federal awards.  To help prepare non-Federal entities to comply with the Uniform Guidance, the Office of Management and Budget (OMB) and the Council on Financial Assistance Reform (COFAR) recently published a second set of Frequently Asked Questions regarding the Uniform Guidance. Additional information from OMB and Federal agencies regarding implementation plans and guidance to non-Federal entities, however, has been sparse. In the spring, OMB announced plans to release a revised version of the Uniform Guidance containing technical edits. OMB has not indicated when it will publish the revised version. Additionally, in the 2014 Compliance Supplement, OMB announced plans to release an update to Part 3 of the Compliance Supplement by August 30, 2014 to reflect new requirements in the Uniform Guidance. OMB has not published the update and has not publicly provided any additional information. Federal agencies have also been less than forth coming about their implementation plans. Except for the National Science Foundation, no other agency has released their draft implementing regulations. The draft implementation regulations would indicate an agency’s plans to deviate from the Uniform Guidance. While OMB expects most agencies to adopt the Uniform Guidance by reference, agencies can request that OMB approve expectations to specific provisions. Gil Tran, an official with the Office of Federal Financial Management in OMB, recently spoke at an American Institute of Certified Public Accountants conference. In his presentation, Tran stated that OMB would release a document containing each agency’s final implementing regulations. The document would also indicate any deviations from the Uniform Guidance. OMB plans to publish the document by December 26, 2014, the date the Uniform Guidance becomes effective for new Federal awards. Non-Federal entities should use the remaining three months to update policies and procedures to ensure compliance with the Uniform Guidance. Be sure to subscribe to this Blog (use the subscribe form to the right) for any additional updates about the Uniform Guidance. Uniform Guidance Resources 2 CFR 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements Council on Financial Assistance Reform (COFAR) Office of Management and Budget Management Concepts Federal Grants & Assistance Course...

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How to Make Training “Stick”

Posted by on Sep 10, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

As summer is ending and kids are going back to school, I was thinking about ways to get the most out of learning. While there are many reasons for attending a training class, most of us take training to meet a certification requirement, or because we need to improve/expand our skills. Just like we tell our kids to do in school, we know that during training, it’s important to take good notes, interact positively with our instructor and classmates, and pay attention to the lessons that are covered. Doing these things will get you through the course just fine. But, to make sure you get the most out of your learning opportunity, there are three easy things you can do before, during, and after training to make sure it “sticks.” Before – Take time to prepare. In addition to having your supervisor approve your training request, you should also spend a few minutes talking to your supervisor about why you need to attend the training. Specifically, review the course objectives with your supervisor and make plans for how you will apply the training once back on the job. If you have an Individual Development Plan (IDP), then the training you are planning to take should be linked directly to a topic or skill on your IDP.If there are specific questions you or supervisor have about the topic or skill, or areas you are struggling with, make a list to share with the instructor. Good instructors will start the class by asking you what you hope to get out of the training. Then, they’ll know which areas to emphasize and which areas will have most meaning for the students. Your instructor and fellow classmates have a wealth of knowledge and varied experiences, and most instructors welcome the opportunity for questions and debate during class! During – Create an action plan. We all know you either “use it or lose it.” Some training courses end with having students develop an action plan. The purpose of this, of course, is to document ways in which you will apply what you learned on the job. This is an important step in helping training “stick.”Mastering the skills you learned in training will take time and practice. Be sure to complete the action plan with things you want to remember and/or apply back on the job. Set goals for yourself and identify a strategy for achieving those goals. Even if you aren’t working on a current project that relates to the training, find a way to get involved with one. Maybe you can take on a small assignment or join a project team at work. Alternatively, maybe there’s a way to practice what you’ve learned in your personal life – plan a party to practice your project management skills, volunteer at your kids’ school, or get involved in a professional or community group to practice your leadership skills. After – Reinforce what you learned. Once you have completed your action plan and left the training facility, it can be easy to get caught up in other priorities, deadlines, and fire drills at work. But, this is the time to put what you learned into action. Here are a few easy tips: Keep your action plan in a place that you can see everyday Create job...

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OMB Releases FAQs for the Uniform Guidance

Posted by on Sep 3, 2014 in Grants & Assistance | 2 comments

The Office of Management and Budget released a second set of frequently asked questions about the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200). This set of FAQs provides additional information to Federal awarding agencies and non-Federal entities preparing to implement the Uniform Guidance, sometimes referred to as the “Superciruclar.” The Uniform Guidance becomes effective for all new Federal awards on December 26, 2014. In the newly released FAQs, OMB addresses more than 80 concerns from the grants community regarding the Uniform Guidance. Some of the questions addressed include: When may non-Federal entities begin to submit proposals for indirect cost rates based on the Uniform Guidance? Should applications submitted prior to 12/26/2014 for Federal awards which will be made after 12/26/2014 reflect the Uniform Guidance? How are procurements of micro-purchase and small purchases under the simplified acquisition threshold less burdensome than those above it? What processes do non-Federal entities need to follow to be authorized to change their current systems for documenting payroll charges? Will the Federal government provide a grace period after the effective date for non-Federal entities to comply with the procurement standards in the Uniform Guidance? Click here to access the...

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This Week in Grants News

Posted by on Aug 25, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Election Uncertainty Complicates Budget Decisions Congress has not passed a single appropriations bill for Fiscal Year 2015, and Congressional leaders are expected to introduce a continuing resolution next month to fund government operations.  Some Republican members, hopeful that their party will retake the Senate in November, are pushing for a CR that would last until January. This could enable the party to have complete control of the process when the CR expires.  Democrats, recognizing the growing likelihood of losing the Senate, are pushing for a December expiration date. Watch for the budget battles to continue up until the start of the new fiscal year on October 1. Read the article here. Being an IG The new DHS IG spoke to the Washington Post about his job, priorities, and office functions. Read the interview here. Metro Pays Feds $4.2M Over Alleged Procurement Violation Metro agreed to repay the Federal government more than $4 million. The government found that Metro improperly awarded a sole source contract without proper documentation or competition.  Read more here. Transparency Group Accuses a Dozen Agencies of Stonewalling FOIA Requests A watchdog organization has filed a suit against a number of agencies. The suit alleges the agencies have withheld information regarding meetings and communications with the White House. Read more...

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This Week in Grants News

Posted by on Aug 6, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Data Transparency: Oversight Needed to Address Underreporting and Inconsistencies on USASpending.gov The Government Accountability Office (GAO) examined agency compliance with the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires agencies to publish award data on USASpending.gov. Multiple government and private studies have found deficiencies in agency reporting on the website. In the latest GAO review, auditors found continued problems related to agencies reporting accurate and complete data for Federal grant awards. GAO estimated the total amount of funding not reported, or reported late, in 2012 was nearly $619 billion. Agencies provided numerous reasons for the reporting problems, including: technical issues, unclear understanding regarding reporting requirements, and lack of internal oversight. GAO recommends improved guidance to Federal agencies detailing reporting requirements and the development of a governmentwide oversight process to ensure agencies are providing consistent information. Read the full report here. GAO: Agencies Performed Internal Control Assessments Consistent with Guidance The GAO issued a report on the internal control processes of the five largest grant-making agencies. The GAO examined the extent in which the Departments of Health and Human Services (HHS), Education, Transportation, Agriculture, and Housing and Urban Development (HUD) complied with requirements in OMB Circular A-123. A-123 requires agencies to provide assurances about the quality and effectiveness of internal controls. Agencies reported ongoing difficulties with making improper payments and deobligating unused grant funds in a timely manner. Read the report here. Congress Remains Stalled on Spending Bills On August 1, Congress began its five week August recess. Congress left Washington without approving any of the twelve annual appropriations bills for Fiscal Year 2015, which begins on October 1. To date, the House has approved seven appropriations bills, while the Senate has yet to approve a single appropriations bill. To avert a government shutdown, Congress is expected to approve a continuing resolution in September to fund all government operations through mid-December. Read more here. President Signs Executive Order to Enforce Labor Laws President Obama signed an executive order requiring Federal contractors to certify their compliance with fourteen Federal labor laws.  The executive order applies to prime contractors and subcontractors receiving more than $500,000 in Federal contracts. Contractors will be required to notify awarding agencies of any violation of the specific laws in the previous three years. This executive order will not affect grant recipients directly; however, any contract made with a Federal grant award in excess of $500,000 will need to contain a provision regarding this new requirement. Read more...

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This Week in Grants News

Posted by on Jul 28, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Obama Signs Executive Order Barring Anti-LGBT Job Bias The president signed an executive order amending Executive Orders 11246 and 11478 to require Federal contractors not to discriminate against gay, lesbian, and transgendered employees. The executive order does not directly affect Federal grants; however, any grant recipient awarding contracts under a Federal grant will need to ensure the contractor abides by the new mandate. Read more here. House Will Vote in September to Avoid Shutdown House Speaker John Boehner announced Thursday that the House of Representatives will consider a continuing resolution (CR) when members return from their month-long August recess.  The CR will likely fund government operations through mid-December, though the House leadership has not released specific details yet. Congress has not yet passed any of the twelve appropriations bills for Fiscal Year 2015, which begins on October 1. Read more here. FEMA: Opportunities to Achieve Efficiencies and Strengthen Operations The Government Accountability Office (GAO) examined the Federal Emergency Management Agency’s (FEMA) administration of disaster assistance programs. This report summarizes previous GAO studies on FEMA’s administrative capabilities. The report does not make any new recommendations. Read the report here. Managing for Results: Enhanced Goal Leader Accountability and Collaboration Could Further Improve Agency Performance The GAO examined how agency priority goal leaders administer their responsibilities under the Government Performance and Results Act Modernization Act (GPRAMA). Multiple officials discussed the role grant programs have in meeting agency priority goals. Read the report here. 3 Ways to Get More Out of the DATA Act Steve Goodrich, President of the Center for Organizational Excellence, examines how Federal agencies should implement the Digital Accountability and Transparency (DATA) Act to maximize benefits of the law. Read Goodrich’s suggestions...

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This Week in Grants News

Posted by on Jul 14, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Senate Confirms Shaun Donovan to Run OMB The Senate confirmed Shaun Donovan as the next director of the Office of Management and Budget (OMB) by a vote of 75-22. Donovan replaces Sylvia Mathews Burwell as OMB Director.  Read more here. What Life is Really Like Behind the IG Curtain Federal News Radio interviewed Brian Miller about his experience as the former Inspector General (IG) for the General Services Administration.  Miller said that the two primary goals of an IG, to reduce waste, fraud, and abuse and to promote efficiency and effectiveness, can pose a difficult balancing act. “It’s like straddling a barbed fence,” Miller said.  Listen to the interview here. Improper Payments by Federal Government Top $100B The Government Accountability Agency (GAO) released its annual report on improper payments made by federal agencies to ineligible recipients. The GAO estimates the amount of improper payments in FY 2013 was $105.8 billion, which is down from $107 billion the previous fiscal year.  Read Government Executive’s article on the GAO report here. Race to Finish FY 2015 Agency Budgets Hits Snag Federal News Radio reports that Congress may not meet the October 1deadline to pass all twelve appropriations bill for the start of fiscal year 2015. As a result, Federal agencies should prepare for a possible continuing resolution for funding. Read the article...

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This Week in Grants News

Posted by on Jul 7, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Federal DATA Act Work Begins President Obama signed the Digital Accountability and Transparency (DATA) Act in May, and Federal agencies have begun the process to prepare for the law’s requirements. The DATA Transparency Coalition examines recent Treasury Department actions to comply with the law. GSA Seeks Public Comment on FAPIIS Collection Forms The Duncan Hunter National Defense Authorization Act of 2009 requires the Office of Management and Budget (OMB) to develop a database to track the history performance of grant recipients. OMB issued proposed guidance in 2010 detailing the implementation of the Federal Awardee Performance and Integrity Information System (FAPIIS). In 2011, OMB announced it did not have the necessary financial resources to continue implementing FAPIIS. On July 3rd, 2014, the General Services Administration (GSA) issued a notice in the Federal Register seeking the public’s input on the FAPIIS collection form. GSA stated in the notice that OMB is in the process of finalizing the guidance on FAPIIS. Is it possible that FAPIIS will become a reality? OMB has not made any public comments about the system since 2011, so it is difficult to draw any conclusions. Stay tuned to this blog for any additional information! To read the GSA’s notice, click...

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This Week in Grants News

Posted by on Jun 30, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Donovan’s Nomination Advances in the Senate The Senate Homeland Security and Government Affairs Committee voted to approve President Obama’s nominee to be Director of the Office of Management and Budget (OMB), Shaun Donovan.  Brian Deese is serving as Acting Director until the Senate confirms Donovan.  Federal News Radio has more information about the committee vote. OMB Calls on Congress to Eliminate Outdated and Duplicative Reporting Requirements OMB has identified more than 400 required reports that should be eliminated. In a blog post on the OMB website, Beth Corbet, the Deputy Director for Management, urged Congress to pass legislation to reduce reporting requirements. Read the blog post here. Education Department Proposes Supplemental Priorities for Discretionary Grant Programs The U.S. Department of Education published a notice in the Federal Register on June 24. The notice explained the Department’s proposed funding priorities for competitively awarded grant projects. The public comment period for the notice closes on July 24. Read the notice here. Reducing the Administrative Workload for Federally Funded Research Two subcommittees of the House Science Committee held a joint hearing on June 12 to examine ways to reduce reporting and administrative burdens for research grant recipients. The subcommittees heard testimony from the Inspector General of the National Science Foundation and a representative from the Federal Demonstration Partnership. Watch the committee hearing...

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This Week in Grants News

Posted by on Jun 16, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important Federal grants-related news. National Science Foundation Releases New Grants Manual The National Science Foundation (NSF) released a draft version of the 2015 Proposal and Award Policies and Procedures Guide. The new manual incorporates the provisions found in the Uniform Guidance (“Supercircular” or Omni Circular). The manual adopts the Uniform Guidance with only minor changes. Review the manual here. Donovan Talks Up Management in OMB Confirmation Hearing Government Executive examines confirmation hearings for Shaun Donovan. President Obama appointed Donovan to be the Director of the Office of Management and Budget (OMB). Donovan testified that he will promote data-driven decision making through greater use of performance metrics. The Senate is expected to easily confirm Donovan, who will be the fourth OMB Director in the Obama Administration. GAO: OMB Should Strengthen Reviews of Cross-Agency Goals The Government Accountability Office (GAO) issued a report this week that examined the Office of Management and Budget’s implementation of The Government Performance and Results Act Modernization Act (GPRAMA). GPRAMA requires OMB to coordinate with agencies in developing cross-agency goals and reporting on agency progress in meeting the goals. GAO provided seven recommendations to improve OMB’s reporting standards. Read the report...

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This Week in Grants News

Posted by on Jun 9, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important Federal grants-related news.   Amendment to Eliminate EDA Funding Fails The House of Representatives rejected an amendment to an appropriations bill to defund the Economic Development Administration (EDA). The EDA is a Commerce Department agency that awards funding to projects designed to increase employment. The vote was 129 to 280. Read more here. With Budget Deadline Still Months Away, Should Agencies Start Prepping for CR? Federal News Radio examines the pros and cons for agencies to prepare for a possible Continuing Resolution this year. Congress has until September 30 to pass twelve appropriations bills; however, few observers expect Congress to meet this deadline. Education Grants: Promise Neighborhoods Promotes Collaboration but Needs National Evaluation Plan The GAO examined the Department’s Promise grants. The report recommended that the Department communicate expectations more clearly, identify Federal resources that can contribute to the program’s goals, and develop a strategy for evaluation of awarded projects. Read the report here. DATA Act Requirements Don’t Map to Federal Systems The Federal Chief Information Officer said that current government systems do not comply with provisions in the DATA Act and that “heavy lifting” will be required. Read why here. NEW WHITEPAPER AVAILABLE: Download our new whitepaper, Grants Management in the Era of Accountability: Performance Measures in the Uniform Guidance to find out how the new performance measures required in the “Supercircular” impact grants...

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This Week in Grants News

Posted by on Jun 2, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important Federal grants-related news. OMB Circular A-133 Compliance Supplement 2014 The Office of Management and Budget released the A-133 Compliance Supplement. In the Compliance Supplement, OMB announced plans to: continue to examine ways to reduce the number of compliance requirements, though no decisions have been made; maintain the basic structure of the compliance requirements, found in Part 3, regardless of the number of compliance requirements; consider updating  Part 3 to align with the Uniform Guidance (“Supercircular”); release a revised Part 3 draft by August 30, 2014 that reflects any proposed changes; and update Part 6 to reflect the Uniform Guidance’s reference to the COSO Internal Control-Integrated Framework and to the Greenbook.                 The A-133 Compliance Supplement 2014 can be found here. HUD Secretary Nominated to Lead OMB The president nominated Secretary Shaun Donovan as the next OMB Director. Once confirmed by the Senate, he will replace Sylvia Mathews Burwell. The Wall Street Journal looks at five challenges that await Donovan at OMB. Agencies Have Taken Steps to Improve Suspension and Debarment Programs The GAO issued a report that examined the suspension and debarment programs at six Federal agencies. The GAO found that the number of contractors and grant recipients suspended or debarred has more than doubled in the past year. Read the report here. Whistleblower Hotlines Changing the Way IGs Respond to Waste, Fraud, and Abuse Federal News Radio looks at how many OIGs have been able to significantly reduce the time to process hotline complaints. For example, some OIGs have begun to use social media to make it easier for individuals to report waste, fraud, and abuse. NIH Seeks to Maximize Fairness in Peer Review The NIH announced new procedures to ensure all applicants are fairly evaluated during the peer review process. Read about the initiatives here. Beating the Odds: Why One Bill Made It Through a Gridlocked Congress In a modern version of Schoolhouse Rock’s “I’m Just a Bill,” Vox explains the behind-the-scenes maneuvering of DATA Act supporters to ensure it became...

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This Week in Grants News

Posted by on May 19, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important Federal grants-related news. Not Everyone Loves the DATA Act President Obama signed landmark legislation that will increase the transparency of Federal spending and not everyone is thrilled. Find out why. Homeland Security Moves Closer to Getting Off GAO’s High-Risk List The Government Accountability Office (GAO) issued a report highlighting the progress the Department of Homeland Security is making in addressing frequent problem areas. Find out what this means for the Department. When Funds Go Missing, What Can You Do? What Must You Do? Nonprofit Quarterly provides a resource to help your organization address suspected embezzlement. Find out what you should do. Department of Energy: Administrative Requirements for Grants and Cooperative Agreements The Department of Energy issued a proposed rule to update administrative requirements for grants and cooperative agreements to for-profit organizations. Find out what the Department...

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This Week in Grants News

Posted by on May 12, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important Federal grants-related news. The DATA Act is Law President Obama signed the Digital Accountability and Transparency (DATA) Act into law on May 9th.  The DATA Act will require all federal spending to be identified on www.USASpending.gov. Financial reporting forms for grant recipients will likely have to be modified to meet the DATA Act’s requirements. Additional information about the DATA Act can be found here.  Radio Interview With the Data Transparency Coalition Federal News Radio interviewed Hudson Hollister, the executive director of the Data Transparency Coalition, about how the DATA Act will affect Federal agencies. Listen to the interview here. President Nominates New OMB Controller President Obama nominated David Mader to be the Controller of the Office of Management and Budget. The position has been vacant since Interim Controller Norman Dong left OMB in March. Mader, who is currently in the private sector, previously worked for the Federal government for over thirty years. Read more about Mader’s appointment here. OMB Prepares for Fiscal Year (FY) 2016 Budget The Office of Management and Budget released a memorandum to Federal agencies regarding budget requests for FY 2016. Agencies were instructed to reduce their budgets by 2% to comply with sequestration requirements. Read the memo here. OPM Issues Final Rules Implementing the Hatch Act Modernization Act The Office of Personnel Management issued a final rule that will implement provisions in the Hatch Act Modernization Act. The law allows local and state employees, whose salaries are paid in part by Federal grants, to run for a partisan political office. This provision does not extend to those employees whose entire salary is derived from Federal grants. Additionally, the law requires District of Columbia government employees to be classified as city employees. The rule goes into effect on June 4. Read the rule...

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Use the Active Voice for More Impactful Writing

Posted by on May 8, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

We often lessen the impact of our writing by using the passive voice. In The Government Manager’s Guide to Plain Language, I offer some very practical guidance and examples that illustrate how government managers can add directness and impact to their communications, both with their staff and with the public. Give it a try with something you’ve written recently. See the difference? PREFER THE ACTIVE VOICE In an active sentence, the person or agency performing an action is the subject of the sentence. In a passive sentence, the person or item acted upon is the subject of the sentence. Changing passive voice to active voice in your writing can add energy and cut wordiness. Consider the following two versions of the same basic message, which describes a supervisor’s actions: All issues and questions were discussed and explained very clearly by my supervisor. Following the completion of each task, I received a full feedback that gave me an opportunity to reflect upon and improve my performance. I was given support in addressing my personal objectives such as improvement of interviewing skills and building technical and client knowledge. My supervisor clearly explained all the issues and fully answered my questions. His comments after every task helped me to reflect upon and improve my performance. He constantly encouraged me to address my objectives, such as improving my interviewing skills and building my technical knowledge. The first version, in passive voice, is wordier, weaker, and less direct. The second version, in active voice, is briefer, clearer, and more conversational or natural. The active voice emphasizes who is doing something: “My supervisor clearly explained all the issues and fully answered my questions.” The actor (my supervisor) comes first in the sentence. The subject of the sentence does the action. The passive voice emphasizes who or what is being acted upon: “All issues and questions were discussed and explained very clearly by my supervisor.” Or, the doer may not be mentioned in the passive sentence: “All issues and questions were discussed and explained very clearly.” To communicate effectively, write most of your sentences in the active voice. To change passive sentences to active, follow these four steps:   1. Find or supply the actors. “An excellent job was done by Stacy.” Stacy is the actor. 2. Put the actor at the beginning of the sentence. “Stacy . . .” 3. Replace the passive verb with an active verb. “Stacy did . . .” 4. Make the subject of the passive sentence the direct object. “Stacy did an excellent job.” Of course, sometimes the passive voice is a better choice, such as when you need to point out an error or shortcoming in a diplomatic way. “A mistake was made in the last set of calculations” is more tactful than “You made a mistake in the last set of calculations.” Excerpted with permission from The Government Manager’s Guide to Plain Language by Judith Gillespie Myers, PhD., a book in series The Government Manager’s Essential Library.   © 2013 by Management Concepts, Inc. All rights reserved....

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NGMA: Embracing Change and Preparing for the Future

Posted by on Apr 25, 2014 in Grants & Assistance | 0 comments

The National Grants Management Association (NGMA) held its Annual Grants Training Program last week in Arlington, VA. This year’s theme, “Embracing Change: Grants Management in Transition,” focused on how the grants community can best prepare for regulatory changes associated with the Office of Management and Budget’s (OMB) grants reform initiative. OMB Officials provided updated information on recent activities from the Council of Financial Assistance Reform (COFAR) and outlined the process for agency implementation of the Uniform Guidance (the “Supercircular”). Gil Tran explained that agencies have until June 26 to submit draft implementing regulations to OMB. OMB expects most agencies will implement the Supercircular by reference. Many of the breakout sessions also focused on the Supercircular, such as how recipients should update their procedures to comply with new procurement and audit requirements. Additional breakout sessions highlighted other recent changes to grants management, including recent Congressional and agency actions. Officials from the National Science Foundation (NSF), the Department of Health and Human Services (HHS), and OMB explained how their agencies are using the Do Not Pay List to reduce the risk of waste, fraud, and abuse to federal funds. The conclusion from this year’s conference was that this is an exciting, but challenging, time for the grants community. Congress Poised to Approve the DATA Act Congress returns from its spring recess this week. Among the bills the House may consider is the Digital Accountability and Transparency (DATA) Act. On April 10, the Senate unanimously approved a compromise version of the bill that was agreed to by members in both chambers. The House is expected to easily approve the bill and send it to President Obama. The DATA Act will require all federal funding, including grant awards, be published on USASpending.gov. The bill is designed to increase the transparency of federal spending and allow the public to identify how, and who, is spending federal funds. Additional information about the DATA Act can be found...

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Assess Before You Diagnose

Posted by on Apr 22, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

I opened my copy of Performance Improvement recently and was excited to read “An Ounce of Good Assessment is Worth A Pound of Analysis and A Ton of Cure” by Roger Kaufman. It is only natural for managers and executives to diagnose their organizations. They want quick answers. The sooner they can figure out what is causing a problem, the sooner they can focus on getting “real work” done. When I go to the doctor, I am the same way. I’ve already Googled my symptoms and think I know what’s wrong. I don’t want to spend time talking about the different possibilities. I want to focus on how I can cure my ailment. What I really want is a shot or pill that can fix me quickly! It’s frustrating when I leave the doctor’s office with nothing more than an order for a diagnostic test. But, I know that it’s the right approach to gather additional information to make a correct diagnosis. Organizations work the same way. Stepping back to gather information takes time. It takes resources. It requires clear thought. An assessment is simply a tool that helps you collect the information so that you can accurately diagnose what’s going on and then find the right solution. Does this mean that assessment has to be a costly, time-consuming endeavor? Of course not. Many ways exist to gather information—interviews, focus groups, online assessments, surveys, observations, and existing metrics. You might conduct a few interviews with key stakeholders.  You could invite five or six people to a focus group or spend a day observing employees on the job. You also might use an online assessment or survey, which are great ways to get information from many people in a relatively short amount of time. I learned from Dr. Kaufman’s article that investing the time to accurately diagnose the problem is not a new concept. In 1975, another leading scholar in the field of instructional design and performance improvement, Joe Harless, wrote a book called An Ounce of Analysis is Worth a Pound of Cure.  Today, people still want to rush to find a quick solution without spending time to analyze the problem. The next time you think you might be self-diagnosing a problem in your organization, stop to ask yourself a few questions: What are other possible explanations for what I am seeing? What evidence do I have that my explanation is the correct one? Am I relying on anecdotal evidence, such as a handful of personal observations or what others have told me? How can I collect information that will help me reach the right conclusion? If you think an assessment will help you better understand an organizational problem, seek assistance from an expert. Find someone who can advise you on how to collect the information you need for an accurate diagnosis. Performance improvement specialists—sometimes called human performance technologists, assessment specialists, instructional systems technologists, or industrial/organizational psychologists—will know the latest and most efficient way to proceed, often drawing on their experience and lessons learned while helping with other...

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Senate Approves DATA Act, Final Passage Expected Soon

Posted by on Apr 14, 2014 in Acquisition, Grants & Assistance | 0 comments

On Thursday, April 10, the Senate approved the Digital Accountability and Transparency Act (DATA Act) by unanimous consent.  The Senate action follows weeks of behind-the-scenes negotiations between House and Senate supporters, and the approved bill represents a compromise between the two chambers. The House, which previously approved another version of the DATA Act by a 388-1 vote in November, is expected to give final approval to the bill in the next few weeks. The DATA Act is designed to increase transparency and accountability of federal grants, contracts, and government spending. The bill would require that all government spending be published and publicly available on USASpending.gov. To achieve this objective, the Secretary of the Treasury and the Director of the Office of Management and Budget (OMB) would be required to develop standardized government-wide data elements to ensure uniformity of reporting requirements. The administrative burden of complying with the DATA Act requirements will fall primarily on federal agencies. Provisions in the legislation requires federal agencies to submit grant financial information to USASpending.gov, therefore, grant recipients and pass-through entities should not see an increase in reporting requirements. Grant recipients may, however, see an increase in financial monitoring as federal awarding agencies will be required to track every federal dollar. This requirement may require grant recipients to improve accounting procedures and internal controls. The White House has not announced President Obama’s position on the legislation. In January, a memo from OMB to agency leaders regarding the DATA Act was leaked to the media. In the memo, OMB proposed significant changes to the legislation, which bill supporters claimed were attempts to severely weaken the bill. The final version of the bill does not contain the proposed changes that OMB supported. With such overwhelming and bipartisan support from Congress, it is almost certain the bill will become law. Washington Post reporter Andrea Peterson wrote a fantastic article summarizing the practical implications of the DATA Act. Her article, “The DATA Act Just Passed the Senate. Here’s Why that Matters.” can be read...

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Is ILT Dying?

Posted by on Apr 8, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

Yes, ILT (instructor-led training) is dying, but we need not mourn its loss. Instead, we should realize we are standing on the brink of something exhilarating: the reincarnation of instructor-led training as virtual instructor-led training (VILT). The traditional brick-and-mortar ILT classroom has been smoldering for a while now. As federal travel budgets shrink and training dollars dry up (although the future of training is looking up), organizations are seeking alternatives to fill their training needs. Organizations are continually looking for a way their employees can be out of the office for less time. In response, virtual instructor-led classes, which are typically delivered by an instructor in a virtual environment, are swooping in to meet this need. Organizations that have previously only offered traditional ILT classroom experiences acknowledge the customer expectation that these same courses be available virtually. ILT Reborn VILT marks the rebirth of ILT. In this format, employees can take required training courses without leaving their worksite. Some parts of the training may be available asynchronously, meaning students can learn at their own pace, and when their schedule allows. The classic VILT experience is guided by a facilitator, who in many cases will be delivering instruction real-time, so students can ask questions and participate in peer discussions. Given that there has been an overall increase in the use of VILT, and it is likely not going away anytime soon, it is important to address some of the common questions that come up around this training modality. How can you possibly replicate the ILT experience virtually? The answer is you cannot — and should not — simply carry over the ILT experience into virtual training. Instead, you design VILT courses so that the material can come to life in a virtual space. VILT courses are not mindless page-turners; rather, they have the potential to be highly interactive, relevant training experiences with frequent instructor and peer interaction built into the course. Where does the instructor fit in this new format? In the VILT class, the instructor still stands at the helm of the learning experience, coaching students, telling stories, answering questions, and delivering lectures (recorded or live). In fact, the instructor may be even more tapped into how individual students are doing than if the class were offered only in a traditional face-to-face classroom. VILT has the potential to provide more engagement through discussion forums, chats, polls, and other “pulse checks” that help the instructor gauge each learner’s mastery of the content. How do you reach those students who prefer to learn in an ILT setting? The point of VILT classes is not to set students adrift, floating alone in the virtual sea. Instead, they are part of a community of learners who happen to interact in a virtual classroom. Students often have the opportunity to explore course content at their own pace, so they can take the time they need with the material. In addition, the virtual environment encourages support, as peers respond to questions and share knowledge with each other. In the VILT classroom, there may also be some hesitation on the part of non-digital natives. Those who have built their careers sitting in the physical classroom with an instructor leading from the podium may find it difficult to envision a productive virtual training experience. Given that the...

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New Requirements in the Supercircular Designed to Enhance Accountability

Posted by on Apr 7, 2014 in Grants & Assistance | 0 comments

Federal agencies and grant recipients face increased pressure to protect federal funds from waste, fraud, and abuse.  The Office of Management and Budget (OMB) and the Council on Financial Assistance Reform (COFAR) identified the need to strengthen oversight of federal awards as one of the primary objectives of grants reform.  As a result, the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements (the “Supercircular”) contains two new provisions that will promote greater recipient accountability relating to federal funds. Under §200.112, federal agencies must establish and implement conflict of interest policies for all grant awards. The Uniform Guidance stipulates that the conflict of interest policy must include a provision requiring recipients to disclose, in writing, any potential conflict of interest affecting the grant award.  Agencies have flexibility in designing conflict of interest policies to best meet their specific programmatic needs. Many agencies currently have established conflict of interest policies, and therefore, the administrative burden of this provision should be minimal. An example of a conflict of interest policy can be found on the National Science Foundation’s website. Grant recipients will also be required to notify the awarding agency or pass-through entity, in writing, of all violations of federal criminal law involving fraud, bribery, or gratuity violations that present a risk to federal funds.  Recipients that fail to notify the awarding agency or pass-through entity may be subject to sanctions for noncompliance, including suspension and debarment. The provision, found in §200.113, uses broad and generic language to provide agencies with flexibility in crafting specific regulations. This provision is modeled after the mandatory disclosure requirements found in the Federal Acquisition Regulation (FAR) (73 Fed. Reg. 67064). Once agencies have implemented the new policy, recipients should update their internal policy manuals and procedures to comply with agency requirements. The Uniform Guidance, found at 2 CFR 200, consolidates eight existing grant circulars into one set of uniform regulations.  The Uniform Guidance contains more than 60 policy changes and new requirements affecting grants management. The provisions in the Uniform Guidance will become applicable to all new grant awards on December 26,...

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Tips for Government Managers to Overcome Writer’s Block

Posted by on Apr 3, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

Whether writing a business plan, memo, or report, one of the hardest tasks government managers face in writing is getting started. In my recent book, The Government Manager’s Guide to Plain Language, I offer some  tips to help you break through the writer’s block we all experience—and also to help you make an initial assessment of what you have written before passing it along for editing and review.   TIPS FOR WRITING DRAFTS To make the draft stage easier and more productive, consider the following steps: • Once you have a complete outline in hand, write your first draft quickly. • Schedule blocks of uninterrupted time for drafting. • Begin with the easiest section. • After you complete the first draft, walk away from it. • After you get some distance, take a few minutes to review your draft with fresh eyes. • Assess the following before going into the editing stage: – Did I explain my purpose clearly? – Did I consider the role, knowledge level, attitude, and other characteristics of the reader? – Does the overall organization of the draft make sense? – Did I provide closure? (For example, did you tell readers exactly what you want them to do?) After taking a cursory look at your first draft, you’re ready to go on to the editing stage. Excerpted with permission from The Government Manager’s Guide to Plain Language by Judith Gillespie Myers, PhD, a book in the new series The Government Manager’s Essential Library.  © 2013 by Management Concepts, Inc. All rights reserved....

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OMB: The Supercircular is “‘Same Same’ But Different”

Posted by on Mar 24, 2014 in Grants & Assistance | 0 comments

On March 19th, officials from the Office of Management and Budget (OMB) presented at the monthly National Grants Management Association’s (NGMA) March training.  The presentation, entitled “Reducing Red-Tape to Improve Outcomes: The Council on Financial Assistance Reform’s (COFAR) New Uniform Guidance 2 CFR 200,” focused on recent actions by the COFAR to enhance grants management. The presentation provided a high-level examination of policy changes contained in the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements (the “Supercircular”). Gil Tran, an official with the Office of Federal Financial Management at OMB, attempted to alleviate the audience’s fears of the upcoming implementation of the Supercircular by displaying a t-shirt he purchased during a recent trip to Vietnam. The shirt read “Same Same” on the front and “But Different” on the back. Tran explained that the saying reminded him of the Supercircular by stating that “it is similar to the current guidance, but different.”  The Supercircular, Tran explained, maintains general principles of grants management while revising existing policies. The policy revisions are designed to: increase accountability for recipient performance; promote the efficient use information technology; provide consistent and transparent treatment of costs; implement standard business processes and data definitions; encourage family-friendly policies; strengthen oversight;  and mitigate the risk of waste, fraud, and abuse to federal funding.  The presentation also provided information about how the federal government will implement the Supercircular. OMB plans to publish the 2014 Single Audit Compliance Supplement in April. The Compliance Supplement will contain additional information on how auditors should adhere to the new audit requirements found in the Superciruclar.  By June 2014, agencies are expected to submit to OMB draft rules incorporating the Supercircular into agency regulations. Tran stated that it is OMB’s expectations that agencies will adopt the Supercircular by reference by publishing a final rule as soon as possible. On December 26, 2014, the Supercircular will become effective for all new awards and federal agencies and recipient entities will be required to comply the new policies.  Tran concluded the training by stating that OMB will be publishing technical corrections to the Supercircular in the Federal Register in the coming months. Tran stated that a review of the Supercircular has identified multiple sections that require edits.  Agency officials are encouraged to submit proposed technical corrections to OMB as soon as possible.  Stay informed of the latest Supercircular developments by following Management Concepts on Twitter at...

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Learn About the Supercircular Online!

Posted by on Mar 14, 2014 in Grants & Assistance | 0 comments

Management Concepts is excited to announce two online sessions of our popular Federal Grants Update 2014 course. This year’s Federal Grants Update course focuses primarily on OMB’s Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements (“Supercircular”).   The Supercircular contains more than 50 policy changes for grants management that must be implemented by December 2014.  The online session is ideal for grants professionals who want to learn about how to prepare for these changes from the comfort of their own home or office. Topics for the course include: OMB’s Supercircular –        Background and structure of the Supercircular –        Changes to the grant award process –        Policy changes to grants management –        New requirements for pass-through entities –        Modifications to the cost principles –        Procedural changes for indirect cost negotiations –        New audit requirements Issues Affecting Grants Management –        Federal budget and fiscal policy –        The DATA Act –        Recent actions taken by the COFAR The online format will enable participants to engage in interactive activities, ask questions, and provide comments to the instructor. When: June 24-25 or September 3-4 Time: 11:00 a.m.-3:00 p.m. ET Where: Anywhere you have internet and phone access Note: To ensure your computer and software meet our basic requirements, run the Adobe Connect Diagnostic Test at...

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Meet the Supercircular – Changes to Procurement Policies

Posted by on Feb 25, 2014 in Grants & Assistance | 0 comments

Meet the Supercircular – Changes to Procurement Policies

The Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements (“Supercircular”) contains more than 50 policy changes to grants administration. Grant recipients and pass-through entities need to prepare for the changes now to be ready on December 26, 2014 when the Supercircular becomes effective. Subtitle III of Subpart D of the Supercircular details the procedures non-federal entities must follow when procuring property, goods, and services under a federal award. The Supercircular uses language from A-102 as the foundation of this subtitle. The selection of A-102 as the basis for procurement standards is likely to present some difficulties and administrative burdens for recipient entities that currently follow 2 CFR 215 (A-110). Institutions of higher education (IHEs), hospitals, and nonprofit organizations will need to review and update their procurement policies to ensure compliance. Section 200.320 identifies the five procurement methods non-federal entities must use. The five allowable methods are: Procurement by micro-purchase; Procurement by small purchase procedures; Procurement by sealed bids; Procurement by competitive proposals; and Procurement by noncompetitive (sole-sourced) proposals. The micro-purchase procurement method is a new provision that will enable non-federal entities to obtain supplies, valued at less than $3,000, without soliciting competitive quotations. For example, a recipient that needs to buy $500 of office supplies, such as pens, computer paper, and ink cartridges, can go to an office supply store and purchase the items. Recipients will no longer have to request quotes for these types of purchases. Receipts will still need to be kept for accounting purposes. All non-federal entities will need to update their internal procurement policies to reflect the changes described in the Supercircular. It is important that a recipient’s procurement policies identify the five allowable methods outlined in Section 200.320. Recipients should also note that the Supercircular increases the Simplified Acquisition Threshold to $150,000 and ties all future increases to the Federal Acquisition Regulation (FAR). The Supercircular also requires all non-federal entities to maintain written policy standards governing organizational conflicts of interest. Under current regulations, non-federal entities are required to maintain standards of conduct covering conflicts of interest. The new provision will require IHEs, hospitals, and nonprofit organizations to devise and implement new...

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Contract Negotiation: The Ambiguous Authority Tactic

Posted by on Feb 20, 2014 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management, Uncategorized | 0 comments

In The Government Manager’s Guide to Contract Negotiation, author LeGette McIntyre offers federal negotiators a host of tactics they can use to get a solid, fair deal for their agency. One of these tactics is the “ambiguous authority” tactic—which we’ve all been subjected to when we’ve bought a car! How do you employ the tactic to get the best deal for the government? Share some experiences with your colleagues and we’ll all be better prepared for the next negotiation!   THE AMBIGUOUS AUTHORITY TACTIC You can use the ambiguous authority tactic when you are the chief negotiator but you don’t have ultimate authority to finalize the deal. You may have to go through an approval process before finalizing the negotiated agreement. You may have instructions to consult with a higher-up before you finalize the deal. These people or committees will be the ambiguous authorities you will defer to if you elect to use this tactic. The most common use of this tactic is in buying a car. You’ve slogged it out with the salesperson all day and finally think you have a deal. But then the salesperson wrinkles her brow, frowns, shakes his or her head slowly, and says those magic words, “I’ll have to talk to my sales manager.” Usually, there is no sales manager. The salesperson simply leaves you in the room to stew and sweat a little bit. You start second-guessing your last offer—and negotiating against yourself.   It’s good practice never to go into a negotiation with unlimited authority to close the deal, even if everyone has given you preapproval to do so. Always have someone you must go back to for approval. If you do have ultimate authority, never let negotiators for the other side know it. Once they find out you are the sole decision-maker, they know you are the only obstacle in the way of the terms and conditions they want. There is just one person to convince. The ambiguous authority tactic is usually employed just before the close of a negotiation. The other side thinks it has a deal, and all of a sudden there is someone else, or even a whole new cast of characters, to deal with. The last thing the other side wants is for this mysterious other person to blow a deal that is so close to being consummated. Negotiators may start to second-guess themselves and be tempted to soften their positions a bit to help you “sell” the deal to the other authority. They actually might start making additional concessions without demanding something in return. In effect, they start bidding against themselves. Always try to keep your ambiguous authority as vague as possible. This prevents the other side from immediately countering your tactic. If you hold out your boss as your ambiguous authority, the other side may simply ask you to bring that person into the negotiation. It’s harder for them to put a face on something vague like “the review committee,” “my finance folks,” or “my customers.” The best way to counter the ambiguous authority tactic is to head it off at the pass. Simply refuse to negotiate with anyone who doesn’t have ultimate authority to bind the company. Remember, you control the process—including setting and running the agenda. When you send the other side...

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Meet the Supercircular: Prepare for the Changes Coming Your Way

Posted by on Jan 28, 2014 in Grants & Assistance | 0 comments

The Office of Management and Budget (OMB) released the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Supercircular”) on December 26, 2013. The Supercircular consolidates eight existing grants-related circulars into a single document and establishes uniform federal grant regulations for non-federal entities. The Supercircular’s provisions become effective on December 26, 2014. To assist awarding agencies, pass-through entities, recipients, grant writers, and auditors in preparing for the changes to grants management, Management Concepts will be hosting a webinar on February 26th. “Meet the Supercircular: Prepare for the Top 10 Changes Coming Your Way!” is a 60-minute webinar that will provide participants with a look at the most important changes to grants management.  Participants will learn best practices to ensure their entity is ready to meet the new requirements. There will also be an opportunity to ask specific questions about the Supercircular.   Course:  Meet the Supercircular: Prepare for the Top 10 Changes Coming Your Way! When: February 26, 2014 from 11:00am to 12:00pm EST Format: Online e-seminar conducted through Adobe Connect Cost: $59 To register for the webinar, visit the Management Concepts course catalog. The Meet the Supercircular webinar is designed to provide participants with a high-level briefing on the Supercircular. Management Concepts will also provide a day-long, indepth analysis of the Supercircular in our Federal Grants Update 2014 course. The Update course will run from March through December...

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This Week in Grants News

Posted by on Jan 22, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. Congress Passes Omnibus Spending Bill On Thursday, January 16th, the Senate gave final approval to the spending plan that will fund government operations through the end of September.  The $1.1 trillion omnibus bill will avert another government shutdown for the next nine months and reduces sequester spending cuts. President Obama signed the bill on Friday. GovernmentExecutive.com has more information. 2014 Funding: Agency-by-Agency Breakdown of Spending Bill Federal News Radio provides details about each agency’s funding levels through the omnibus spending bill. Highlights include: an increase in the Department of Education’s grant spending; a slight increase in research funding for the Department of Energy; a reduction in funding to the National Institutes of Health; and increased funding for some grant programs through the National Science Foundation. Federal Scientists Crying Foul Over DATA Act’s Conference Restrictions The DATA Act contains provisions that would increase transparency for federal employees participating in conferences.  One organization representing scientists at federal agencies has written to the Senate sponsors of the bill to express concerns regarding the proposed requirements.  The bill would require federal employees to publish information about conference activities and presentations. Researchers are concerned this could hamper their ability to actively participate in conferences. Federal News Radio has additional...

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This Week in Grants News

Posted by on Jan 14, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. OMB Official Discusses the Supercircular Norman Dong, the Deputy Controller at the Office of Management and Budget, gave an interview to Federal News Radio on January 9th about the Supercircular. Listen to the interview here. Deal Struck on Final Appropriations Bill Congressional negotiators announced Monday night that they have reached an agreement for spending allocations for the remainder of Fiscal Year 2014. The $1.012 trillion omnibus spending bill outlines spending for each government agency and program. Congress is expected to approve the bill by the end of the week. Read National Journal for more information. The Winners and Losers of the New Spending Bill The Washington Post identifies the winners and losers in the omnibus spending bill. Hoyer Expects, But Can’t Promise, No Federal Employee Furloughs in 2014 The House Minority Whip, Congressman Steny Hoyer (D-MD), expects the federal budget agreement will protect federal employees from additional furloughs this year. Read Congressman Hoyer’s comments here. Congress Sheds Light on Government Waste Senators Carper and Coburn testified before the House Oversight Committee about proposals to reduce government waste, including the DATA Act. The Washington Post has more information from the hearing.    FY2013 By the Numbers: Research Applications, Funding, and Awards The NIH released statistics for FY 2013, which show a decrease in the number of...

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This Week in Grants News: Meet OMB’s Supercircular

Posted by on Jan 7, 2014 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. OMB Releases the Supercircular On December 26th, the Office of Management and Budget (OMB) published the final rule for the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, known affectionately in the grants community as the “Supercircular.” The Supercircular will consolidate eight grants-related circulars into one uniform set of regulations for all grant recipient entities. OMB designed the Supercircular to reduce the administrative burden on recipients, improve transparency of the federal awards process, and protect federal funds from waste, fraud, and abuse. The Supercircular contains more than 60 policy changes for grant recipients, awarding agencies, and auditors. These changes include: Raising the Single Audit threshold to $750,000; Standardizing the simple acquisition threshold to $150,000; Requiring recipients to notify awarding agencies of potential conflict of interest in the administration of grant awards; Revising , adding, and eliminating  selected  items of cost; Providing new recipients the opportunity to indefinitely elect a de minimis indirect cost rate of 10%  of Modified Total Direct Costs; and Allowing recipients to apply for a one-time extension of a negotiated indirect cost rate for up to four years. In February 2013, OMB released a draft guidance of the Supercircular that contained a substantial change to audit requirements. OMB had proposed to streamline the Single Audit process by eliminating seven compliance requirements from the A-133 Compliance Supplement. The final Supercircular, however, retains all fourteen compliance requirements. The Supercircular provisions will become applicable to federal awards on December 26, 2014. The audit requirements will apply to all audits of fiscal years beginning on or after December 26, 2014. The full text of the Supercircular can be found here. Management Concepts grant training courses will provide you with the latest information on the Supercircular to help your entity prepare for the upcoming changes. Additionally, our Federal Grants Update 2014 course will focus primarily on how the Supercircular will affect the grants community. More information about the Federal Grants Update 2014 course can be found here. 2013 Single Audit Deadline Extended (Again) OMB has extended the 2013 Single Audit submission deadline to February 28, 2014. The deadline extension is due to the prolonged approval process for the SF-SAC 2013 Data Collection Form. For more information, visit the Federal Audit Clearinghouse. Lawmakers Put Finishing Touches on Spending Bill Last month, Congress approved a two-year budget agreement. Since then, members of the House and Senate Appropriations Committees have been negotiating on how to allocate more than $1 trillion to specific government agencies and programs. Leading members of the Appropriations Committees expect to release a final bill by the end of this week, with Congressional approval anticipated before January 15th. Federal News Radio provides additional information about the appropriations process. National Journal also provides a “Budgeting 101” resource that explains the federal budgeting process. Social Security Death Data: Additional Action Needed to Address Data Errors and Federal Agency Access The GAO released a report that examined the accuracy of the Social Security Death File and the accessibility of this file for other agencies. The Death File is an important tool used by the federal government to reduce improper payments. Legislation has been introduced in both chambers of...

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Play Dumb to Get What You Want: The Question Tactic in Negotiation

Posted by on Dec 27, 2013 in Acquisition, Financial Management, Grants & Assistance, Human Resources, Leadership, Project Management | 0 comments

Negotiation skills aren’t just for entrepreneurs on Shark Tank. Federal managers can also benefit from mastering these valuable skills. In The Government Manager’s Guide to Contract Negotiation, LeGette McIntyre offers some very specific tactics that could help any fed facing a tough negotiation. Here’s a great example from the book that McIntyre calls “The Question Tactic.” Try this in your next meeting and let us know your results. THE QUESTION TACTIC In any negotiation, knowledge is power. You increase your power relative to the other side as you increase your knowledge about it. Use questions to probe for answers that will increase your information about the other side. Dig for more information about its position, interests, needs, hidden agendas, and so forth. In a negotiation, acting dumb is smart! When you ask questions, you tap into the tendency for people to want to help out folks they regard as less informed or less intelligent than they are. It makes them feel important. So ask questions that make the other side feel superior, such as, “I’m not sure I fully grasp all the intricacies in your proposal. Would you mind explaining them to me again?” Or, “I know the dollars you are proposing are backed up with sound facts, but for some reason I’m just not getting it. Can you explain to me how you came up with these figures?” Notice that you are asking for help in both these examples. Get in the habit of asking that all-important question, “Can you help me…?” That’s almost guaranteed to trigger the human need for the other side to feel smart and superior, and the negotiators will give you information they otherwise wouldn’t have. You also should use questions to test the credibility of the “facts” the other side is asserting. Get good at asking open-ended questions that start with “how,” what,” “what else,” “which,” and “why.” Some examples: “How did you come up with those figures?” They now have to defend their position with additional facts, and remember, any additional information shifts power. “What would you do if you were in my shoes and someone gave you that choice?” This has the added benefit of bringing them around to your side, even if it’s just a little bit. “What is really important to you?” Always follow up with “what else is important?” If they see you as caring for their position, they are likely to be more open sharing information with you. Then, ask them “which of these things is more important to you?” This gives you insight into their “must” and “give” positions. Test their credibility by asking “why do you think that position is fair?” That puts them on the defensive to justify their position. Notice that all these questions are open-ended and can’t be answered by a simple “yes” or “no” or with some finite fact. They require elaboration, which will give you more information. Closed-ended questions run the risk of eliciting a simple answer and nothing more. For example, if you ask, “Don’t you think your price is a little too high?” they may answer with a simple “no.” That doesn’t give you much information. If you ask “when will you be able to deliver?” they can answer with one date. Again, you aren’t gaining useful information....

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OMB Announces the Supercircular Release

Posted by on Dec 19, 2013 in Grants & Assistance, Uncategorized | 1 comment

OMB will be releasing the Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards, also known as the “Supercircular,” TODAY for public inspection. OMB will be posting the Guidance on the Federal Register’s Public Inspection webpage. OMB will publish the final rule in the Federal Register on December 26th.  The Guidance is a culmination of years of collaboration between federal agencies, recipients, and other stakeholders in the grants community. The Guidance will streamline grants administration by creating uniform regulations for cost principles, administrative requirements, and audit requirements by consolidating eight OMB circulars into one; hence the nickname “The Supercircular.”  Management Concepts Federal Grants Update 2014 course will focus on how the Supercircular affects the entire grants lifecycle for awarding agencies, recipients, pass-through entities, and auditors. Visit the Federal Grants Update 2014 for more information.  Stay up-to-date on the latest news by tracking the Management Concepts Grants Blog and following Management Concepts on Twitter (#MCGrants or...

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This Week in Grants News

Posted by on Dec 17, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. Is the Supercircular Coming This Week? With only two weeks left in 2013, the grants community is waiting to see if the Office of Management and Budget (OMB) meets its self-imposed deadline of releasing the final Supercircular by December 31st. At the annual GPA conference in November, an OMB official announced that the government shutdown has slowed the approval process, and if OMB does not publish the Supercircular by Christmas, then OMB will issue the Supercircular sometime following the president’s State of the Union address. The president’s speech is scheduled for January 28, 2014. The Supercircular may be just hours away…or perhaps weeks. Stay tuned to Management Concepts’ Grants Blog for the latest information. Senate Poised to Approve Budget The Senate is expected to approve the bipartisan budget agreement on Wednesday. The agreement sets spending and revenue levels for FY 2014 and FY 2015. The Hill provides additional information about the debate in the Senate. With Budget Agreement Nearly a Done Deal, Focus Turns to Appropriations The budget agreement only sets the spending ceiling for the federal government. Following the expected adoption of the agreement, the Appropriations Committee in each chamber will determine the exact spending for every government program. Federal News Radio looks at how this process will unfold in the next few weeks. Budget Deal May Restore Federal Grants The Yale Daily News reports on how the budget agreement may benefit universities by increasing funding to research grants. Fischer Introduces GONE Act to Eliminate Government Spending on Nothing Senator Deb Fischer (R-NE) introduced legislation this week to require federal agencies to close expired grant accounts that have a zero balance. The GAO issued a report in April 2012 that found that it costs taxpayers approximately $173,000 a month to maintain more than 28,000 expired grant accounts with zero-dollar balances. Read more about Senator Fischer’s legislation...

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This Week in Grants News

Posted by on Dec 11, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. Budget Agreement Reached Senator Patty Murray and Congressman Paul Ryan, the co-chairs of the Congressional budget conference committee, announced a two-year budget agreement. The agreement is designed to prevent another government shutdown. The agreement provides “sequester relief” by increasing domestic spending by $22 billion for FY 2014 and by an additional $9 billion in FY 2015. Politico provides additional information about the budget agreement.    Treasury Moves on Data Transparency (With or Without DATA Act) The DATA Transparency Coalition hosted a policy briefing on December 5th that featured speakers from the Recovery Board and the Department of the Treasury. The event focused on the DATA Act and how the legislation, if enacted, would affect government operations, including grants reporting. Officials from the Treasury announced, regardless of Congressional action, that they will begin to standardize data elements in the near future. Additional information can be found here. Federal Audit Clearinghouse Website Redesign The Federal Audit Clearinghouse has redesigned its homepage to enhance the user’s experience. The content and functions of the webpage remain the same. In a related note, the website has an announcement explaining that the SF-SAC Data Collection form has not been approved, and Single Audits for 2013 will be due on January 31, 2014. Visit the Federal Audit Clearinghouse here. Open Data Round Up The Office of Management and Budget (OMB) blogged about how agencies are implementing the administration’s Open Data Policy. The Open Data Policy is designed to increase government transparency and accountability by increasing the accessibility of government data. Read the OMB’s blog here. Will the National Action Plan Tackle Spending Transparency Gaps? The Center for Effective Government analyzed the Open Government National Act Plan. The analysis was critical of the Census Bureau’s decision to eliminate the Consolidated Federal Funds Report (CFFR). The CFFR provided an in-depth look at government spending that went beyond the information at USASpending.gov. Read the analysis here. County Prepares for the Next Federal Shutdown Salt Lake County is taking steps to prepare for a future government shutdown. The county currently does not have a policy that allows for temporary furloughs of employees funded solely by federal grants, which, in a prolonged shutdown, would force the county to terminate employees....

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This Week in Grants News

Posted by on Nov 26, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. The High Cost of Gobbledygook The Center of Plain Language released a report card grading agency compliance with the Plain Writing Act. This legislation requires agencies to use concise and simply language when drafting public communications. Read the report card here. House Members Introduced the Improper Payments Agency Cooperation Enhancement Act A bipartisan group of House members introduced companion legislation to a Senate bill that would improve agency access to certain databases. The bill is designed to reduce improper payments by ensuring all agencies have access to the Death Master File.  Read the press release here.   Federal Government Budget Problems Make State  Budgeting Impossible State budget officials have expressed concern that the ongoing budget stalemate in Congress is making their jobs very difficult. Read the article here. Test Drive SciENcv NIH provided an update about the SciENcv initiative that will allow researchers to easily upload biographic information into grant applications. Read the NIH blog post...

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“This Week in Grants News” – House Passes DATA Act, Considers FIRST Act

Posted by on Nov 19, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. House Passes the DATA Act The House of Representatives approved the DATA Act on November 18 by a 388-1 vote. The House’s actions followed the release of the Congressional Budget Office’s (CBO) score for the bill. The CBO estimates the DATA Act will cost $395 million over the first five years. The Senate is expected to vote on the bill in the coming months. The House and Senate differ on the role of the Recovery Board in implementing the legislation and the two chambers will need to reconcile their differences after the Senate acts. The Digital Transparency Coalition provides additional information about the DATA Act. House Bill Calls for Science Research “In the National Interest” The House Science Committee released a draft bill that proposes to alter how the National Science Foundation (NSF) awards grants. The Frontiers in Innovation, Research, Science and Technology (FIRST) Act would require the agency to prioritize projects that serve the national interest by addressing one of six identified priority research areas. The legislation would also require the NSF to publicly justify their award decisions.  A subcommittee hearing on October 13th heard testimony regarding the draft bill. Additional information about the FIRST Act can be found on the Science Committee’s website. A Hundred Ways to Cut the Deficit The CBO released a report last week that provided Congress with 103 options to reduce the federal deficit.  The report identified a number of programs that could be eliminated or consolidated, including a number of grant programs such as the Community Development Block Grant and the Airport Improvement Program.  It is unlikely Congress will act on the recommendations. The CBO report can be found here. Special Designation Could Help Region Win Federal Grants The Department of Housing and Urban Development announced a competition for communities to be designated as Promise Zones. The initiative is designed to assist economically disadvantaged communities obtain federal resources to combat poverty. To assist communities, grant applications from Promise Zone communities would automatically receive a competitive advantage for federal grants. The Ogemaw County Herald examines how six counties in Michigan are collaborating on the Promise Zone application.   New Grant Competitions The following grant programs opened in the last week. For additional information about these and other grant programs, visit Grants.gov. NSF, Innovative Technology Experiences for Students and Teachers (47.076) – Close Date: February 11, 2014 HRSA, Rural Health Network Development Planning Program (93.912) – Close Date: January 14, 2014 IMLS, Sparks! Ignition Grants for Libraries (45.312) – Close Date: February 3, 2014...

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The Super Circular is Coming in December…or Next Spring

Posted by on Nov 18, 2013 in Grants & Assistance | 0 comments

Speaking at the annual Grants Professional Association (GPA) conference in Baltimore last Friday, Gil Tran, an official at the Office of Management and Budget (OMB), told a workshop that OMB is in the process of finalizing the “Super Circular.” Tran told the attendees that OMB is still hoping to release the Super Circular by the end of this year, but that the government shutdown has complicated matters. “If it is not out by Christmas, then we will release it sometime after the State of the Union next year,” Tran said. Tran indicated that the release may be as late as early spring. President Obama is currently scheduled to give the State of the Union Address on January 21, 2014, so a February 2014 release may be the most realistic timeframe. The Super Circular is a proposal by OMB to consolidate eight grants-related circulars into a uniform regulation applicable to all grant recipients.  In February 2013, OMB published a draft of the Super Circular in the Federal Register. OMB received more than 300 comments from the grants community regarding the proposed changes. During his presentation, Tran highlighted some of the proposed changes to grants management and explained how each change would affect recipients. GPA conference attendees expressed most interest about the proposed 10% minimum indirect cost rate for new recipients One participant asked Tran when the Super Circular’s provisions would be implemented. Tran stated that OMB anticipates that Super Circular will apply to all grants beginning in Fiscal Year 2015, which starts on October 1, 2014. Stay informed of all Super Circular developments by following Management Concepts on Twitter at...

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This Week in Grants News

Posted by on Nov 12, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. Senate Panel Approves DATA Act The Senate Homeland Security and Government Affairs Committee approved an amended version of the Digital Accountability and Transparency (DATA) Act last week. The amendment removed a provision related to the Recovery Board’s role in implementing the legislation, deleted a section regarding improper payment review, and extended deadlines for agencies to implement the legislation. Both the House and Senate are expected to consider the legislation next year. Nextgov summarizes the committee’s actions. Feasibility of DATA Act Question Even as Senate Committee OKs It Some agency leaders have questioned the feasibility of the DATA Act and have expressed doubts about their agency’s ability to meet the bill’s requirements.  Federal News Radio examined the problems facing some agencies. Impacts and Cost of the Government Shutdown OMB released a report detailing the effects of the shutdown on government operations.  The report includes grants-related information. The report can be found on OMB’s blog. Single Audit Deadline Extended to January OMB has extended the deadline for submitting FY 2013 Single Audit packages until January 31, 2014. For more information, visit the Federal Audit Clearinghouse. Researchers Use Crowd-Funding for Projects As sequestration reduces the amount of funding for research grants, some scientists are turning to crowd-funding for small-dollar needs. Read More… New Grant Competitions The following grant programs opened in the last week. For additional information about these and other grant programs, visit Grants.gov. National Endowment for the Humanities,  Museums, Libraries, and Cultural Organizations – Close Date: January 8, 2014 Department of Transportation, Railroad Safety Technology Grants – Close Date: February 5, 2014 National Science Foundation, Improving Undergraduate STEM Education – Close Date: February 4, 2014 National Science Foundation, Robert Noyce Teacher Scholarship Program – Close Date: March 5,...

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Single Audit Deadline Extended to January

Posted by on Nov 6, 2013 in Grants & Assistance | 0 comments

The Office of Management and Budget (OMB) announced an extension for recipients to submit their single audit reporting packages.  The approval process for the SF-SAC 2013 Data Collection form has been significantly delayed, and therefore OMB extended the reporting deadline. The new deadline for submitting the required materials to the Federal Audit Clearinghouse is January 31, 2014. This extension applies only to single audits for the fiscal year ending in 2013. The SF-SAC is the standard data collection form used for Single Audit Act audits. In May, OMB published a notice in the Federal Register soliciting public comments for proposed changes to the form. The form will be automatically approved 30 days following the final publication in the Federal Register. OMB has not indicated when it will be published. For additional information, visit the Federal Audit...

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This Week in Grants News…

Posted by on Nov 5, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week.  Senate Committee to Consider the DATA Act The Senate Homeland Security and Government Affairs Committee will markup the DATA Act tomorrow. Senators are expected to consider an amendment that would alter some of the bill’s provisions. Management Concepts’ Grant Blog will provide additional information after tomorrow’s committee meeting.  Yesterday, the Federal News Network wrote an article about the proposed amendment. House Committee Approves the GRANT Act The House Government Affairs and Oversight Committee approved the GRANT Act last week on a 19-15 party-line vote. The bill’s author, Congressman James Lankford (R-OK), talked to Science magazine about the implications of his bill. Agencies Can’t Always Tell Who’s Dead and Who’s Not Agencies are required to check the Do Not Pay List before authorizing funding to recipient organizations and individuals. The Do Not Pay List is a platform that integrates multiple government databases. One database that the Do Not Pay List uses to verify recipient eligibility is the Death Master File, which contains death records of over 85 million Americans. Even with access to the Death Master File, the federal government continues to pay hundreds of millions of dollars in benefits to deceased individuals. The Washington Post examines why this occurs. NSF Announces 2014 Political Science Program Competition On November 1st, the National Science Foundation released a “Dear College Letter” announcing a January 15th deadline for the agency’s Political Science Program competition. For additional information about the program, read the letter. Chicago Loses $9 Million Because of Sequestration Chicago officials are estimating sequestration will reduce federal grant funding to the city by $9 million this year. The Chicago Tribune examines the impact to the...

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House Committee Approves GRANT Act

Posted by on Nov 1, 2013 in Grants & Assistance | 0 comments

The House Oversight and Government Reform Committee approved the Grant Reform and New Transparency (GRANT) Act, HR 3316, on Tuesday, October 29. The committee approved the bill on a party-line vote of 19-15. Before the vote, both sides acknowledged the need to refine the bill before the House of Representatives might consider the legislation. The bill, introduced by Representative James Lankford (R-OK), would require greater transparency of the grants award process. Agencies would be required to publish the names and employers of peer reviewers, clearly identify award selection criteria, and make funding decisions based solely on merit. Unsuccessful applicants would have access to documents outlining the decision-making process. The legislation also mandates that agencies publish the grant applications, grant agreements, and closeout documents for all awards. The chairman of the committee, Darrell Issa (R-CA), called the GRANT Act a “hallmark piece of legislation.”  Chairman Issa said there is a clear need for the legislation and that “identifying and reducing vulnerabilities in the awarding and administration of grant programs is critical to ensure that our government is being responsible as possible to the taxpayers.” Democrats on the committee expressed reservations regarding two key provisions of the bill. The Committee’s Ranking Member, Elijah Cummings (D-MD), had concerns about the disclosure requirement of peer reviewers. Cummings urged the committee to protect the anonymity of the peer reviewers to prevent lobbying from applicants and potential employer reprisals. Wisconsin Democratic Congressman Mark Pocan offered an amendment to allow agencies to use a unique identifier for each peer reviewer. The purpose of the amendment was to increase transparency of the peer review process, while protecting the privacy of individual reviewers. Lankford expressed some support for the amendment, but was adamant that the identities of the final decision-makers be publicly available. Pocan withdrew his amendment and told the committee that he would work with Lankford to find a solution. Congressman Gerry Connolly (D-VA) offered an amendment to require the publishing of only the grant abstract instead of the grant application. Connolly explained his amendment was on behalf of the academic community‘s concerns of “potential, inadvertent harm the GRANT Act could inflict on research and innovation systems.” According to Connolly, the publication of grant applications could result in the release of protected intellectual property. The committee rejected the Connolly amendment on a 15-19 party-line vote. Connolly expressed his willingness to seek a bipartisan compromise to allow universities the ability to redact sensitive information. On a voice vote, the committee approved an amendment from Representative Jackie Spier (D-CA). The GRANT Act would require agencies to conduct a pre-award review of the financial capabilities of applicants. Spier’s amendment modified the provision’s exemption requirements. Under the approved amendment, recipients that received more than $10 million in grant funding, and had successfully completed a grant project in the previous three years, would be exempt from the financial capabilities review process.   The House Oversight committee previously approved the GRANT Act during the 112th Congress; however, the bill was never considered by the House of Representatives. It is not clear if the bill will fare any better during the 113th Congress.  Even if the House considered the bill, opposition from Democrats and the academic community would probably doom the bill in the...

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This Week in Grants News

Posted by on Oct 30, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week.  Grant Reform and New Transparency Act of 2013 Congressman Lankford reintroduced the GRANT Act last week. The bills seeks to improve the transparency of the federal grants award process by requiring agencies to publish all grant agreements and closeout reports. For more information about the bill, read Management Concepts’ blog post. NIH Resumes Grant Programs The National Institutes of Health published guidance to grant recipients on the agency’s plans to resume normal operations following the government shutdown. Many grant deadlines have been extended into November. Read the guidance here. How Have Washington’s Budget Battle Affected Ed Tech Grants? This article looks at the status of Education technology grants following the shutdown. Read more about the Department of Education’s grant programs here. Grants Drying Up to Outfit Sheriff’s Cruisers Law enforcement agencies are finding grants increasingly difficult to obtain as the amount of funding continues to decline. One sheriff’s in Ohio stated, “The government is denying more of my requests now.” Read the article...

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GRANT Act Introduced in House

Posted by on Oct 28, 2013 in Grants & Assistance | 0 comments

Congressman James Lankford (R-OK) introduced the GRANT Act, HR 3316, on October 23rd. The legislation is designed to increase the transparency of the grant award process. The legislation was previously introduced in the 112th Congress, but neither chamber voted on the bill.  The legislation would increase the public’s access to the information regarding the awards process. Agencies would be required to announce all potential grant competitions for the upcoming year on their website.  The bill would also codify required elements for the Notice of Funding Opportunity. Currently the required elements are contained in OMB circulars.  There are some controversial aspects to the legislation that concerns stakeholders in the grants community. The legislation would require agencies to publish on their websites the rankings of successful applicants as well as a copy of the grant agreement. Unsuccessful grant applicants would have the opportunity to request documentation relating to the award decision process and to seek clarification on why a project was not funded. Agencies would also be required to post closeout reports for each grant project. Some stakeholders believe these requirements could potentially infringe on recipients’ privacy relating to research projects, patents, and business practices.  The GRANT Act also contains provisions to mandate merit-based award selection and to require agencies to conduct financial capability evaluations of potential recipients.  These requirements are similar to provisions contained in the Office of Management and Budget’s proposed “Super Circular.”  The legislation is assigned to the House Government Oversight and Reform Committee. The committee’s chairman, Congressman Darrell Issa (R-CA), is a co-sponsor of the legislation and therefore it is likely the committee will consider and approve the legislation. There is no current indication the House will consider the legislation anytime soon.  Additional information regarding the legislation can be found...

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Grants Management Contingency Plans During a Government Shutdown

Posted by on Sep 30, 2013 in Grants & Assistance | 0 comments

Unless Congress acts by midnight, the federal government will shut down. In preparation for a potential shutdown, OMB required all agencies to develop and publish contingency plans.  Each agency’s contingency plan can be found here.  A government shutdown will affect grant recipients. While work on most grant programs may continue, agency staff will be unavailable to provide oversight, technical assistance, or prior approval to recipients. Most recipients will also be able to draw down funds, but payment processing will be halted.  “High risk” recipients may be prevented from drawing down funds.  While no new grant awards will be made during a government shutdown, Grants.gov will continue normal operations.  Application deadlines will most likely be unaffected by a shutdown, but applicants should double-check funding announcements to determine any changes to close dates. Applications submitted through Grants.gov during a shutdown will be processed and stored until agency officials return to work. Listed below is information from agency contingency plans as it pertains to grants management. Recipients should contact their awarding agencies as soon as possible to address specific problems before a government shutdown occurs.  U.S. Department of Agriculture Foreign Agricultural Service: Most FAS assistance will continue to operate under normal circumstances. Rural Development: No new grant awards will be made. U.S. Department of Education Formula funding under Titles I and II will continue as normal. U.S. Department of Health and Human Services No awards will be made. Most agencies will not be able to monitor grants. Payments for some grant programs will be suspended. U.S. Department of Homeland Security Oversight, accounting, administration, payment processing, and other grant management activities will not continue. Performance on grant projects may continue, but recipients should be aware that program assistance will not be available. U.S. Department of Housing and Urban Development Staff will monitor payment system to ensure recipients can draw down funds. Recipients will not be able to receive additional CDBG funds. The Homeless Assistance Program will continue to operate as normal. U.S. Department of the Interior Mandatory grants under the Office of Insular Affairs will continue. U.S. Department of Justice OJP, COPS, and the Office of Violence Against Women are funded from no-year funds, and operations will continue as normal. U.S. Department of State No new awards will be made. U.S. Department of Transportation No new grants will be made. Some grant programs will be suspended during a shutdown. Corporation for National and Community Service “For the most part, previously awarded grants and cooperative agreements will not be affected.” Recipients should be able to draw down funds from the Payment Management System. There will be no CNCS oversight or assistance provided to recipients. No new grants will be awarded. Denali Commission No new grants or cooperative agreements will be awarded. Environmental Protection Agency Grant projects can continue to operate. EPA staff will not be available to make payments until a shutdown ends. Most recipients should be able to draw down funds. Recipients must stop work on grants if they require EPA involvement or prior approval. Recipients should document allowable costs related to a work stoppage. Institute of Museum and Library Services No new grants will be awarded. Applications will not be accepted. Payments will not be processed. Previously scheduled grant review panels may only meet for the first day of a shutdown.  National...

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This Week in Grants News

Posted by on Sep 27, 2013 in Grants & Assistance | 2 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week Senate Poised to Vote on Spending Measure The Senate is expected to vote on, and pass, a bill that will provide temporary funding to keep the government open. After the Senate approves the bill, it will be returned to the House of Representatives for consideration. The House leadership has not yet indicated how they will respond. The federal government will shut down if funding is not approved by October 1st. Read about the latest developments here. Wondering About a Government Shutdown? The Washington Post answers the frequently asked questions about a government shutdown. A government shutdown will affect grant recipients. During a shutdown, federal funding for most grant projects will cease and most agency grant officers will not be available to address questions or concerns. Find out more here. Grants.gov Should Remain Operational During a Government Shutdown The Grants.gov Program Management Office expects the website to remain operational if the government shuts down next Tuesday. The Contact Center should also continue to provide assistance.  Most agencies have not announced how application deadlines would be affected by a government shutdown, but applicants should be prepared to submit all applications by the announced deadlines. Additional information about Grants.gov can be found here. States Fear Big Losses if Government Shuts Down Governors across the nation are issuing orders to state agencies to prepare for a possible federal government shutdown. In Virginia, the governor’s office urged agencies to avoid all expenses related to federally funded grant projects during a shutdown. Read the article here. State Reliance on Federal Dollars Near All-Time High A recent study found that the federal government provided $675 billion in federal grants to states in 2010. On average, federal grants account for 1/3rd of state budgets. Federal grant funding, as a percentage of a state’s budget, ranged from a low of 24% in Alaska to a high of 49% in Mississippi. Read more about the study here. GAO: COPS Grant Application and Monitoring Processes Could Further Ensure Grantees Advance Community Policing The Community Oriented Policing Services (COPS) program is a federal grant designed to assist law enforcement agencies in hiring police officers. Officers hired under the grant must be engaged in community policing activities. The GAO examined the COPS program and found that grant funding is not always being used for community policing. To rectify this problem, GAO recommended the COPS Office revise the program’s application and improve monitoring of grant recipients. Read GAO’s report here. To get the latest grant news, follow Management Concepts at Twitter @Mgmt_Concepts or use...

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This Week in Grants News

Posted by on Sep 20, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. OMB Issues Shutdown Guidance to Agencies On Wednesday, OMB released a memo explaining how federal government agencies should prepare for a potential government shutdown. The memo also provided a Q&A section detailing how grants administration would be affected by a shutdown. Read OMB’s memo here. 5 Reasons Why a Government Shutdown is (Likely) Coming Chris Cillizza of The Washington Post examined the current budget stalemate and identified five compelling reasons why a shutdown seems, to him, likely. Read his five reasons here. Government Shutdown Becoming Less Likely As a counterpoint to the previous article, this author takes the position that a government shutdown is becoming less likely. Draw your own conclusions! Read the article here. How to Explain the Continuing Resolution to Your Friends Confused about why the government might shutdown? This is a great infographic that can help any football lover better understand the political maneuverings happening in the Capitol. Confused about football? This will not help you then. See the inforgraphic here. Everyone Agrees it Should be Easier to Say How Much the Government Spends Officials from GAO testified before a Senate Budget Committee task force Wednesday to explain the difficulties in determining how much, and where, the federal government spends funds. The hearing was designed to promote the Digital Accountability and Transparency Act (DATA Act). The Senate Homeland Security and Government Affairs Committee is expected to approve the DATA Act in October and the House should consider the legislation in the coming months. Read about the hearing here or watch the hearing here. Stimulus Tracking Site is Rebooted to Monitor Hurricane Sandy Spending The Recovery Accountability and Transparency Board, the agency charged with overseeing Recovery Act funds, is often cited as a successful model on how government agencies can better promote transparency and prevent fraud, waste, and abuse of federal funds. The board’s mandate was set to expire at the end of the month, but Congress extended its mission to include monitoring the spending associated with the recovery from Hurricane Sandy. Read more about the board’s new responsibilities here....

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Preparing for a Potential Government Shutdown

Posted by on Sep 18, 2013 in Grants & Assistance | 0 comments

OMB released memorandum yesterday, “M-13-22, Planning for Agency Operations During a Potential Lapse in Appropriations,” which provides agencies guidance on how to prepare for a potential government shutdown. The memo also provides a useful Q&A section detailing how agencies must manage and administer grants during a shutdown. The memo can be accessed here.  Important guidelines for federal grants officials during a government shutdown include the following: Awarding agencies cannot issue new awards; Federal employees cannot, except in limited cases, provide technical assistance to recipients; and Agencies must cease oversight, inspection, monitoring, closeout, and payment processing. Performance and work on grant projects may continue during a government shutdown. The federal fiscal year ends on September 30th. For normal government operations to continue, appropriations of funding for each federal agency must be approved by that date. On October 1st, any agency that lacks funding must shut down. There are limited exceptions provided for national security and essential government functions. Congress has not approved any of the 12 appropriations bills for Fiscal Year 2014 as this deadline approaches. To avert a shutdown, Congress may pass legislation called a continuing resolution (CR) to temporarily fund government agencies until the appropriations bills are adopted. To track the status of the appropriations bills, click here. Political and ideological differences between the House and Senate are complicating efforts to pass a CR. In response to the political gridlock, OMB released the memo yesterday to assist agencies in planning for a potential shutdown.   Grant recipients should also be making preparations for a potential shutdown. Steps recipients can take include: Contact agency officials now to assess the consequences of a potential shutdown; Make necessary programmatic and administrative plans; and Take into account the expected delays in receiving funds for the new fiscal year. A government shutdown is the worst-case-scenario and political analysts are divided on whether a shutdown will actually occur. In previous budget battles, House and Senate leaders often find a compromise solution at the last...

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This Week in Grants News

Posted by on Sep 14, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important federal grants-related news from the week. Congress To-Do List Crowded With Budget Headaches Congress returned to work this week after its five-week summer break and faced multiple budget-related issues that need immediate attention. The end of the fiscal year is September 30th and a continuing resolution must be in place to  avoid a government shutdown. Congress must also pass an increase to the debt ceiling or face a potential default. The Treasury is expected to reach the statutory debt ceiling by the end of October. Congress adjourned on Thursday without voting on either issue. Read more here… Push for More Federal Data Transparency Gaining Momentum on Capitol Hill The Digital Accountability and Transparency (DATA) Act continues to gain support as the House of Representatives is expected to vote on the legislation in the coming weeks. Additionally, the Senate Homeland Security and Government Affairs Committee is tentatively scheduled to consider the bill in October. Read more here… Lawmakers Offer Appropriations Directions, But Don’t Call Them Earmarks Both houses of Congress have banned the use of earmarks, however, Rollcall found a number of appropriators are using their influence to direct agencies to fund specific pet programs. Read the article here… GAO Released Two Reports on Grants Related Issues The Government Accountability Office (GAO) issued two reports this week that may interest the grants community. The first report focused on federal data transparency and summarized recent actions by OMB, the GATB, and Recovery Board to improve transparency of government spending. In a move likely to increase the likelihood of the DATA Act’s passage, GAO recommended Congressional action on the issue. A second report examineed agency compliance with the Freedom of Information Act (FOIA). The report called on the Office of Government Information Services to develop and implement a time frame to review agency compliance with FOIA requirements. Read the report on data transparency here and the report on FOIA compliance here. Tennessee Loses Out on Federal Funds Over Weak Texting Laws Eligibility requirements for federal grants can sometimes be difficult to meet, as the state of Tennessee recently discovered. The state did not qualify for two federal grants designed to combat distracted driving because a state law prohibiting texting while driving was not stringent enough. Find out more here…...

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This Week in Grants News

Posted by on Sep 6, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week.  Appeals Court Delays HUD Grant Reallocation A U.S. District Court has delayed HUD’s request to reallocate $7.4 million in funding from Westchester County, New York. Agency officials determined that communities in the county had “exclusionary zones” that were in violation of regulations. HUD had planned on reallocating the funding to other recipients before the end of this fiscal year, September 30th. The Court upheld the county’s request to block the agency’s actions until another hearing can be held on September 10th. Read more here… Backup Funding Required for Some Grant Applicants Like many states, Illinois is facing severe budget constraints and cash shortfalls. As a result, state agencies are forced to delay disbursing grant awards for months. A consequence of this is that recipients must perform project activities without adequate funding. Read more here… Three Out of Four HUD Findings Against N.M. Department Dismissed In May, HUD officials expressed concerns about the New Mexico Department of Finance’s management of CDBG awards and threatened to terminate $280,000 in funding. Last week, HUD reversed course and dismissed three of the four findings against the state and will continue funding. Read more here… New Grant Competitions The following grant programs were announced this week. For additional information about these programs, visit Grants.gov. National Science Foundation Small Business Technology Transfer Program – Close Date: December 4 AmeriCorps State and National Grant Competition – Close Date: January 8,...

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This Week in Grants News

Posted by on Aug 30, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Sequestration Update Report OMB released a report updating the president and Congress on the sequester.  The report analyzed the FY 14 spending levels in the pending appropriations bills and informed policymakers that significant spending cuts will be necessary to meet the legal requirements in the American Taxpayer Relief Act of 2012.  Read the report here. Agencies’ FY15 Budget Planning ‘Tied Up in Knots’ By Uncertainty Agencies are preparing their FY 2015 budget requests  even though Congress has yet to pass any of the twelve appropriations bills for FY 2014, which starts October 1st.  It is a difficult process for many agencies, as they do not know their level of funding for next fiscal year or the fate of the sequester. Agency leaders do not seem to concerned however, as one former Bush Administration official stated, “agencies are used to this situation.” Read more… Deficit Talks Break Down, Focus Returns to House Treasury Secretary Jack Lew announced earlier this week that the nation will reach the debt limit in mid-October. Congress must pass legislation increasing this limit or else the nation faces a potential default. In preparation for this deadline, the White House has been in discussions with Senate Republicans to reach a compromise. Those negotiations, however, seem to have failed to reach an agreement. Read more… Quiz: Test Your Knowledge About the Debt Limit How much do you know about the debt limit? Take the quiz. Detroit Getting Review of Grant Administration The Ford Foundation announced it is providing $170,000 to Detroit to hire consultants to review the city’s administration of federally awarded grants. The emergency manager of the city recently commented that he believes all 71 grant programs fail to comply with federal regulations. Read more… Federal Grant Competition Close Dates The following grant programs have applications due within the next week. For additional information about these programs, or any other grant program, visit Grants.gov. FEMA SAFER Grant Program – Close date: August 30th Tribal Wildlife Grants FY2014 – Close date: September 3rd High Energy Cost Grant Program – Close date: September 3rd VetSuccess Americorps 2013 – Close date: September 4th...

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This Week in Grants News

Posted by on Aug 23, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. OMB Issues Memo to Protect Privacy Rights  The Office of Management and Budget released guidance detailing procedures on how federal agencies should safeguard and protect privacy rights when using the “Do Not Pay List.” The Do Not Pay List is a database that federal agencies are required to check before awarding funds to recipients. Read the memo here.  Grants Highlight Municipal Government Efficiency Thomas Piedrahita, an undergraduate student at the University of Pennsylvania, examines how New York City used the Internet to engage citizens in developing plans to spend CDBG funds.  Read the article here. States Brace for New Round of Sequester Cuts Grant funds constitute nearly 1/3rd of state budgets and additional sequestration cuts are forcing state leaders to prepare for the worst. Read more… ED OIG Audit: OESE Process of Awarding Discretionary Grants The Department of Education’s OIG audited the Office of Elementary and Secondary Education’s grants management system and found the office mostly complied with all regulations. Auditors, however, reminded program officials of their obligation to notify applicants if their application was ineligible for peer review. The audit report can be found here, and honestly, who wouldn’t want to spend a Friday afternoon reading an OIG report? To get the latest grant news, follow Management Concepts at Twit ter @Mgmt_Concepts or use #MCGrants....

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This Week in Grants News

Posted by on Aug 16, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Department of Education The Department published a final rule this week that increases the reliance of performance measures in grant applications, modifies award selection criteria, and provides for the limited use of subgrants. Find out more here. Fraud Warning The Federal Trade Commission issued a warning about a scam targeting furloughed federal employees. Federal employees have reported receiving phone calls offering “free federal grants.” The caller asks for a small fee or bank account information to guarantee the “grant” is approved. Read more… NSF Cancels Political Science Grants Following recent Congressional action, the NSF announced that it was canceling a round of grant funding for political science research. NSF anticipates resuming the grant competition next year after the Congressional mandate has expired. Read more… Budget Battles Heat Up in Congress A multitude of budget problems await Congress after members return from their five-week recess in September. Congress must pass the annual appropriations bills and  address the debt ceiling. Partisan battle lines are being drawn and the threat of a government shut-down is a growing concern. Read more… NIH Hosts Free Webinar for Multi-Project Applicants On August 13th, NIH conducted a free webinar to assist recipients in preparing and submitting multi-project applications. The webinar was conducted by two grant specialists with NIH. Watch the webinar here.   To get the latest grant news, follow Management Concepts at Twitter @Mgmt_Concepts or use...

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This Week in Grants News…

Posted by on Aug 2, 2013 in Grants & Assistance | 0 comments

“This Week in Grants News” is a resource Management Concepts provides to keep you informed of important grants-related news from the week. Grants.gov Debuts a Redesigned Site On August 2nd, the grants community awoke to find a brand new look for Grants.gov. The website redesign is meant to provide a more user-friendly interface to find grant opportunities. The function and content of the website remains the same. Take a look for yourself. SAM.gov Anticipates Delays The homepage of SAM.gov provides unexpected and unfortunate news. Users are warned that processing registrations through the website may take up to 10 days. Before an entity can submit a grant application through Grants.gov, they must be registered with SAM.gov. Be sure to plan ahead! Additional information can be found on the SAM.gov homepage. Is SAM.gov Prone to Technological Glitches? Senator Charles Schumer (D-NY) expressed his concerns to Secretary of Education Arne Duncan that a “technological glitch” with SAM.gov prevented his constituents from successfully submitting an application. He is demanding the department take action to rectify the problems.  Read More… University Settles Grant Fraud Case The Department of Justice announced a settlement in a False Claims Act case.  The university received funding from NIH for drug research. It was discovered a researcher involved with the project charged his personal travel and food to the grant award. The university will repay nearly $3 million. Read More… Senate Committee Approves Bill to Stop Payments to Dead People The Senate Homeland Security and Government Affairs Committee unanimously approved the Improper Payments Agency Cooperation Enhancement Act. This legislation would provide federal agencies access to the Social Security Administration’s Death Master File. The Government Accountability Office (GAO) recently found that the Department of Agriculture had made payments of more than $30 million to deceased recipients over a four year period. Read More… GAO Recommends Improved Training for Grants Officials In a report issued on July 29th, the GAO stressed the importance of a well-trained grants workforce for the federal government. The report recommended OMB and COFAR make a clear distinction between grants management specialists and program specialists when implementing competency plans for federal grant employees. Read More… Follow Management Concepts at Twitter @Mgmt_Concepts and get the latest grants news using #MCGrants.  ...

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Grants Legislation Update

Posted by on Aug 1, 2013 in Grants & Assistance | 0 comments

In the past few months, members of Congress have proposed numerous bills affecting federal grants management. Listed below is a summary of pending legislation concerning the grants community. H.R. 882 – Contracting and Tax Accountability Act of 2013:  This legislation would prohibit the awarding of grants and contracts to entities that are “seriously delinquent” in paying federal taxes. The House approved the bill on April 15, 2013. Additional information about the bill can be found at the following post: House Approves Bill to Prevent Delinquent Taxpayers from Receiving Grants and Contracts. H.R. 1162 – Government Accountability Office Improvement Act: This bill expands the authority of the Comptroller General to access federal records to conduct audits and investigations. Additionally the Comptroller General is authorized to administer oaths when investigating fraud or federal employee misconduct. The House of Representatives approved the bill on April 15, 2013 and the Senate Homeland Security and Government Affairs Committee approved the legislation yesterday, July 31st. H.R. 1211 – FOIA Act: This legislation would require all federal agencies to utilize FOIAonline.gov to process and publish FOIA requests and responses. Under current law, FOIAonline is voluntary and only six agencies, to varying degrees, participate. The House Oversight Committee approved the bill in March 2013 and it is anticipated the House of Representatives will consider the bill before the end of next year. H.R. 1856 – Closing Long-Empty Accounts Now (CLEAN) Act of 2013: This legislation is a response to the large number of grant accounts that remain open after the end of the project. Under the provisions of this bill, agencies would be required to close grant accounts that remain open 180 days after final reports have been received. This bill mirrors a provision in OMB’s proposed Uniform Guidance. That provision has received negative feedback from some program officials. This legislation, therefore, may be an attempt to pressure OMB to adopt the proposal. H.R. 2061 / S. 994 – The Digital Accountability and Transparency (DATA) Act of 2013: The DATA Act is designed to increase transparency of federal spending by requiring agencies to publish financial information for grant awards on USASpending.gov. The House Oversight and Government Reform Committee approved the legislation in May 2013. The Senate Homeland Security and Government Affairs was originally scheduled to consider the bill on July 31st, however, the bill was removed from the committee’s agenda. Additional information about the DATA Act can be found at the following post: The Data Act is Reintroduced. H.R. 2781 – Stop Paying Something for Nothing Act of 2013: This legislation is similar to the CLEAN Act, however, it would require agencies to close out grant accounts after 3 years upon receiving the final reports. S.1360 – Improper Payments Agency Cooperation Enhancement Act of 2013:  This legislation is designed to provide federal agencies greater access to the Death Master File to reduce improper payments to individuals that have died. The Senate Homeland Security and Government Affairs unanimously approved the bill on July 31st. The chairman of the committee, Senator Carper, is the author of the bill. S. 1366 – Verifying Agency Conduct and Needs Through (VACANT) Inspectors General Act: The VACANT Act was introduced last week to address congressional concerns relating to the prolonged vacancies in offices of Inspectors General. Currently there are seven Offices of Inspectors...

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How Congress Can Help You With Federal Grants

Posted by on Jul 26, 2013 in Grants & Assistance | 3 comments

Grant writers and applicants are familiar with most of the steps in the grant application process: locate a funding source, check the requirements of the grant, compile the necessary information for the application, complete and submit the application, and then cross your fingers and hope for the best. Applicants, however, frequently omit the important step of contacting their federal elected officials. Members of Congress and their staffs can provide valuable resources to assist grant applicants with each step of the application process. For four years I had the opportunity to serve as Grants Director for Oklahoma Congressman Brad Carson. When Congressman Carson was first elected, he realized his district ranked near the bottom of all congressional districts in the amount of competitive federal grant funding. He made it a priority to ensure his constituents “received their fair share.”  As the congressman’s Grants Director, it was my responsibility to provide our constituents with every available resource to help them with a successful grant application. During Congressman Carson’s four years in office, the amount of competitive grant funding to his district doubled. One reason for this success was due to his work on behalf of his constituents.  The congressman’s office conducted over 100 grant workshops to inform his constituents of funding opportunities and tips for successful grant writing, wrote thousands of letters of support for grant applications, and frequently met with program officials from federal and state awarding agencies. While most members of Congress do not have a staff member solely dedicated to assisting constituents with federal grants, congressional offices can still provide resources to grant applicants. You should always visit your elected officials’ webpages. The Congressional Research Service provides each member of Congress with a webpage template that provides links to federal and private grant-related websites. You can also contact a member’s office and ask to speak to a staff member that can provide assistance in locating funding sources, obtaining statistical information, or writing a letter of support for your application. When seeking a letter of support for your grant application, provide the congressional staff member with the following information: Name of organization seeking grant funding; Contact information for the applicant; Address of awarding agency and contact person at the agency; Name of the grant program and CFDA number; and Deadline for the letter. When constituents contacted Congressman Carson’s office seeking a letter of support, I would also ask them to provide a copy of the project’s narrative or a short description of the project that highlighted the purpose of the project, how the project would benefit the community, and how grant funds would be used.  This information allowed the Congressman to write a letter that addressed the specific needs of the applicant and how federal funding would benefit his constituents. It is always important to inform your congressional delegation when you submit an application.  Members of Congress and their staff can provide behind the scenes support once an application has been submitted. One of my responsibilities as Congressman Carson’s Grants Director was to maintain a database of our constituents’ grant applications.  Congressman Carson would frequently contact federal agencies to inform them of an application from his district and speak about the benefits of the proposed project. The Congressman once arranged a visit by an agency director to tour the...

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Staying Up To Date in Federal Grants Has Never Been More Convenient

Posted by on Jul 19, 2013 in Grants & Assistance | 0 comments

Management Concepts is excited to announce an online session of our popular Federal Grants Update 2013 course. This online session is ideal for grant professionals who want to learn about the latest developments in grants management from the comfort of their own home or office. Topics for the course include: OMB’s proposed “Super Circular” The latest statutory and regulatory changes to grants management Best practices to detect and prevent grants fraud How increased emphasis on grants closeout, performance measures,  and suspension and debarment polices are affecting grant professionals The effects of sequestration on grant awards The online format of the course will enable participants to engage in interactive activities, ask questions, and provide comments to the instructor. When: July 30-31, 2013 Time: 11:30-3:00 EST Where: Anywhere you have internet access For more information or to register, visit the Federal Grants Update (Online) course...

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Follow #MCGrants on Twitter!

Posted by on Jul 17, 2013 in Grants & Assistance | 0 comments

Management Concepts Grant Blog is now on Twitter! Follow us at @Mgmt_Concepts or use the hashtag #MCGrants to get the latest grant-related information, news, and resources all in 140 characters or...

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Agencies Required to Use Federal Award Identification Number (FAIN) for Grant Awards

Posted by on Jul 10, 2013 in Grants & Assistance | 1 comment

The Office of Management and Budget (OMB) recently outlined new initiatives designed to improve data quality and information of federal grant spending on USASpending.gov. In a June 2013 memorandum to the chief financial officers of federal agencies, OMB Deputy Controller Norman Dong directed agencies to 1) assign all federal financial awards with a unique identifying number and 2) validate funding information on USASpending.gov. USASpending.gov is designed to increase the transparency of federal spending by allowing the public to readily identify how their tax dollars are being spent. While USASpending.gov has expanded the availability of information related to government spending, there have been repeated calls from members of Congress and government watchdog associations to improve the quality of data on the website. Beginning in October 2013, federal agencies will be required to assign a Federal Award Identification Number (FAIN) to every grant and ensure the FAIN is used in all federal award documents. Additionally, grant award terms and conditions must specifically instruct pass-through entities to use the assigned FAIN on all subawards. The use of a FAIN is intended to enhance data quality on USASpending.gov by allowing the public to more easily track specific government awards and spending. The OMB memorandum also requires agencies to validate federal financial award data on USASpending.gov by November 15, 2014. OMB has provided agencies with flexibility in developing and implementing procedures to meet this requirement. In recent years, policy makers have emphasized enhancing transparency of federal financial awards. In May, the House Oversight and Government Reform Committee approved the Digital Accountability and Transparency Act (DATA) of 2013. The DATA Act would increase transparency and accountability of federal grants, contracts, and spending by standardizing reporting requirements. Pursuing a similar objective, the Government Reform and Transparency Board (GAT Board) has analyzed methods to improve transparency. One method would be the creation of a government-wide universal award ID (UAID) system that would assign a unique number to every federal award. The UAID system would be incorporated into the Treasury Department’s payment system. The OMB memo is available here:...

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2013 A-133 Compliance Supplement Released

Posted by on Jul 9, 2013 in Grants & Assistance | 0 comments

The Office of Management and Budget (OMB) has released the 2013 A-133 Compliance Supplement.  As usual, the document contains new programs and modifications to existing programs. There are also numerous revisions to the compliance requirements for programs funded through the Recovery Act. Perhaps the most significant change relates to the ongoing confusion regarding the simplified acquisition threshold.  The Supplement states that the $100,000 threshold remains the government-wide policy and auditors should continue to test for that threshold. The exception is when “an agency/program has issued guidance raising the threshold or the increased threshold is specified in the terms and conditions of the award.” The Compliance Supplement can be found at:...

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GAO Recommends COFAR Improves Planning and Communication

Posted by on Jun 27, 2013 in Grants & Assistance | 0 comments

The Government Accountability Office (GAO) released a report on June 24th critical of the Council of Financial Assistance Reform’s (COFAR) strategic planning and communication with the grants community. The report, Grants Management: Improved Planning, Coordination, and Communication Need to Strengthen Reform Efforts (GAO-13-383), examines previous and current government-wide initiatives designed to reform grants management. The GAO recommends OMB and COFAR develop and make publicly available an implementation schedule of ongoing activities, clearly identify and define the roles and responsibilities in grants reform initiatives, and improve communication with grant recipients and other stakeholders involved with grants management policy. The report traces efforts to streamline and reform grants management since the passage of the Federal Financial Assistance Management Improvement Act of 1999 (PL 106-107). The GAO identifies successful, and some less successful, attempts to improve grants management.  Some of the initiatives discussed in the report include; consolidating and revising grants management circulars, simplifying the pre-award phase, promoting shared IT solutions for grants management, and improving the timeliness of closing grants and deobligating funds. Improving the grants closeout process remains a priority for the GAO and has been the subject of multiple Congressional hearings. The report briefly discussed OMB’s proposed Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards. The Uniform Guidance, known informally as the “Super Circular,” will streamline grants management by consolidating existing policies into one document that will apply uniformly to all grant recipients. OMB plans on circulating the final proposal among awarding agency officials before publishing the final rule, tentatively scheduled for December 2013. The primary focus of the report regards the activities of the COFAR. The GAO provides a history of the COFAR and summarizes its current priorities and goals. OMB established the COFAR in 2011 and charged it with the responsibility to identify issues and challenges in grants management policy and make recommendations to improve grants administration. For grant recipients, the most relevant aspect of the report is the discussion on the extent of stakeholder participation in COFAR’s decision-making process. GAO notes “members of the grantee community told us they continue to have concerns because they do not see a role for themselves as OMB and COFAR develop priorities for reforming federal grants management.“ To rectify this problem, the report cites the Federal Demonstration Partnership (FDP) as a successful model to fully engage the grants community. The FDP is a consortium of research universities and awarding agencies that holds quarterly meetings that allow for recipients to provide input on grants management policies and procedures. The report also suggests adopting the Recovery Board’s practice of holding weekly conference calls with grant recipients to hear comments and concerns. Additionally, the GAO identifies the Partnership Fund for Program Integrity Innovation (Partnership Fund) as an opportunity to improve communication with recipients. The Partnership Fund, administered by OMB, enables federal agencies to execute pilot programs with state and local governments. OMB responded to the GAO by agreeing with the report’s recommendations.  OMB stated that COFAR is developing and implementing strategies to engage stakeholders proactively. OMB also repeatedly referred to the COFAR as a work in progress. COFAR will be a leading player in the adoption and implementation of the Super Circular. It is therefore critical that COFAR fully engages the grants community and is receptive to and understanding of...

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Supreme Court Upholds First Amendment Rights for Grant Recipients

Posted by on Jun 20, 2013 in Grants & Assistance | 0 comments

In a 6-2 decision released this morning, the Supreme Court upheld the First Amendment rights of grant recipients. In Agency for International Development v. Alliance for Open Society, the Court examined the power of the federal government and awarding agencies to impose certain award terms and conditions that would require a recipient to “adopt and espouse, as their own, the Government’s view on an issue of public concern.” The Court ruled that a condition of federal funding “requiring recipients to profess a specific belief” exceeds the government’s power to administer a federally funded program and is therefore a violation of the recipient’s First Amendment rights. In 2003, Congress passed the United States Leadership Against HIV/AIDS, Tuberculosis, and Malaria Act, known as the President’s Emergency Plan for AIDS Relief (PEPFAR). Congress authorized the disbursement of program funding to nongovernmental organizations and appropriated $3 billion annually for five years. A provision in the Act denied funds to “any group or organization that does not have a policy explicitly opposing prostitution and sex trafficking.” The full text of the law can be found at http://www.gpo.gov/fdsys/pkg/PLAW-108publ25/html/PLAW-108publ25.htm. Two recipient organizations, the Alliance for Open Society International and Pathfinder International, challenged the provision by arguing the condition of aid violated the First Amendment by forcing recipients to adopt the government’s message as their own. The organizations maintained a neutral policy towards prostitution and argued that adopting the government’s position and message would marginalize sex workers and limit the organizations’ ability to achieve the program’s goal in preventing the spread of HIV.  The respondents’ brief can be found at http://sblog.s3.amazonaws.com/wp-content/uploads/2012/12/12-10-Brief-in-Opp-OK-TO-PRINT12-12-12.pdf.pdf. In its brief, the federal government argued that “Congress has wide latitude to attach conditions to the receipt of federal assistance in order to further its policy objectives.” The government maintained the policy did not violate the First Amendment rights of the recipients because nothing compels organizations to apply for funding and that “private entities that do not wish to comply with those conditions may avoid them simply by declining federal funds.”  The government’s brief can be found at http://www.americanbar.org/content/dam/aba/publications/supreme_court_preview/briefs-v2/12-10_pet.pdf. The Court recognized the ability of the government to establish terms and conditions for recipients of federal funding.  In this situation, however, the Court determined the condition of aid required the recipients to “pledge allegiance to the Government’s policy of eradicating prostitution.” The Court found the recipients’ First Amendment rights were violated because the award terms and conditions went “beyond defining the limits of the federally funded program to defining the recipient.” The policy requirement, the Court determined, would infringe the recipients’ ability to effectively administer programs financed with non-government funds.  “A recipient cannot avow the belief dictated by the condition when spending [PEPFAR] funds, and assert a contrary belief when participating in activities on its own time and dime.” This ruling is a significant victory for grant recipients. The Court upheld the First Amendment rights of recipient organizations and established guidelines for award terms and conditions. With this decision, Congress and awarding agencies cannot establish award terms and conditions that exceed the scope of the program. The Court’s decision can be found at...

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Comments for the Super Circular are Due!

Posted by on May 31, 2013 in Grants & Assistance | 0 comments

The deadline for submitting comments for the Super Circular is June 2nd. Comments must be submitted electronically through regulations.gov. To directly access the docket for the Super Circular, click here. The “Super Circular,” known formally as the Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards, is a proposal to consolidate all current regulations for grants management into a single document that would apply uniformly to all recipient entities. The purpose of the proposal is to streamline grants management by reducing administrative burdens on recipients. Officials from OMB have repeatedly stressed the importance placed on public comments. The final regulation, expected to be released within a year, will be shaped, in part, by the submitted comments. The deadline for comment submission was originally May 2nd; however, OMB extended the deadline to this Sunday to provide additional time for the public to weigh in on this landmark proposal. As of this morning, only 119 comments have been...

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OMB Grants Single Audit Deadline Extension

Posted by on May 29, 2013 in Grants & Assistance | 0 comments

On May 9th, OMB published a notice in the Federal Register soliciting public comments for proposed changes to the SF-SAC form. The SF-SAC is the standard data collection form used for Single Audit Act audits. The proposed changes to the form include additional data elements, as well as modifications to existing elements. The deadline for comment submission is July 8th. OMB anticipates the SF-SAC will be available by the end of the summer. Recognizing this time frame affects audit deadlines, OMB has granted an automatic extension until September 30, 2013 for reporting packages due to the Federal Audit Clearing House before that date. The extension applies only to single audits for FY 2013. Additional information can be found at...

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The DATA Act is Reintroduced

Posted by on May 21, 2013 in Grants & Assistance | 0 comments

Congress may be on the verge of approving The Digital Accountability and Transparency (DATA) Act.  Last week, Congressman Darrell Issa, chairman of the House Oversight and Government Reform Committee, announced plans to reintroduce the legislation following behind the scenes bipartisan negotiations with Senator Mark Warner, the Senate sponsor of the DATA Act. Tomorrow, May 22nd, Congressman Issa’s Committee is scheduled to markup the bill and will likely adopt the legislation with minimal changes. The DATA Act is designed to increase transparency and accountability of federal grants, contracts, and spending. The primary purpose of the legislation is to publish all federal spending on the Internet with the intent of reducing waste, fraud, and abuse. The DATA Act would standardize reporting requirements which would expand the ability for government officials and the public to easily search and examine spending from one Internet location. During the 112th Congress (2011-2013), Congressman Issa and Senator Warner introduced the DATA Act in their respective chambers. After the House of Representatives approved the bill in April 2012, a number of professional organizations expressed concern the legislation would increase the reporting and financial burdens of grant recipients.  To address these concerns, Senator Warner introduced a modified version of the DATA Act, S. 3600, in September 2012 that was designed to shift the responsibility of reporting financial award information to awarding agencies. Many of the associations opposed to the House version expressed support for the Senate bill. The 112th Congress adjourned before the Senate could consider the measure. The latest version of Congressman Issa’s DATA Act reuses most of the language and adopts many of the provisions from S. 3600. Federal agencies would be required to publish award information on USASpending.gov and to use a standard, governmentwide award identification process.  Additionally, the legislation would expand the Recovery Board’s authority to conduct a three year pilot program to improve the accuracy of federal financial data. With Congressman Issa and Senator Warner appearing to have reconciled the differences between the two companion bills, the chances that Congress will approve the DATA Act have significantly improved. UPDATE – The House Oversight and Government Reform Committee approved the DATA Act on May...

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COSO Releases Updated Internal Control-Integrated Framework

Posted by on May 21, 2013 in Grants & Assistance | 0 comments

On May 14th, the Committee of Sponsoring Organizations (COSO), an initiative of five private sector organizations that develop guidance on risk management and internal control, released an updated Internal Control-Integrated Framework. The Integrated Framework is widely used by entities in evaluating their internal control systems to reduce the potential for fraud. The revised Integrated Framework reflects the changes to business practices and regulations since the original Framework was published in 1992. The Framework is used by business and corporations, for-profit and nonprofit organizations and government entities. The grants community will be affected by the changes to the framework because auditors will examine how a grant recipient has established internal control procedures to mitigate risk. COSO will continue to make available the original Framework to organizations through the transition period, which ends on December 15, 2014. After this date, COSO will consider the original Framework superseded by the updated version and auditors and organizations should be in compliance with the changes. For additional information, visit the COSO website at...

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SAM.gov Webinar

Posted by on May 14, 2013 in Grants & Assistance | 0 comments

The General Services Administration (GSA) will hold a free webinar to assist individuals in using SAM.gov.  The webinar will assist individuals in creating SAM.gov accounts, migrating permissions from the Central Contractor Registration (CCR) database, and updating existing registration. A recording of the webinar will be available for individuals who cannot attend at the assigned time. The information for the webinar is below: Date: Wednesday, May 15th Time: 2:00pm-3:00pm  EST Registration webpage: http://gsa.gov/portal/event/form/170683 Link for webinar: http://gsafas.adobeconnect.com/sam_webinar/ SAM.gov is the centralized federal procurement system. Grant recipients are required to register with SAM.gov before submitting grant applications through grants.gov.  Users must renew their SAM registration...

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Draft Legislation Would Alter the National Science Foundation’s Peer Review Process

Posted by on May 1, 2013 in Grants & Assistance | 0 comments

Multiple websites have reported on draft legislation that would alter the National Science Foundation’s (NSF) grant award process. According to the reports, Congressman Lamar Smith, chairman of the House Science, Space, and Technology Committee, is drafting legislation that would require the Director of NSF to certify each awarded project: is in the interest of the United States to advance the national health, prosperity, or welfare, and to secure the national defense by promoting the progress of science; is the finest quality, is ground breaking, and answers questions or solves problems that are of utmost importance to society at large; and is not duplicative of other research projects being funded by the Foundation or other Federal science agencies. Critics claim the draft legislation represents an undue congressional and political intrusion and would undermine the peer review process. Congressman Smith released a statement maintaining the draft legislation would serve the interest of taxpayers by requiring the NSF to prioritize funding to the highest-quality research and by enhancing accountability of the awards process. The draft bill, which was leaked to media outlets, can be found here. The Ranking Member on the Committee, Congresswoman Eddie Bernice Johnson, released a letter critical of the attempts to alter NSF’s award procedures. Congresswoman Johnson’s letter can be found here. Included in the draft legislation is a provision that would require the Director of the Office of Science and Technology Policy to analyze how the certification requirements could be implemented by other federal science agencies. Agencies that could potentially be affected included NASA, the Department of Energy, the EPA, and FEMA. The proposal is still in the initial steps of the legislative process, and Congressman Smith has not yet introduced the...

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House Approves Bill to Prevent Delinquent Taxpayers from Receiving Grants and Contracts

Posted by on Apr 16, 2013 in Grants & Assistance | 0 comments

The U.S. House of Representatives unanimously approved a bill yesterday that would prevent entities from receiving grants and contracts if they are “seriously delinquent” in paying federal taxes. The Contracting and Tax Accountability Act of 2013, H.R. 882, would require grant applicants to submit a certification indicating if their federal taxes have been paid in full. Federal agencies would be required to initiate debarment procedures against recipients that file false certificates or are found to have serious delinquent tax debt. Agencies could award grants to recipients with tax debt; however, those recipients would be designated as high-risk entities. If passed into law, the implications for grant recipients should be minimal. A majority of grant recipients are local government entities or not-for-profit organizations, therefore, the issue of delinquent taxes will not be applicable. The bill has not been introduced in the U.S. Senate yet, and it is unclear when, or if, the Senate will address this issue. To stay informed of the latest developments on this bill, click...

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OMB Extends Grant Reform Comment Deadline

Posted by on Mar 23, 2013 in Grants & Assistance | 0 comments

Just a quick note: OMB is extending the deadline for submitting comments on its “Advanced Notice of Proposed Rulemaking” relating to the grants management requirements overhaul. The new comment deadline is April 30. To read the original February 29 Federal Register notice describing OMB’s ideas for reforming grants management, click...

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House Committee Approves Bill to Limit Grant Awards to Delinquent Taxpayers

Posted by on Mar 21, 2013 in Grants & Assistance | 0 comments

The House Oversight and Government Reform Committee approved a bill yesterday that would limit an agency from awarding a grant if a recipient is delinquent in paying federal taxes. The Contracting and Tax Accountability Act of 2013, H.R. 882, would require grant applicants to submit a certification indicating whether they have fully paid their federal taxes. Federal agencies would be required to initiate debarment procedures against recipients that file false certificates or are found to have serious delinquent tax debt. The language in the bill would allow agencies to award a grant to a recipient with tax debt, but the agency would be required to designate the recipient as high-risk. In recent years, Congress has passed numerous laws to reduce waste, fraud, and abuse of federal taxpayer dollars and hold grant recipients more accountable for their awards. This bill is seen as a continuation of that policy. The primary goal of this legislation is to prevent businesses from receiving contract awards if they have not paid their federal taxes. While grant awards are included in the legislation, the practical effect on grant recipients may be minimal, as a large percentage of recipients are tax-exempt entities or non-federal government entities. It is not clear when, or if, the House will vote on the bill.  For more information on the bill, including the text, click...

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OMB Officials Discuss the Proposed Uniform Guidance

Posted by on Mar 20, 2013 in Financial Management, Grants & Assistance | 0 comments

OMB officials discussed the proposed “Super Circular” today at the monthly National Grant Management Association (NGMA) training luncheon held in Washington, D.C. The officials discussed some of the proposed changes that would affect grants management, with one official labeling the entire process Extreme Makeover: OMB Edition. The “Super Circular,” known formally as the Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards, is a proposal to consolidate all current regulations for grants management into a single location that would apply uniformly to all recipient entities. The purpose of the proposal is to streamline grants management by reducing administrative burdens on recipients. During the presentation at the training luncheon, OMB officials discussed some of the more than 30 regulation changes found in the Guidance. The presentation primarily focused on the proposed changes to the Cost Principles, specifically the ability for select entities to choose a flat 10% modified total direct cost standard rate and the reduction in administrative burdens, and to audit requirements, with a significant amount of time devoted to discussing changes to compliance requirements. The officials stressed the Guidance is only a set of proposals and that public comment will be critical in shaping the provisions and language used in the final rule. The presenters urged the attendees to submit comments to help advise OMB in developing the final regulations. To provide additional opportunity for the grants community to have a role in the process, OMB announced the deadline for public comments has been extended to June 2nd. To comment on the Guidance, visit the Regulations.gov docket here. OMB released the proposed Guidance on February 1st in the Federal Register and plans to publish the final rule by the end of this year. The final rule will be published simultaneously in the Federal Register and 2 CFR. Agencies will adopt the regulations, by reference, in 2 CFR. According to OMB, the final rule should be fully implemented by mid-2014 and recipients with continuing awards will be required to adhere to the regulations at the beginning of the following fiscal year, which starts October 2014. The Uniform Guidance is a major topic in Management Concept’s one-day Federal Grants Update 2013 seminar.  The seminar provides students with a detailed explanation of the structure of the Uniform Guidance and of all the proposed changes that will affect federal agencies, grant recipients, and pass-through entities. In addition, the seminar also includes other topics such as the increased emphasis on program assessments and performance measurements in grants management, recent legislative and regulatory changes affecting grants administration, and the latest developments regarding the federal budget and sequestration. To register for the course, visit the Federal Grants Update 2013 seminar’s webpage located...

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GAO Releases Redbook Update

Posted by on Mar 15, 2013 in Grants & Assistance | 0 comments

The GAO recently released the annual update to the Principles of Federal Appropriations Law, more commonly referred to as the Redbook. Two GAO opinions referenced in the update are important for the grants community. The first important GAO opinion concerned the authority of the Social Security Administration to carry out two grant programs after the authorization for appropriations had expired. The GAO determined that as long as the underlying program authority is still valid, appropriations in the authorizing statute do not have to be current. The second opinion, GAO opinion B-322628, involved the Department of Labor’s authority to make replacement grants. The GAO determined that the department could use funds de-obligated from a defective award to make new awards after the period of obligation of the funds had expired. The entire annual update can be downloaded by clicking here. Both GAO opinions are discussed and explained in Management Concept’s one-day Federal Grants Update 2013 seminar. The seminar provides students with the latest information affecting grants management and administration. An outline of the course can be found at the Federal Grants Update 2013 seminar’s webpage located...

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The Sequester is Here

Posted by on Mar 1, 2013 in Acquisition, Financial Management, Grants & Assistance | 0 comments

Barring a last minute compromise, the  sequester will become a reality tonight. In preparation for the $85 billion in automatic spending cuts, OMB released a memo yesterday detailing the effect of the sequester on important government functions. Included in the memo is an explanation of how grant funding will be impacted. The excerpt from the memo about financial assistance is provided below. “Given the widespread use of grants, loans, and other Federal financial assistance to non-federal entities (e.g., State, local and tribal, non-profit organizations, and companies), sequestration will impact the funding of these activities. As a general matter, agencies should ensure that any new financial assistance obligations or funding increase under existing agreements are consistent with the need to protect the agency’s mission at the post-sequestration level. In light of sequestration, agencies may also consider delaying awarding of new financial assistance obligations, reducing levels of continued funding, and renegotiation or reducing the current scope of assistance. Agencies may be forced to reduce the level of assistance provided through formula funds or block grants. Should any such steps be necessary, agencies should evaluate the associated costs and benefits of such actions and appropriately engage and inform recipient(s) as early as possible.” A link to the full memo can be found here:...

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OMB Wants Your Input on Grants Management Reform

Posted by on Feb 24, 2013 in Grants & Assistance | 0 comments

As promised, OMB has set out a list of recommendations about ways to improve grants management — and now is your chance to comment. The notice appeared on OMB’s website earlier today, but the official version will not be published in the Federal Register until next Tuesday. This “Advanced Notice of Proposed Guidance” briefly outlines the reform ideas OMB is considering, which could reshape the entire landscape of federal grants management. OMB is targeting all aspects of grants management: audit, cost principles, and uniform administrative requirements. At this point, OMB is simply asking for feedback on these rather broad ideas. Using that feedback, it will then develop a detailed proposal that will be published in the Federal Register for further comment. But now is the time to let your voice be heard. You have 30 days to comment on the ideas. To read the OMB announcement and to find out how to comment, click on the link below or watch the Tuesday Federal Register....

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Are You Ready for a New OMB Circular?

Posted by on Feb 21, 2013 in Grants & Assistance | 0 comments

The Office of Management and Budget is working on a draft “omnibus circular” that would consolidate and revise the current uniform administrative requirements, cost principles, and audit circulars. While details are sketchy, the new circular could represent a significant change for grants management. For example, OMB may raise the single audit threshold, consolidate the current cost principles into one set, and set standards for merit-based reviews of grant applications. OMB officials say a Federal Register notice inviting comments on the proposal will be published before the end of February. You will have 60 days to comment, and then OMB will review all of the input before issuing a second notice. If all goes according to OMB’s schedule, the new circular could be in effect by early fall. However, for those of us in the grants management community, we know this is an ambitious goal. Nonetheless, I wanted to give everyone a heads-up about the coming notice so you can be prepared to submit comments. Keep watching this blog for more information. In addition, our annual Federal Grants Update seminar will cover this proposal in detail once it is...

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Help Us Help You!

Posted by on Feb 21, 2013 in Grants & Assistance | 0 comments

We need your help to plan our upcoming class schedule and training. Where would you like us to schedule classes? Are there additional courses you’d like to see offered online? What new courses or products could we offer to meet your training and professional development needs? Your answers to these and other questions will help us improve our grants management training curricula. Please take a few minutes to complete our online survey. We ask that you complete the survey by February 25th. To access it, click here. Your feedback is greatly appreciated and is for informational purposes only....

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Free Webinar for SAM.gov Information

Posted by on Feb 19, 2013 in Grants & Assistance | 0 comments

The General Services Administration (GSA) will hold a free webinar to assist individuals in using SAM.gov.  The webinar will assist individuals in creating SAM.gov accounts, migrating permissions from the Central Contractor Registration (CCR) database, and updating existing registration. A recording of the webinar will be available for individuals who cannot attend at the assigned time. The information for the webinar is below: Date: Tuesday, February 26, 2013 Time: 1:00pm EST Registration webpage: http://www.gsa.gov/portal/event/form/160683 SAM.gov is the centralized federal procurement system. Grant recipients are required to register with SAM.gov before submitting grant applications through grants.gov.  Users must renew their SAM registration...

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OMB to Host Webinar on Proposed Guidance

Posted by on Feb 4, 2013 in Grants & Assistance | 0 comments

OMB announced plans to hold a webinar on the proposed Uniform Guidance on February 8, 2013 at 11:00 am EST at www.cfo.gov. The webinar is free and preregistration is not required. The webinar will explain the proposed policy changes and how the grants community will be impacted. The Guidance was published last Friday. It is designed to provide a uniform policy for federal grants by consolidating and updating government regulations. A copy of the Guidance, along with other useful documents, can be found here. The chart below identifies the OMB Circulars that are proposed to be consolidated into the Guidance. Subject Regulation Entity Cost Principles 2 CFR 225(OMB Circular A-87) State, Local, and Indian Tribal Governments 2 CFR 220(OMB Circular A-21) Educational Institutions 2 CFR 230(OMB Circular A-122) Non-Profit Organizations Administrative Requirements 2 CFR 215(OMB Circular A-110) Educational Institutions, Hospitals, and Non-Profits OMB Circular A-102 State and Local Governments Audits OMB Circular A-133 States, Local Government, and Non-Profit OMB Circular A-50 CFDA OMB Circular A-89 Management Concepts will continue to update the Grants Blog in the coming days to discuss proposed changes in the...

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OMB Releases SuperCircular

Posted by on Jan 31, 2013 in Grants & Assistance | 0 comments

Tomorrow’s Federal Register will publish OMB’s “supercircular.” The official name of the proposal is the OMB Uniform Guidance: Cost Principles, Audit, and Administrate Requirements for Federal Awards. OMB has published the supercircular and additional resources on its webpage. One resource is the “Crosswalk from Existing Guidance to Proposed Guidance.” This chart explains all the proposed changes. The following is the link to the OMB supercircular and provided resources. The public will have 90 days to provide comment on the proposed changes. Management Concepts will release a detailed analysis of the supercircular very shortly. We’ll also be covering the proposed changes and their impact on the grants community in our Federal Grants Update...

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Federal Grants Update 2013 Course

Posted by on Jan 24, 2013 in Grants & Assistance | 0 comments

Information about Management Concepts’ annual Federal Grants Update seminar is now available. This one-day course is a great way to keep track of the latest developments in grants management and to learn about pending changes that may impact your day-to-day grants work. This year’s course will focus on the increased emphasis on program assessments and performance measurements in grant applications, improved oversight of  the closeout process, recent legislative and regulatory changes to grants management, and COSO’s updated internal controls framework. Additionally, the course will bring up-to-the-minute information about developments relating to OMB’s “Supercircular.” Classes start the first week in April and run throughout the summer in cities around the country. We can also bring the course to your location. Click here to see dates, locations, topics, and registration...

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The Fiscal Cliff, Sequestration, and Federal Grants

Posted by on Dec 12, 2012 in Grants & Assistance | 0 comments

In recent weeks, the media has been in a near non-stop reporting frenzy analyzing the daily offers and counteroffers by the major players in the “fiscal cliff.” One local channel in the Washington area has even begun to broadcast a clock counting down the days until the nation plunges off the fiscal cliff. While national polling suggestions a majority of the American public is “very closely” or “fairly closely” following the negotiations between President Obama and Speaker Boehner, many remain confused about the details of the fiscal cliff and what might occur if an agreement is not reached. The term “fiscal cliff” refers to numerous events affecting the federal budget occurring simultaneously at the end of this calendar year. These factors include sequestration, the expiration of the 2001 and 2003 tax breaks, and the expansion of the Alternative Minimum Tax (AMT). Sequestration – spending cuts to defense and discretionary spending – may have the most significant impact on federal grant recipients and subrecipients. If the president and Congress fail to reach a compromise by January 2, 2013 then current discretionary spending will be automatically reduced by $500 billion. Sequestration would result in drastic cuts to federal grant funding. It is estimated that budgets for three of every four grant programs would be reduced. The formula Congress developed to impose sequestration does not impact all programs equally. The most significant cuts would be to agriculture, employment, community development, justice, energy, and education grant programs. State and local grant recipients would see reduced funding in many popular and widely utilized programs, including the Community Development Block Grant, community policing, Rural Development, energy and weatherization assistance, and transportation grants. School officials are particularly concerned about the potential $3.5 billion in cuts to U.S. Department of Education programs. While negotiations between President Obama and Speaker Boehner have primarily focused on tax rates, there is a developing consensus among agency officials that there will be an agreement on sequestration at some point. Should sequestration take effect, grant recipients should be prepared for a period of confusion as agencies attempt to implement the mandatory cuts. Management Concepts will continue to provide updates in the coming weeks. Stay...

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Federal Grants Management and Legalized Marijuana

Posted by on Dec 11, 2012 in Grants & Assistance | 0 comments

On Election Day, voters in Colorado and Washington approved ballot measures that decriminalized the use and possession of small amounts of marijuana. In direct conflict with these state laws is the federal Controlled Substance Act, which classifies marijuana as a Schedule I Controlled Substance. Many employers in these two states face uncertainty on how to implement drug-free workplace policies. These laws also present potential legal questions to grant recipients. Currently, all grantees are required to implement and adhere to the requirements in the Drug-Free Workplace Act.  Since marijuana remains illegal on the federal level, grant recipients in these two states should continue to follow the terms and conditions of their awards and ensure employees do not use illegal drugs in the workplace. The picture gets more complicated in Colorado and Washington, where grant recipient organizations could potentially be facing increased wrongful termination lawsuits from employees. To comply with the Drug-Free Workplace Act, many grantees conduct drug screening of employees. As state marijuana laws change, individuals who lose jobs or are denied employment after testing positive for marijuana might file lawsuits challenging their dismissal. However, in states that allow marijuana use of medicinal purposes, state courts have generally upheld an employer’s right to terminate an employee who has tested positive for medical marijuana use by citing the Controlled Substance Act’s recognition of marijuana as an illegal substance. Will that continue to be the case for states that decriminalize marijuana? With the number of states legalizing medicinal and recreational marijuana increasing, grant recipients may be facing many additional legal questions on how to implement the terms and conditions of their awards while complying with both federal and state law. This poses a great question, what other issues might grant recipients be concerned with in states that have legalized, to any extent, marijuana? What are the appropriate proactive and reactive measures grant recipients in these states should be...

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Super Circular Update

Posted by on Dec 11, 2012 in Grants & Assistance | 0 comments

Only a few weeks remain of 2012 and OMB still has not indicated when the draft super circular will be released. While rumors seemed to indicate OMB was on the verge of releasing the draft regulations a month ago, there have not been any new developments. Management Concepts is hearing that individuals who have seen the portions of the draft regulations have called them “vague” and “ambiguous” and that OMB is continuing to revise them. Management Concepts continues to monitor developments and will update this blog when we hear of...

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Senate Adopts Whistleblower Protections for Grantees

Posted by on Dec 3, 2012 in Grants & Assistance | 0 comments

Last week, the Senate agreed to an amendment to the Defense Authorization Act designed to strengthen whistleblower protections for employees of contractors, subcontractors and grantees. The amendment prohibits employers from firing or punishing employees who report abuse, waste, or fraud relating to Federal grants or contracts. Individuals believing that they have been punished by an employer would be able to file a complaint with the Inspector General’s office of the awarding agency. The amendment also prohibits employers from waiving the provisions of the amendment as a condition of employment. Additionally, employers will be required to notify employees of their rights and remedies provided by the amendment. The amendment’s provisions would impact all future contracts and grants, and would only impact previously awarded contracts if the contract was modified to specifically include the provisions. In June, the House passed a version of the bill that included language that would provide extended whistleblower protection only to Defense Department contracts or grant awards. The Senate amendment would extend this protection to all contractor and grantee employees. Management Concepts offers a Federal Grants Update course each year that reviews, examines, and analyzes legislative and regulatory changes in Federal grants management.  The 2013 Update Course will cover this issue as well as many other important changes. Additional information about this course will be posted on our website in January. A list of current course offerings is found in the course...

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Is OMB Close to Releasing a Draft “Super Circular?”

Posted by on Nov 2, 2012 in Grants & Assistance | 0 comments

Rumors abound that OMB is on the verge of releasing the draft “super circular” of changes to federal grant policy. In February, OMB issued an Advanced Notice of Proposed Guidance recommending changes to the administration of federal grants, costs principles, and A-133 audit requirements. Over 300 comments were submitted to OMB by the April 30th deadline. Since then, OMB has been consulting with agency officials in developing a draft of the proposed changes. Once released in the Federal Register, the public will have a sixty day window to submit further comments. OMB will review those comments and incorporate appropriate changes before releasing a final version. Management Concepts is watching the developments at OMB very closely, as any proposed changes will significantly change the landscape of grants management. Please note that the next action OMB takes will only be a draft, and will not have an immediate impact. The Grants Blog will be updated as soon as OMB does release the draft super circular. To view the February Advanced Notice and all submitted comments, click...

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Nation Faces Sequestration

Posted by on Oct 31, 2012 in Grants & Assistance | 0 comments

The presidential election is a week away, and the winning candidate will immediately face a dire economic situation known as “The Fiscal Cliff.” This term applies to numerous budgetary factors all occurring simultaneously at the end of this calendar year. These factors include sequestration, the expiration of the 2001 and 2003 tax breaks, and the expansion of the Alternative Minimum Tax (AMT). Sequestration may have the most significant short-term impact on federal grant recipients and subrecipients. The Budget Control Act of 2011 requires $500 billion in reductions to discretionary, non-security spending achieved through an 8.2% across-the-board spending cut. The required spending cuts will be automatic unless the president and Congress act to prevent sequestration by the end of this year. Currently, a bipartisan coalition of eight senators is working behind the scenes to reach a compromise. Many observers and policy experts do not expect any compromise to emerge until after the election. If sequestration does occur, the level of funding for competitive federal grants is likely to be reduced significantly. Management Concepts will continue to monitor the budgetary process and update the Grants Blog when major developments...

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New DATA Act Introduced in the Senate

Posted by on Oct 1, 2012 in Grants & Assistance | 0 comments

Senator Mark Warner (D-VA) introduced a new version of the DATA Act (S.3600) after the previous version passed the House but died in the Senate.   This version differs in several ways from the previously introduced version, including a new design for the accountability board. This new version eliminates the creation of an independent board which would have had control over all federal spending, including management of USAspending.gov, subpoena power, and other oversight tasks (see our post from June 15, 2011).  The newly introduced DATA Act stifles some of the power created in the House bill.  The Senate version’s Federal Accountability Spending and Transparency Board (FAST Board) would be smaller and not independent and is also intended to replace the President’s Government Accountability and Transparency Board created under Executive Order 13576.  According to the legislation, the board would consist of five members appointed by the President and would include at least one senior official from the Office of Management and Budget (OMB). Other pieces to note: USAspending.gov would be expanded to include money spent by federal agencies on salaries, facilities, and other expenses beyond grants, loans, and contracts. Both versions of the bill include a requirement for the online posting of federal funds that were actually expended, not just what was promised to contractors or grant recipients. The new Senate version contains similar language to the old bill creating common data elements, “such as codes, unique award identifiers, and fields, for financial payment information required to be reported by Federal agencies.” The bill would streamline recipient financial reports by requiring OMB to review reporting requirements required by the agencies in an effort to reduce duplicative financial reporting and then submit a report to Congress on any legislative action required to streamline these reporting requirements. The full text of the legislation can be found here. We will keep you posted on any movement through the...

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GAO Examines Challenges to Grant Administration and Management

Posted by on Sep 27, 2012 in Grants & Assistance | 0 comments

The Government Accountability Office (GAO) released a report on September 25, 2012 entitled “Grants to State and Local Governments: An Overview of Federal Funding Levels and Selected Challenges.” The report provided a synopsis of federal assistance programs, the grant awards process, and funding levels of federal grants over the last thirty years. The GAO did not examine any new issues regarding federal grant programs, and instead summarized previous audit reports focusing on the challenges in implementing and managing federal assistance programs. While the report did not provide any new recommendations for policy initiatives or insight into grants management, it can serve as an excellent reference for individuals seeking to learn more about federal grant programs. The report provided a concise summation of GAO concerns regarding the lack of appropriate performance measures for many grant programs, overlap and duplication of program scopes and objectives, and the need for more effective oversight and monitoring of grant awards. The report can be found at http://www.gao.gov/assets/650/648792.pdf. Management Concepts offers two courses designed to address the some challenges in grants management outlined by the GAO. The Monitoring Grants and Cooperative Agreements for Federal Personnel course provides training to federal grant and program officials to develop working familiarity with essential monitoring techniques and gain insight into potential problem areas in grants administration. The Accountability for Federal Grants course is designed for anyone in the grants community, awarding and recipient personnel alike, who is interested in applying performance-based principles to grant projects. Additional information about these courses can be found in our course...

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GAO Sustains Housing Agencies’ Protest for HUD’s Improper Use of Cooperative Agreements

Posted by on Sep 25, 2012 in Grants & Assistance | 0 comments

The Government Accountability Office (GAO) recently sustained protests by several housing agencies who asserted that the Department of Housing and Urban Development’s (HUD) use of a notice of funding availability (NOFA) was improper in seeking to obtain contract administration services.   Instead, the protesters contend, HUD should have used a procurement instrument for these services. (GAO B-406738) In March of this year, HUD issued a NOFA providing for cooperative agreements to be issued to public housing agencies (PHA) for the administration of Project-Based Section 8 Housing Assistance Payment (HAP) contracts.  The NOFA stated that the awards would be a contract between the PHA and HUD to administer Section 8 contracts as a Performance-Based Contracts Administrator.  The PHAs would receive an administrative fee to pay for operating expenses while administering the contracts under HUD regulations. The protesters argue that HUD improperly used a NOFA for contract administration services that should be solicited through a procurement instrument.  The GAO noted that its jurisdiction does not extend to disputes over cooperative agreements, so it must first determine whether the instrument was correctly used.  Contending that cooperative agreements were the appropriate instrument, HUD maintained that the principal purpose of the contracts between the agency and the PHAs was to assist states and local governments by having the PHAs administer the contracts.  The agency further argued that the NOFA transfers a thing of value to the PHAs by providing the administrative fees. The GAO rejected HUD’s arguments and found that the PHAs act only as a conduit for the funds and that they have “no right to retain or use for the purposes any of the funds it receives for payment to the property owners.”  The GAO agreed that the administrative fee could be considered a “thing of value”, but did not agree that the principal purpose of the fee was to assist the PHAs in the performance of their mission.  The GAO concluded that the “principal purpose of the NOFA and [contracts] to be awarded under the NOFA is for HUD’s direct benefit and use.” The GAO’s recommended that HUD cancel the NOGA and instead use a procurement instrument  that will result in the award of...

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GAO Updates Grants Community on Streamlining Efforts

Posted by on Sep 20, 2012 in Grants & Assistance | 0 comments

Yesterday at the NGMA monthly training session, representatives from the Government Accountability Office (GAO) gave participants some insight on what to expect regarding grants streamlining efforts. Tom James and Betsy Hosler of the GAO introduced a “New Streamlining Engagement” effort that will: “1) Evaluate the progress OMB and other federal grant governance bodies have made toward streamlining grants management across federal grant-making agencies; and 2) Assess what further actions should be taken to streamline grants management across grant-making agencies.” Additionally, they confirmed that the status of the proposed notice for the “omnibus circular” is still expected to come out this month or...

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Grants Management Certificate Program™ Hits Milestone

Posted by on Sep 17, 2012 in Grants & Assistance | 0 comments

We generally don’t use this space to toot our own horn, but this is a special occasion. Last week, the Grants Management Certificate Program graduated its 5000th student. On behalf of all of us here at Management Concepts, we’d like to thank all of the Certificate Program candidates who allowed us to assist them with their career development over the...

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Court of Appeals Rules Against Cornell University in False Claims Act Case

Posted by on Sep 17, 2012 in Grants & Assistance | 0 comments

On September 5, 2012, the Second Circuit Court of Appeals upheld a lower court’s judgment finding that Cornell University’s Weill Medical College and Dr. Wilfred van Gorp, a former faculty member, submitted false claims on grant renewal applications and progress reports from 1999 through 2001. The case is U.S. ex rel. Daniel Feldman v. Wilfred van Gorp and Cornell University Medical College. The National Institutes of Health (NIH) awarded the grant to Cornell and Dr. van Gorp to provide training to post-doctoral fellows researching neuropsychology and HIV/AIDS. In 2003, Daniel Feldman, a fellow hired under the grant, filed a qui tam case under the False Claims Act.  (The False Claims Act imposes liability on persons and companies who defraud governmental programs.  These cases are often referred to as qui tam actions, which are suits brought by an individual, known as a relator, in an effort to prosecute government procurement and program fraud.  Additionally, to help alleviate the potential negative aspects of being a “whistleblower,” the federal government allows the relator to keep up to 30% of the amount the government recovers.)  Dr. Feldman alleged the program misused grant funds and that material changes had been made from the original grant application. After a four-year investigation, the government declined to intervene; however, Dr. Feldman pursued the claim using private counsel. The Court of Appeals upheld damages in the amount of $855,714 – three times the amount the government paid in grant funds to Cornell after it submitted its first fraudulent progress report.  The lower court also awarded $32,000 in statutory penalties and more than $625,000 in attorneys’ fees to Dr. Feldman. The Court of Appeals rejected all of the defendants’ arguments and provided a detailed discussion on awarding damages.  The Court found that when no tangible benefit has been received on the part of the government, then the “benefit of the bargain” method would be inappropriate.  The government, the Court said, received no benefit at all and therefore should be made whole again. We’ll be taking a closer look at this case in our Federal Grants Update 2012 course. The entire the decision can be found...

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OMB Tells Agencies to “Test” New Forms

Posted by on Aug 10, 2012 in Grants & Assistance | 0 comments

Beginning in August, federal agencies will have to “test” new or revised forms to ensure that the forms and instructions are clear and easy for users to understand. This requirement was issued by OMB’s Office of Information and Regulatory Affairs (OIRA) through an August 9 memo to the heads of all federal agencies. In the text of that memo, OIRA Administrator Cass Sunstein wrote: “With respect to Federal forms, simplicity and ease of comprehension are exceedingly important. In recent years, agencies have made important efforts to simplify and streamline forms and, where appropriate, to eliminate them. Despite these efforts, it is a continuing challenge for agencies to minimize complexity and confusion. The purpose of this memorandum is to help agencies to meet that challenge by testing whether forms are sufficiently clear and comprehensible.” Agencies will test forms either before issuing them for public comment or during the OIRA review. This testing should: ensure that the forms are not unnecessarily complex, burdensome, or confusing; help agencies obtain reliable information about the likely burdens on members of the public; and identify ways to reduce burdens and to increase ease of comprehension. Advance testing might include focus groups, in-person observations of users’ perceptions of the forms and questions (cognitive testing), web-based experiments, and randomized controlled experiments. A copy of the memo, which includes links to several guidance documents and resources for federal agencies, is available at...

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OMB Releases 2012 A-133 Compliance Supplement

Posted by on Jul 24, 2012 in Grants & Assistance | 0 comments

Ok, I’ll be honest. I haven’t looked at it yet, so I can’t comment on what’s included. But it’s finally here so I wanted to let everyone know ASAP. OMB just released the 2012 A-133 Compliance Supplement. It can be found here: http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2012 Enjoy! And keep checking the blog. I’ll be posting items of interest when I come across...

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Comments Sought on Streamlining Regs

Posted by on Jul 18, 2012 in Grants & Assistance | 0 comments

The following was just posted on the OMB blog. Since it is rather succinct and complete, I thought it best to just copy and paste it. So here is what OMB is doing… How can we continue to streamline, simplify, and improve rules and regulations? Which rules should be eliminated, streamlined, or made more effective? How can we reduce reporting and paperwork burdens? What are the best ways to cut regulatory costs? We’re looking for your ideas. In January 2011, the President directed all executive agencies to undertake an unprecedented government-wide review of regulations on the books, in order to figure out what is working and what is not, and where appropriate, to streamline or eliminate ineffective, overly burdensome, and outdated rules. Over two dozen agencies responded with regulatory reform plans, listing more than 800 initiatives. We are already seeing big results. Just a small fraction of those initiatives, already finalized or formally proposed to the public, will save more than $10 billion over the next five years. Far more savings are expected as the plans are implemented and improved. This May, the President made regulatory reform a continuing responsibility of all executive agencies and departments. All agencies must engage with the public to obtain suggestions about which regulations should be reassessed, modified, improved, streamlined, or eliminated. All agencies must give priority to reforms that would produce significant quantifiable savings or big reductions in paperwork and reporting burdens. And all agencies must report regularly to the public on their progress. The next reports are due fairly soon – this fall. To improve our review, and to make it as ambitious as possible, we are announcing, today, an opportunity for members of the public to offer their ideas. Which rules are outdated? Which ones are imposing unjustified costs? Which ones can be improved or made more effective? Submit your ideas at WhiteHouse.gov/Advise. They will be given careful...

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Health Care Ruling Leaves Many Questions About Grants

Posted by on Jul 2, 2012 in Grants & Assistance | 0 comments

Just a quick note regarding the Supreme Court ruling on the health care act and its potential impact on federal grants. Part of the decision expressly addresses the issue of whether Congress has the authority to set conditions upon the receipt of grants. The short answer is: yes, it can, as long as those conditions do not constitute “coercion.” The Court said that in this case, the threat of withholding 100% of Medicaid funding from states that did not want to participate in the expanded coverage program was coercion and was therefore unconstitutional. However, it did not clarify if withholding lesser amounts was coercion or simply “persuasion” — which is permissible. (The Court indicated that “persuasion” was permissible when it ruled that Congress had the authority to withhold highway construction funding — which totaled about 5% of state funding — from states that did not raise the drinking age to 21). So the Court’s health care decision leaves a lot of room for discussion, interpretation and perhaps even future legal challenges. At what point does “persuasion” become “coercion?” Does this logic apply to all grants and cooperative agreements or just certain essential services? And so forth. We’ll be taking a closer look at this issue in our Federal Grants Update 2012...

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What Happened to the DATA Act?

Posted by on Jun 26, 2012 in Grants & Assistance | 0 comments

Earlier this year there was a flurry of activity and far-ranging discussion surrounding a new DATA Act, legislation that would impose strict new reporting requirements on federal agencies and grant recipients. But what happened to that proposed measure? Apparently, it has died in the Senate. During a Sunday morning talk show, Rep. Darrell Issa, the bill’s primary sponsor in the House, was discussing the Republican agenda when he said “we want to be jobs and the economy,” Issa said. “The Data Act passed unanimously out of the House, and it’s died in the Senate. That would bring greater transparency and accountability and save money. We have those issues we’re working on.” If the measure does see any action in the Senate, we’ll let you...

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In Case You Missed It

Posted by on Jun 20, 2012 in Grants & Assistance | 0 comments

Deployment of SAM, the new System for Award Management, is being delayed until late July. SAM is a project sponsored by GSA that will consolidate numerous grants and contracts databases into one location. This consolidation will give users one central point for finding information, and also one login site for accessing data currently housed on sites such as EPLS, CCR and numerous others. GSA originally planned to launch Phase 1 of the project in late May, but is now indicating that it will be late July before it goes live. For more information, go to...

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Tips for Cross-Agency Coordination

Posted by on Jun 20, 2012 in Grants & Assistance | 0 comments

Looking for some advice on how to design a collaborative network? The IBM Center for The Business of Government just published a new report that highlights the successes and challenges of users who have implemented cross-agency collaborative networks. In the introduction to the report, the authors say: Government agencies face increasing internal and external pressure to share information and to communicate across agency boundaries. Multiple-organization collaborative initiatives are far more complex and difficult than technology-based projects developed for use by a single agency. Collaboration requires a shared technology infrastructure that knits together legacy information systems of each partnering organization. Even more challenging is the need to design new approaches to organizing, funding, governing, sharing data, security, and operations. The recommendations in the report are fairly straightforward. For example, they recommend involving all stakeholders. But they also go on to give pointers about how to do that. You can access the report...

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Some Progress Seen But Grant Closeout Remains A Challenge

Posted by on May 18, 2012 in Grants & Assistance | 0 comments

Nearly $800 million in undisbursed federal funds remained in expired grant accounts at the end of fiscal year 2011, according to a new report from the Government Accountability Office. And while some agencies have taken steps to reduce that amount and speed the grant closeout process, more work needs to be done. In a May 2012 follow-up to a 2008 report, GAO repeated its basic recommendation: OMB needs to establish governmentwide guidance for grant closeout. In the 2012 report, GAO noted that while the total amount of undisbursed funds in FY 11 essentially equaled the amount reported in its previous study, the percentage of total grant funding that those funds represented was lower – meaning that agencies were doing a better job of getting rid of those unobligated monies and closing accounts. For example, in February 2011, HHS established an interagency workgroup—the Accelerated Closeout Team—led by the Office of Grants and Acquisition Policy and Accountability to coordinate a departmentwide response in strengthening financial controls and accelerating the number of grant and contract closeouts. “Our analysis shows that there has been an improvement in closing out expired grant accounts with undisbursed balances in PMS since our 2008 report,” GAO said in the report. Nevertheless, GAO continues “The presence of tens of thousands of expired grant accounts in PMS with no undisbursed funds remaining raises concerns that these accounts are not receiving sufficient attention. Reducing the number of accounts with zero balances remaining would help ensure that administrative and financial closeout—the final point of accountability for these grants—is being completed. It would also minimize the amount agencies pay in potential fees for maintaining these accounts, which can accumulate over time.” If you are interested in learning about effective grant closeout, Management Concepts’ two-day Closeout of Grants for Federal Personnel will be helpful. This course provides students with a framework and actionable process for overseeing and conducting grant closeouts. Visit www.managementconcepts.com/grants for more...

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SAM Is Going Live Soon — And It Will Impact Grantees

Posted by on May 14, 2012 in Grants & Assistance | 0 comments

The General Services Administration (GSA) is undertaking a federal acquisition streamlining effort that while targeted to contracting, will nevertheless have an impact on the grants community. On May 29 GSA plans to move the functions currently hosted by the Central Contractor Registration (CCR) and the Excluded Parties List System (EPLS) into a new System for Award Management (SAM). SAM will consolidate nine acquisition databases that track pre- and post-award contract data across the entire federal civilian and Department of Defense acquisition communities. Included in this list of systems are several used by grantees and grantor agencies, such as CCR, EPLS, the FFATA (Federal Funding Accountability and Transparency Act) Reporting System (FSRS), and the Catalog of Federal Domestic Assistance (CFDA). The intent of SAM is to take each of these systems and their myriad databases – which now have separate login functions (with the exception of CFDA), overlapping data, and various host locations – and move them into one system. Users will have one login, one source for data, and one central host (reducing maintenance and operation costs for the federal government). SAM is not merely a portal into existing systems. It is an integration of current capabilities, information, and functionalities. The transition to SAM will be done in phases. Phase 1 – which includes EPLS and the CCR (along with other contract-related databases) — is set to go live May 29. According to the CCR website, the CCR site will go down May 23 and from that point on, its functions will be done through SAM. For entities that currently are registered in CCR, this will really not impact them at this moment. However, any entity that is registering for the first time and those that must re-register will now have to go through SAM. Phase 2, scheduled for deployment from December 2012 through June 2013, will include the FSRS and CFDA. (GSA, through SAM, is planning to assume responsibility for the development and maintenance of the catalog.) For more info, go to https://www.sam.gov/sam/ or...

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330 Comments — Now What?

Posted by on May 4, 2012 in Grants & Assistance | 0 comments

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...

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New Recipient, Fed Reporting Bill Clears House

Posted by on Apr 26, 2012 in Grants & Assistance | 0 comments

With the buzzwords “accountability” and “transparency” cited over and over, the House yesterday approved the DATA Act, a measure that would impose strict new reporting requirements on federal agencies and grant recipients. Recipients would have to report at least quarterly on receipt and use of federal funds. Similarly, federal agencies would have to report at least quarterly on all obligations and expenditures of federal funds. The Treasury Department would also report federal agency obligations and expenditures, and all of this information would be identified by program, budget category, or other Treasury account number so that it could all be easily compared. An interesting provision in this legislation is that it would not waive the reporting requirements for entities that receive small awards; only certain individuals would be exempt. The House also attempted to put some teeth behind the measure by allowing federal agencies to impose penalties of up to $250,000 on recipients who fail to meet the reporting requirements. To enforce agency reporting, OMB would be directed to issue guidance requiring compliance with the new act. The Data Accountability and Transparency Act (HR 2146) would also create a new oversight panel, the Federal Accountability and Spending Transparency Commission. This commission would have extensive power. For example, it would establish reporting deadlines, specify the data elements and the format of reports, and issue guidance to federal agencies and recipients on compliance with the new law. Also, rather than repealing the Federal Funding Accountability and Transparency Act, as was originally proposed in the House bill, the measure that members approved yesterday would amend that legislation by aligning it with the new reporting and transferring control over FFATA reporting and USAspending.gov from OMB to the new council. A companion measure was introduced in the Senate earlier this year, but is still awaiting action in the Committee on Homeland Security and Governmental...

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Agencies To Begin Using Do Not Pay Web Site

Posted by on Apr 12, 2012 in Grants & Assistance | 0 comments

Federal awarding officials now have a new tool to help them confirm individual and entity eligibility before making any grant, loan, contract, or benefit payment. Launched today, the new Do Not Pay List web site is a single point of entry for accessing relevant data. The portal allows federal agencies to to access data sources including the Death Master File, the Excluded Parties List System, Treasury’s Debt Check Database, and the List of Excluded Individuals and Entities. The site also offers data analysis of information from other sources that are not currently available through the portal, such as prison information and several privately available sources. OMB Memo 12-11 directs federal agencies to submit to OMB a draft of the agency’s plan for using this new tool by June 30, 2012. OMB will review those plans and agencies will finalize them no later than Aug....

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NIH Begins Testing RPPR

Posted by on Apr 3, 2012 in Grants & Assistance | 0 comments

This month the National Institutes of Health will begin pilot testing the new governmentwide Research Performance Progress Report (RPPR). Seven institutions will pilot the RPPR for NIH beginning in April 2012. During the initial pilot the RPPR will be used only for progress reports under awards that do not require submission of an annual detailed budget (i.e., awarded under the Streamlined Noncompeting Award Process or SNAP) and for individual fellowships. NIH anticipates expanding the pilot in the summer of 2012 to include all Federal Demonstration Partnership (FDP) institutions. Grantees will complete the RPPR electronically through the eRA Commons. Although the information that grantees will provide is not significantly different from what is currently reported, the format of the RPPR will be new to NIH grantees. The RPPR will consist of a series of 8 screens where grantees will answer questions using a checkbox, by entering text or uploading a PDF, or selecting “Nothing to Report.” The timing of full implementation of the NIH RPPR will be determined based upon the success of the initial pilot. For additional information, visit the NIH RPPR web...

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OMB Extends Grant Reform Comment Deadline

Posted by on Mar 23, 2012 in Grants & Assistance | 0 comments

Just a quick note: OMB is extending the deadline for submitting comments on its “Advanced Notice of Proposed Rulemaking” relating to the grants management requirements overhaul. The new comment deadline is April 30. To read the original February 29 Federal Register notice describing OMB’s ideas for reforming grants management, click...

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Keeping Tabs on the DATA Act

Posted by on Mar 19, 2012 in Grants & Assistance | 0 comments

I picked up some very interesting information about the DATA Act at last week’s NGP webcast. According to Cornelia Chebinou (NGP co-chair and the director of NASACT’s Washington, DC office) The legislation that will eventually be debated on the full House floor will be significantly different than the measure that came out of the House committee. The House is using a “manager’s amendment” to make significant changes to the bill. There were few details on what the changes would be, but one thing that was mentioned was the fact that the bill will no longer repeal FFATA. Also, bill sponsor Rep. Darrell Issa asked Majority Leader Rep. Eric Cantor to bring it to House floor as soon as possible once the amendment is done. The Senate has said it won’t act on the bill until it sees what comes out of the House. So we might have a case of wait, wait, wait, and then some very swift action. Just as a reminder, the DATA Act in its current form would require all recipients of grants, loans and contracts (with some exceptions for small-dollar recipients), as well as federal agencies to provide transaction information about those awards at least quarterly. A new Federal Accountability and Spending Transparency Board would set the standards for the data and would compile, analyze and publish the...

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It’s Your Training; Tell Us What You Want

Posted by on Mar 14, 2012 in Grants & Assistance | 0 comments

We need your help to plan our upcoming class schedule and training. What classes would you like to see offered in various locations? Are there other cities where you think we should offer training? What new courses or products could we offer to meet your training and professional development needs? Your answers to these and other questions will help us improve our grants management training curricula. Please take a few minutes to complete our online survey. We ask that you complete the survey by April 1. To access it, click here. .Your feedback is greatly appreciated and is for informational purposes...

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Lawmakers Introduce Bill To Amend Hatch Act

Posted by on Mar 8, 2012 in Grants & Assistance | 0 comments

Legislation has been introduced in both the House and Senate to update the nearly 75-year-old Hatch Act, a law that governs the political activities of federal, state, and local government employees. The Hatch Act Modernization Act of 2012 would make three major changes: • State and local government employees covered by the Hatch Act would be allowed to run for partisan elective office. • The Merit Systems Protection Board (which rules on alleged Hatch Act violations) would have more options for penalties. Currently, the only penalty, regardless of the level of the infraction, is immediate termination. Under the proposed legislation, the board could also impose sanctions such as reprimands, suspensions, demotions, or fines. • Employees of the District of Columbia would be subject to the same restrictions that apply to employees of state and local government agencies. Under the current act they are treated as federal employees. It has been nearly 20 years since Congress revised the Hatch Act and supporters of the new legislation say the proposed changes are “common sense” revisions that are desperately needed. Do you have any thoughts on the Hatch Act? I’ll be tracking this legislation as it moves through Congress, so keep watching this...

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OMB Wants Your Input on Grants Management Reform

Posted by on Feb 24, 2012 in Grants & Assistance | 0 comments

As promised, OMB has set out a list of recommendations about ways to improve grants management — and now is your chance to comment. The notice appeared on OMB’s website earlier today, but the official version will not be published in the Federal Register until next Tuesday. This “Advanced Notice of Proposed Guidance” briefly outlines the reform ideas OMB is considering, which could reshape the entire landscape of federal grants management. OMB is targeting all aspects of grants management: audit, cost principles, and uniform administrative requirements. At this point, OMB is simply asking for feedback on these rather broad ideas. Using that feedback, it will then develop a detailed proposal that will be published in the Federal Register for further comment. But now is the time to let your voice be heard. You have 30 days to comment on the ideas. To read the OMB announcement and to find out how to comment, click on the link below or watch the Tuesday Federal Register....

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Are You Ready for a New OMB Circular?

Posted by on Feb 21, 2012 in Grants & Assistance | 0 comments

The Office of Management and Budget is working on a draft “omnibus circular” that would consolidate and revise the current uniform administrative requirements, cost principles, and audit circulars. While details are sketchy, the new circular could represent a significant change for grants management. For example, OMB may raise the single audit threshold, consolidate the current cost principles into one set, and set standards for merit-based reviews of grant applications. OMB officials say a Federal Register notice inviting comments on the proposal will be published before the end of February. You will have 60 days to comment, and then OMB will review all of the input before issuing a second notice. If all goes according to OMB’s schedule, the new circular could be in effect by early fall. However, for those of us in the grants management community, we know this is an ambitious goal. Nonetheless, I wanted to give everyone a heads-up about the coming notice so you can be prepared to submit comments. Keep watching this blog for more information. In addition, our annual Federal Grants Update seminar will cover this proposal in detail once it is...

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Federal Grants Update 2012 Is On The Way!

Posted by on Jan 20, 2012 in Grants & Assistance | 0 comments

We’ve just posted information about our annual Federal Grants Update course to the Management Concepts web site. This one-day seminar is a great way to keep track of the latest developments in grants management and to learn about pending changes that may impact your day-to-day grants work. This year we’ll be discussing OMB’s plans for consolidating and revising the grants management circulars, new grants oversight boards, A-133 audits, suspension and debarment, and much more. Classes start the first week in April and run throughout the summer in cities around the country. We can also bring the course to your location. Visit the web page here for additional information about the topics that will be covered, locations and dates, and registration information. And if you have any other questions, feel free to contact...

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GRANT Bill Focuses on Preaward Issues, Single Audits

Posted by on Dec 13, 2011 in Grants & Assistance | 0 comments

There has been a lot of talk in Congress about grants accountability, but mostly in the realm of post-award administration. Now comes a bill that addresses those topics before an award is made. HR 3433, the s-called GRANT Act, would call for some rather dramatic shifts in the way discretionary grants are awarded. For example, federal agencies would have to establish and publish merit-based selection criteria. And before an award is made, agencies would have to evaluate whether the applicant is capable of properly managing federal awards and successfully completing the project. This seems fairly noncontroversial to me and aligns with current OMB circulars and administrative requirements. But the legislation would make all of the preaward information available to the public — everything from the applicant’s proposal to the award notice and the final award decision and applicant rankings. Further, agencies would post each recipient’s final report on a public website, along with any other information that could be useful to “future researchers or the public.” As for A-133 single audits, the proposed legislation would require OMB to report on how the process could be made more useful and efficient, something OMB has been working on for years. This legislation, which you can read here, is just now beginning to make its way through Congress, but I thought some of the above points are very interesting and show lawmakers’ continued interest in grants. Do you see anything else in the bill that you find...

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OMB Creates New Grants Policy Council

Posted by on Oct 31, 2011 in Grants & Assistance | 0 comments

The Office of Management and Budget has just created a new Council on Financial Assistance Reform to ”foster more efficient and effective federal financial management.” The council will work with the Government Accountability and Transparency Board and federal agencies to: coordinate the development and implementation of a standardized business process, data standards, and IT work with key stakeholders  to eliminate unnecessary regulatory, reporting, and grant agreement requirements and increase flexibilities for satisfying grant requirements; identify emerging issues in grants management and policy; and serve as a clearinghouse of information on innovations and best practices in grants management. The council replaces the Grants Policy Committee which was established in 1999 and the Grants Executive Board which was established 2004. I’ll keep you posted on any new developments and council actions as they...

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New Real Property Reporting Form Released

Posted by on Oct 24, 2011 in Grants & Assistance | 0 comments

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: added questions and supporting explanations regarding sustainable/green practices and energy consumption;  added an option for “encumbrance” on Attachment C “Disposition or Encumbrance Request”; and added the words “kilometers” and “meters” in questions relating to acreage and footage. Here is a link to the new form and...

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Join the Conversation About Recovery Act Oversight

Posted by on Oct 13, 2011 in Grants & Assistance | 0 comments

Log in next week (Oct. 17-24) to join an online conversation discussing ways to prevent fraud and abuse in federally funded Recovery Act programs. This week-long public dialog is sponsored by the Recovery Accountability and Transparency Board and the National Academy of Public Administration. While the scope of this discussion will focus primarily on oversight of Recovery Act funds, the sponsors are also interested in ideas related to the oversight of other federal spending that might be applicable to Recovery Act dollars. Some of the questions to be addressed include: What specific governmental, public or proprietary data sources could help the Recovery Board prevent and detect fraud, waste and abuse? What technologies or systems do you think would be effective in integrating and aggregating diverse types of data? What types of risk models would identify entities receiving Recovery Act funds as being most vulnerable to fraud, waste and abuse? What types of performance metrics could be applied to Recovery Act-funded programs and recipients to increase oversight and accountability? The board and the academy encourage a variety of participants from the general public, state and local governments, the private sector, the nonprofit field, and academia. For more information, visit the dialog’s page on Facebook or go...

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Agencies Told To Spend Remaining Recovery Money

Posted by on Sep 19, 2011 in Grants & Assistance | 0 comments

In a recent memo, the Office of Management and Budget told federal agencies to send out the remaining Recovery Act funds as quickly and efficiently as possible — or they could be returned to the federal treasury in two years.  OMB said “there remain billions in discretionary Recovery Act funds that, although they have been obligated, have not yet been outlayed. In light of the current economic situation and the need for further economic stimulus, it is critical that agencies spend these remaining funds as quickly and efficiently as possible.”  In fact, if those funds have not been spent by September 30, 2013, agencies will reclaim them. Agencies should work with grant recipients, OMB said, to accelerate the spending rate for all awarded funds while still achieving core programmatic objectives. Agencies are encouraged to reduce administrative hurdles that can delay expenditure of funds, as well as decrease delays between the receipt of invoices and the outlay of funds. Federal agencies can request waivers from the 2013 deadline in cases where contractual commitments by the grantee with vendors or subrecipients prevent adjusting the timeline or where project completion may not be possible (such as in large transportation projects). To accomplish this accelerated pace, agencies will be amending current grant award agreements and adding these deadline requirements to new grant agreements. OMB memo M-11-34 is available...

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GAO Releases “Semi-Final” Yellow Book

Posted by on Aug 24, 2011 in Grants & Assistance | 0 comments

December Update: It is now final. In mid-December, GAO released the final version of the Yellow Book. Click on the link below to access the standards, as well as a summary of the major changes. GAO just released a new version of the Yellow Book that “contains the intended content for the final 2011 Revision of Government Auditing Standards. GAO plans to formally issue the 2011 Revision Government Auditing Standards later this year after the AICPA has completed its clarity revisions.” In the 2011 revision, GAO is establishing a “conceptual framework” for making independence determinations based on each situation’s unique facts and circumstances. Auditors would identify potential risks to independence, evaluate the significance of those threats, and apply safeguards to eliminate the risks if necessary. Rather than issuing a specific list of prohibited activities, GAO offers examples of threats to independence, for example an audit organization having undue dependence on income from a particular entity or a member of the audit team entering into employment negotiations with an audited entity. The independence section also identifies specific nonaudit services that would impair auditor independence in the government environment. These include, for example, preparing accounting records or financial statements. Grants management officials may also find the new Yellow Book’s appendix helpful not only in preparing for or conducting an aduit, but also in improving overall organizational operations. As part of their responsibilities, auditors review the organization’s internal controls. In the Yellow Book, GAO provides more than a dozen indicators of internal control problems that can serve as an alert for grants management officials. GAO also offers examples of activities that could indicate fraud or abuse in government-funded programs and activities. The Yellow Book is only available online at...

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Let OMB Know What You Think About the FFR

Posted by on Jul 29, 2011 in Grants & Assistance | 0 comments

Do you have comments on the usefulness of the Federal Financial Report (SF-425), how it could be improved, other ways to collect the same information, or similar ideas about the collection of financial information? Well, OMB wants to hear from you. In the July 28 Federal Register, OMB invited comments on the renewal of the SF-425. OMB is currently not planning to make any changes to the data collection form, but in the notice, it specifically said it was interested in receiving comments on: “How the SF–425 and SF–425A are an improvement over the data collections they replaced (SF–269, SF–269A, SF–272, and SF–272A); how using a specification for a data exchange or other data model instead of structured forms could facilitate the submission and collection of the financial data identified in the SF–425 and SF–425A; and any proposals, use cases, specifications, or models for eliminating redundancies in reporting grant financial information and increasing its usefulness regardless of how the financial information is reported (form, data input, system-to-system, etc.).” Comments are due September 26 and can be sent through www.regulations.gov. Click here to read the FR...

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Comments Sought on Potential Changes to 2 CFR 220

Posted by on Jun 30, 2011 in Grants & Assistance | 0 comments

Federal agencies are asking for your help in finding ways to reduce the administrative burdens and costs associated with cost principles compliance in federally sponsored research projects. Colleges, universities, grants offices, associations, and others involved in research have until July 28 to offer their ideas. For several years, a federal interagency task force has been looking at 2 CFR 220 (Circular A-21) with respect to its application in federally sponsored research at educational institutions. That task force has gathered preliminary information on areas that could be improved, and is now inviting the public to offer their comments on these issues. Specifically, the task force is seeking input in the following areas: effort reporting, recovery of direct costs associated with administrative and project management support for investigators, institutional eligibility for the Utility Cost Adjustment, consistency among agencies that establish governmentwide F&A rates, programs with F&A reimbursement at other than governmentwide rates, rationalization between agencies of regulations and reporting requirements audits of research institutions and awards, and definitions of general and research equipment All comments must be submitted electronically to: http://grants.nih.gov/grants/guide/rfi_files/a-21/add.htm You can read the full request for information here. The task force plans to produce a summary of the suggestions by September, and will then begin to draft a set of recommendations that it will forward to OMB for...

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What’s the Future of Grants Management?

Posted by on Jun 24, 2011 in Grants & Assistance | 0 comments

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...

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More Transparency, More Reporting?

Posted by on Jun 15, 2011 in Grants & Assistance | 0 comments

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...

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What’s New in the Compliance Supplement?

Posted by on Jun 8, 2011 in Grants & Assistance | 0 comments

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...

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A-133 Compliance Supplement Is Here!

Posted by on Jun 1, 2011 in Grants & Assistance | 0 comments

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....

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Still Looking for the A-133 Compliance Supplement?

Posted by on May 11, 2011 in Grants & Assistance | 0 comments

So are we. Nearly two months ago I wrote in this blog that OMB might be close to meeting its goal of releasing the 2011 Circular A-133 Compliance Supplement by the end of March. But it’s now May and OMB has yet to publish the annual audit guidance. In fact, at the recent National Grants Management Association annual conference, OMB’s Gil Tran said it might be “several weeks” before the document is released. This would put the publication date well into mid- or late May.  Auditors, grantees. and federal program personnel who rely on the guidance — which will be effective for audits of fiscal years beginning after June 30, 2010 — will have to wait a little longer. Keep watching this post for further information. You can also learn more about A-133 audit developments and other grants management issues at Management Concepts’ Federal Grants Update seminar. Click here for more on the topics, dates, locations, and registration...

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A Few Thoughts on the CR

Posted by on Apr 14, 2011 in Grants & Assistance | 0 comments

This week Congress will vote on a continuing resolution to fund the federal government for the remainder of the current fiscal year. I’ve been looking at the proposal and noticed a few things that might be of interest to grants professionals. First, while the theme of transparency and accountability grow, Congress is planning to slash funding for electronic government initiatives by about 75 percent. This would impact sites such as USAspending.gov where the public has access to information about federal aid recipients. With only $8 million to spend on e-gov, federal officials would have to make some tough choices about which transparency sites to maintain and which ones to shut down or scale back. The second interesting tidbit is that the funding proposal would implement an across-the-board cut for all non-defense programs, but agencies would still have discretion over the funding levels for many of their individual programs. Finally, one of the federal government’s innovation efforts is being de-funded. The Partnership Fund for Program Integrity Innovation would be zeroed out, with only enough funding to cover the projects OMB already committed to. This initiative, originally funded $34 million, was intended to support innovative programs that promoted efficiency and cooperation among federal agencies and states, local governments , and nonprofit organizations. So, those are my first thoughts on this massive spending package for FY 11. Anyone else have comments they would like to...

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OMB Shutdown Guidance

Posted by on Apr 7, 2011 in Grants & Assistance | 0 comments

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...

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Management Concepts Needs Your Help

Posted by on Mar 21, 2011 in Grants & Assistance | 2 comments

We need your help to plan our upcoming class schedule and training. What classes would you like to see offered in various locations? Are there cities where you think we should offer training? What new courses or products could we offer to meet your training and professional development needs? Your answers to these and other questions will help us improve our grants management training curricula. Please take a few minutes to complete our online survey. It should only take about 5-10 minutes. We ask that you complete the survey by April 1. To access it, click here. .Your feedback is greatly appreciated and is for informational purposes only....

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CCR Troubles? You’re Not Alone

Posted by on Mar 9, 2011 in Grants & Assistance | 0 comments

According to a recent post on the Grants.gov blog, the installation of new hardware and software at the Central Contractor Registry has caused a severe processing backlog. Both new CCR registrants and those looking to renew their current registration are being affected. Although the technical problems at CCR  have been resolved, there is still a backlog and the delay could impact an entity’s ability to submit a timely grant application through Grants.gov. Applicants experiencing delays are encouraged to contact the relevant federal awarding agency for...

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Does Flexibility Equal Change?

Posted by on Mar 4, 2011 in Grants & Assistance | 0 comments

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...

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A-133 Compliance Supplement MAY be Coming Soon

Posted by on Mar 1, 2011 in Grants & Assistance | 0 comments

The Office of Management and Budget recently provided AICPA’s Governmental Audit Quality Center a draft version of the 2011 OMB Circular A-133 Compliance Supplement for review. While only AICPA members can currently access the document, it could be an indication that OMB is on track to issue the guidance very soon. In the past, the Compliance Supplement was traditionally updated each spring, but in recent years the guidance has been released later and later. The 2010 version was not posted to the OMB website until July. In response to a recommendation in a recent GAO report, OMB said its goal this year was to publish the Compliance Supplement by March 31 — and it looks like they may be...

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No Changes for Procurement Under Grants

Posted by on Jan 28, 2011 in Grants & Assistance | 0 comments

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...

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Just Announced: Federal Grants Update 2011!

Posted by on Jan 19, 2011 in Grants & Assistance | 0 comments

Information about Management Concepts’ annual Federal Grants Update seminar is now available. This one-day course is a great way to keep track of the latest developments in grants management and to learn about pending changes that may impact your day-to-day grants work. This year we’ll be discussing GPRA, subaward reporting, transparency and accountability, audit guidance, presidential and congressional priorities, and more. Classes start the first week in April and run throughout the summer in cities around the country. We can also bring the course to your location. Click here to see dates, locations, topics, and registration...

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Congress Clears GPRA Reform

Posted by on Dec 22, 2010 in Grants & Assistance | 0 comments

Congress has just approved major changes to the Government Performance and Results Act, pushing for not only better performance from federal agencies and programs, but also better reporting and more transparency. The measure calls for federal agencies to identify their top priorities, publicly report program results, and identify ineffective and duplicative federal programs. Each federal agency would designate a Chief Operating Officer and a Performance Improvement Officer with primary responsibility for pursuing cost-savings through the improved analysis and coordination of duplicative programs. These officials would also look at how to better coordinate administrative functions common to every agency, such as purchasing. However, the bill gives no specific direction to agencies on how to conduct any of these assessments. Agency and governmentwide information relating to performance is to be posted to a new public website on a quarterly basis. President Obama is expected to sign the legislation, the Government Performance and Results Modernization Act of...

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Subaward Data Beginning to Appear

Posted by on Dec 8, 2010 in Grants & Assistance | 2 comments

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...

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OMB Offers Funds for Program Innovation

Posted by on Oct 20, 2010 in Grants & Assistance | 0 comments

 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...

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Audit Review Guide Available From CIGIE

Posted by on Oct 13, 2010 in Grants & Assistance | 0 comments

Are you interested in audits? Do your job responsibilities entail audit reviews? Want to know what a quality audit looks like? The Council of Inspectors General on Integrity & Efficiency (CIGIE) has a revised Guide for Quality Control Reviews of OMB Circular A-133 Audits. The guide is a fairly easy-to-understand tool that offers a checklist of issues to consider when evaluating the quality and reliability of a single audit. It will help reviewers determine whether the audit was conducted in accordance with applicable standards and identify any follow-up work needed to support the audit report opinions. It is organized by audit standards and elements of an A-133 audit, focusing on the portions that are of most interest to federal officials. Visit the IGnet website here to download a...

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New Real Property Reporting Form Released

Posted by on Sep 28, 2010 in Grants & Assistance | 0 comments

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...

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OMB To Conduct Webinar on Transparency Act Reporting

Posted by on Sep 15, 2010 in Grants & Assistance | 0 comments

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...

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New Award Terms Set for FFATA, DUNS/CCR

Posted by on Sep 14, 2010 in Grants & Assistance | 0 comments

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...

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OMB Details Subaward Reporting

Posted by on Sep 2, 2010 in Grants & Assistance | 0 comments

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...

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GAO Invites Comments on Revised Yellow Book

Posted by on Aug 24, 2010 in Grants & Assistance | 0 comments

GAO has released the 2010 draft revisions to Government Auditing Standards (the Yellow Book). Comments on the proposed changes are due Nov. 22, 2010. The revisions consolidate many of the current Yellow Book chapters, and amend language and requirements to align with AICPA standards. But one of the most significant changes is a shift in the Yellow Book approach to auditor independence. Rather than establishing a specific list of “do’s” and “don’ts”, GAO is proposing a “conceptual framework” for making independence determinations based on each situation’s unique facts and circumstances. Auditors would identify potential risks to independence, evaluate the significance of those threats, and apply safeguards to eliminate the risks if necessary. The independence section also identifies six specific nonaudit services that would impair auditor independence in the government environment. The draft Yellow Book is only available in online PDF format. Click here to view the draft and for instructions on submitting...

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2010 Compliance Supplement Released

Posted by on Jul 30, 2010 in Grants & Assistance | 0 comments

The 2010 A-133 Compliance Supplement is now available on the OMB website. As usual, changes have been throughout the guidance to reflect new statutory and regulatory requirements, and to make technical and clarifying revisions. But perhaps the most important change, at least for this year, is the information on the Recovery Act and its impact on single audits. The Recovery Act discussion is found in Appendix VII, which is called a rather vaguely named  “Other OMB Circular A-133 Advisories.” The guidance addresses the impact of these new funds on the SEFA, major program determination, and risk assessment. I’ll post more information once I have looked through the supplement, but for now, I just wanted to alert everyone to the...

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Obama Signs Improper Payments Act

Posted by on Jul 26, 2010 in Grants & Assistance | 0 comments

President Obama has signed the Improper Payments Elimination and Recovery Act of 2010, requiring federal agencies to identify programs most at risk of improper payments, take steps to address those risks, and use a variety to tools to recapture payments that were made in error.  Specifically, the head of each federal agency must review agency programs and activities every three fiscal years and identify those that are susceptible to “significant” improper payments. Significant improper payments are those that total either $100 million, or 2.5 percent of total program outlays for programs expending $10 million or more per year. Agencies must explain why the programs are at risk, what steps it plans to take to reduce those risks, and the resources it has or needs in terms of personnel, technology systems, and internal controls. The plans will also describe how agency managers, programs, and where appropriate, state and local governments, are held accountable for preventing, detecting and recovering improper payments.  The new legislation (PL 111-204) also focuses on the use of recovery audits to return improper payments to federal agencies. Also, under the measure, agencies may keep the funds that are recaptured through recovery audits rather than returning them to the Treasury. The money may be reinvested back into the original program, used for agency OIG activities, or support financial management improvement...

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AGA Recap

Posted by on Jul 15, 2010 in Grants & Assistance | 0 comments

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...

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Agencies Ordered to Check ‘Do Not Pay’ Lists Before Making Awards

Posted by on Jun 21, 2010 in Grants & Assistance | 0 comments

In an effort to stem payments to ineligible individuals and entities, President Obama has ordered federal agencies to check nearly half a dozen existing databases before making any financial assistance award – including grants. In a June 18 presidential memo, Obama said that in the preaward phase, agencies must consult, where appropriate, the Social Security Administration’s Death Master File, the General Services Administration’s Excluded Parties List System, the Department of the Treasury’s Debt Check Database, the Department of Housing and Urban Development’s Credit Alert System or Credit Alert Interactive Voice Response System, and the Department of Health and Human Services’ Office of Inspector General’s List of Excluded Individuals/Entities. OMB will issue guidance on exactly how agencies can meet the new preaward requirements and on the impact the eligibility check will have on funding decisions. The memo also directs OMB to coordinate these databases, a so-called “Do Not Pay List,” with the new Federal Awardee Performance and Integrity Information System (FAPIIS) so that agencies can access them through a single entry point. (FAPIIS was mandated by the 2009 Defense Authorization Act and will include information about contractors and grantees (and subcontractors and subgrantees) that receive more than $10 million in federal assistance. Those recipients will have to provide information about any criminal convictions, civil penalties, or administrative actions against them. Self-reporting of that information would be included as a term and condition in grant awards.) To view the presidential memo, click...

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OMB Tells Agencies To Cut 5 Percent From FY 12 Budgets

Posted by on Jun 9, 2010 in Grants & Assistance | 0 comments

President Obama’s themes of tying performance to funding, and tightening the discretionary budget belt will carry forward into fiscal year 2012 and beyond. In June 2010, OMB issued budget guidance to federal agencies that are now working to develop their FY 12 budget requests for submission to OMB. The guidance, which came in the form of two memos, directs agencies to “identify the programs and subprograms that have the lowest impact on your agency’s mission and constitute at least five percent of your agency’s [FY 10] discretionary budget.”  In Memo M-10-19, OMB noted that agencies should not simply reduce spending across the board. Instead, agencies should aim to restructure their operations strategically. This should include eliminating low-priority programs and activities, re-engineering staffing plans, improving procurement and grants management processes, and strengthening IT and financial management.  A follow-up memo, M-10-20, gave more insight into how these reductions are to be achieved. Agencies are to evaluate programs based on their impact on the agency’s mission and relevant administration initiatives. Agencies should consider whether the program has an unclear or duplicative purpose, uncertain federal role, a completed mission, or lack of demonstrated effectiveness, according to the June guidance. The intent is to identify those programs with the lowest impact. OMB emphasized that agencies were not to meet the five-percent low-priority program target with across-the-board reductions or incremental savings in administrative costs. You can view both of the memos on OMB’s website. Also, remember that these and other recent developments in grants administration will be covered in our Federal Grants Update 2010 seminar which is currently running in locations around the country. [1]      OMB Memo 10-19, Fiscal Year 2012 Budget Guidance, 8 June...

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OPM Plans New Grants Management Series

Posted by on May 26, 2010 in Grants & Assistance | 0 comments

The federal government’s Office of Personnel Management (OPM) is circulating a proposed job classification series that would specify and standardize the use of the job title “Grants Management Specialist.” Federal law requires OPM to establish official position titles to include a basic title (e.g., Grants Management Specialist) and optional titles such as “lead” or “supervisor”. Agencies must use the official position titles for human resources management, budget, and fiscal purposes. According to the draft, the so-called Grants Management Series 1109 would include positions which “manage, supervise, lead, or perform administrative business and analytical work involving: (1) the management, award, and obligation of funds for federal assistance such as grants, cooperative agreements, and other related assistance and services using financial, administrative, business, and negotiation procedures; (2) the competitive or non-competitive evaluation of grants proposals; and (3) the administration or termination, and closeout of grants.” The draft then goes on to list nearly 20 typical job duties of a grants management specialist. You can read the full draft job classification here. Comments may be submitted until June 25 to...

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HHS Invites Comments on Proposed Conflict of Interest Regs

Posted by on May 21, 2010 in Grants & Assistance | 0 comments

The Department of Health and Human Services is planning to overhaul its researcher financial conflict of interest regulations and is inviting public comment on the proposed changes. Among other things, the changes would expand the scope and coverage of the regulations, amend the definition of “significant financial interest”, expand research institutions’ responsibilities for identifying and managing conflicts of interest, and strengthen the federal government’s oversight roles and responsibilities. The conflict of interest regulations are intended to help ensure that there is no bias in the design, conduct, or reporting of government-funded research due to financial relationships between researchers and the private sector. But with the growing inter-relationship between academia, government, researchers, and the private sector, HHS said there is a need to revamp the regulations. According to HHS, financial support of biomedical research increased from $37.1 billion in 1994 to $94.3 billion in 2003, and more than half of the funding in 2003 came from industry sources. At the same time, relationships between academic researchers and industry have also increased from 28% in a 1996 survey to 53% in 2007. You can view the full Federal Register notice by clicking here. The notice includes information on how to submit comments, which are due July...

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Once More, From OMB…

Posted by on May 5, 2010 in Grants & Assistance | 0 comments

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...

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All Agencies Must Move Back to Grants.gov

Posted by on Apr 27, 2010 in Grants & Assistance | 0 comments

In a new memo, OMB has directed all federal agencies to once again begin using Grants.gov now that the portal has been upgraded and is capable of handling a large influx of proposals. The system was overwhelmed last year after enactment of the Recovery Act, and OMB had allowed agencies to move away from Grants.gov and to use alternative methods for receiving applications. But according to the memo, recent upgrades and planned improvements have alleviated any risk that Grants.gov might fail and all agencies must move back to Grants.gov for receipt of applications by the end of April. OMB also notes in the memo that the departments of Energy and Interior are conducting a “proof of concept” that would use the FedBizOpps.gov contracting platform for grants. However, OMB gave no details about the effort and said it expects to have results of the test sometime this...

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Let Us Know What You Think

Posted by on Apr 14, 2010 in Grants & Assistance | 1 comment

We need your help to plan our schedule for next year. What classes would you like to see offered in various locations? Are there cities where you think we should offer training? What new courses or products could we offer to meet your training and professional development needs? Your answers to these and other questions will help us improve our grants management training curricula. Please take a few minutes to complete our online survey by clicking here. Your feedback is greatly appreciated and is for informational purposes only....

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OMB Tells Agencies to Begin Posting FFATA Subaward Data

Posted by on Apr 7, 2010 in Grants & Assistance | 0 comments

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...

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Obama Calls for Tough Action Against Nonreporters

Posted by on Apr 7, 2010 in Grants & Assistance | 0 comments

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...

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Is Grants Management a Government-Only Function?

Posted by on Mar 31, 2010 in Grants & Assistance | 0 comments

If you would like to voice your opinion on this question, now is your opportunity. The Office of Management and Budget is seeking input about what constitutes “inherently governmental” functions as it works to develop new guidance for determining whether federal agencies should contract out certain tasks or whether the work should be performed by government employees. Some activities seem obviously governmental, such as hiring federal workers or establishing federal policy, but other areas are less clear. And while much of the attention is directed toward the role of contractors and procurement actions by federal agencies, there is also a question about grants management responsibilities. Specifically, OMB’s Office of Federal Procurement Policy wants to know whether the new guidance should say anything new about the use of contractors to manage federal grantees. Comments are due June 1. The Federal Register notice is available by...

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OMB Amends 2 CFR Part 176

Posted by on Mar 26, 2010 in Grants & Assistance | 0 comments

Wow, it’s been a busy week in the area of grants management… On March 25, OMB amended 2 CFR Part 176 – the award term for the Recovery Act – to reflect changes in U.S. policy regarding Buy America requirements as they relate to international agreements with certain countries. Specifically, OMB has amended the threshold that applies to international Buy America agreements, added an international agreement to the Buy America policy, and added a country to an existing agreement. If you’re interested, you can view the Federal Register announcement here. And remember, all of these changes I’ve discussed in my recent blogs are covered in our Federal Grants Update course. To view dates and locations, click...

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Comments Invited on Personal Property Reporting Form

Posted by on Mar 26, 2010 in Grants & Assistance | 0 comments

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...

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OMB Issues More Recovery Act Guidance; Focuses on Audits

Posted by on Mar 26, 2010 in Grants & Assistance | 0 comments

Just days before the next Recovery Act reporting cycle begins, OMB has issued further reporting guidance for federal agency personnel and recipients. In the March 22 memo, OMB addresses data quality, technical issues, and the importance of single audits, among other topics. Some of the specific items covered in the memo include the actions federal agencies must take during the new “continuous corrections” phase of the reporting cycle, a new category of data quality that federal officials must now review, immediate actions that should be taken to review and act on single audit findings, and for recipients, technical issues such as when a report is considered to be the “final” report. And in the area of single audits, there is an interesting note. Because of the need to quickly review and act on audits, OMB has told federal agencies not to grant any requests for A-133 filing extensions. OMB says it realizes the April reporting period is fast approaching and that it will respond to questions and concerns in a timely manner. You can download the new guidance...

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Court Says ACORN Funding Ban is Unconstitutional

Posted by on Mar 22, 2010 in Grants & Assistance | 0 comments

A federal district court has ruled that Congress’ ban on funding for the controversial ACORN organization is unconstitutional, and OMB has rescinded an October 2009 memo that had directed agencies to stop funding the nonprofit. Here’s a little background:  ACORN is a nonprofit social justice organization that conducts voter registration campaigns, offers free tax return preparation for low-income individuals, provides low-income housing counseling and similar community development projects. However, the group and its affiliates came under fire after hidden cameras allegedly captured ACORN employees giving advice on how to operate a prostitution ring, avoid federal taxes, and engage in other illegal activities. As a result Congress stopped ACORN funding and ACORN sued, claiming Congress unconstitutionally convicted the organization of a crime without a trial, which is a “bill of attainder.” The court agreed that indeed Congress’ action constituted a bill of attainder and ordered OMB to rescind its October memo and to direct all federal agencies to inform their grantees and contractors of the court’s ruling. You can read the OMB memo and the court ruling here. The Justice Department plans to appeal the...

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Recovery Act Programs Taxing Federal Resources

Posted by on Mar 16, 2010 in Grants & Assistance | 0 comments

A new report confirms what most of you in grants management probably already knew: implementation and administration of Recovery Act programs has put a strain on the federal grants workforce. The Recovery and Accountability Transparency Board surveyed the 29 agencies charged with handing out Recovery Act funds. Review of Contracts and Grants Workforce Staffing and Qualifications in Agencies Overseeing Recovery Act Funds showed that most agencies felt staffing was inadequate to operate Recovery Act programs, or that if the staffing level was adequate, administration of Recovery Act programs adversely impacted the administration of non-Recovery Act programs. The impact on both Recovery and non-Recovery Act programs included award delays, decreased postaward monitoring, increased staff hours, and use of supplemental staff. The board also looked at the training and qualifications of grants staff, and noted that there is no governmentwide qualification or training requirements for the grants workforce. Only about 8 percent of the grants officers, 50 percent of grants program managers, and 29 percent of grants specialists work in agencies that will have implemented agency-specific training and continuous learning requirements by June 2010. Without a common certification and continuous learning program, the report said it is difficult to determine whether the qualification requirements and training of the grants workforce are adequate. You can view the full report...

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After a Year, GAO Sees Improvement in Recovery Act Accountability, But Still Room for Improvement

Posted by on Mar 3, 2010 in Grants & Assistance | 0 comments

Now that the Recovery Act is one year old, the Government Accountability Office is taking a look back — and a look forward — at how state and local agencies have used the money they received, and the efforts being made to improve accountability for those awards. Most of the nearly 200-page report deals with specific programs and agencies, including Medicaid, Transportation, and Education, but GAO also addresses issues relating to recipient reporting, and a significant amount of attention to the OMB A-133 single audit process. GAO seems generally pleased with OMB’s efforts to use single audits, although the office continues to urge OMB — and Congress — to amend the single audit process so that it can be more efficient and timely. And GAO has several agency-specific recommendations, such as encouraging the Education Department to work with OMB on a formula for determining FTE jobs during the summer months. One new recommendation that should be of interest to most recipients is that OMB develop a “formal and feasible” framework for review of recipient reporting changes during the continual update period and consider providing more time for agencies to review and provide feedback to recipients before posting updated reports on Recovery.gov. You can read the full GAO report...

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OMB Invites Comments on New 2 CFR Parts

Posted by on Feb 23, 2010 in Grants & Assistance | 0 comments

The Office of Management and Budget is accepting comments on a set of proposed regulations that would impact several parts of the governmentwide grants administration process. While the impetus for the proposed new rules is a legislative mandate to create a governmentwide database of information about large, potentially high-risk grantees, OMB’s proposal also addresses other areas, especially preaward. It represents the office’s ongoing efforts to relocate governmentwide guidance into one central location – Title 2 of the Code of Federal Regulations. In many cases OMB’s proposal would simply codify existing policy. For example, a proposed new 2 CFR Part 25 would implement existing OMB guidance regarding the use of DUNS numbers. This guidance is currently in two separate OMB policy memoranda. This is just one example of what is included in the proposed regulations; there are many others. The proposal would create or amend 2 CFR Part 25, DUNS/CCR registration; 2 CFR Part 27, program announcements; 2 CFR Part 35 postaward responsibilities; 2 CFR Part 77, termination; and 2 CFR Part 180, suspension and debarment. As for the new database (mandated by the 2009 Defense Authorization Act) it would include information about grantees and subgrantees that receive more than $10 million in federal assistance. Those recipients would have to provide information about any criminal convictions, civil penalties, or administrative actions against them. Self-reporting of that information would be included as a term and condition in grant awards. Comments are due April 19. To read the full OMB announcment, click here. The proposed changes, along with other Title 2 developments, will be covered in our upcoming Federal Grants Update 2010 seminar. For dates and locations, click...

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Here’s an Update on Federal Grants Update 2010

Posted by on Feb 8, 2010 in Grants & Assistance | 0 comments

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...

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Standard Research Report About to Hit the Streets

Posted by on Jan 15, 2010 in Grants & Assistance | 0 comments

The National Science Foundation – on behalf of the Grants Policy Committee and the Research Business Models Subcommittee – is accepting final comments on the new governmentwide Research Performance Progress Report (RPPR) format, while at the same time putting the format out for use by federal agencies. In a Federal Register announcement, NSF said agencies may now use the new standard format, which is designed to help streamline the reporting process for grantees as well as allow federal awarding agencies to more easily analyze, compare, and compile research program information. NSF says it expects this to be the last opportunity for public input before the reporting format is finalized. Comments may be submitted until February 12 via email to Suzanne Plimpton, splimpton@nsf.gov. You can access the FR notice inviting comments here. Our annual Federal Grants Update seminar will have additional information about this new report, as well as other developments in grants management. Dates and locations of the one-day seminar will be announced soon. Watch this blog or visit our website www.managementconcepts.com/grants for future...

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How Would You Improve Grants.gov?

Posted by on Jan 12, 2010 in Grants & Assistance | 0 comments

The Grants Policy Committee is preparing a response to a GAO report about the timeliness of grant application submission through Grants.gov, and they want help from the public. The GPC’s Preaward Workgroup is drafting an OMB response to the July GAO Report, “Grants.gov Has Systemic Weaknesses That Require Attention.” This workgroup is specifically focusing on the GAO recommendation regarding the timeliness of applications. Some of the issues being addressed by the GPC workgroup include what constitutes a timely application, how to notify applicants regarding the timeliness of applications, and handling of late applications. While this is not a formal request for comments from the workgroup, it is an outreach effort designed to gather input from the grants community and offer stakeholders the opportunity to have their concerns and ideas reflected in the official OMB response. Input can be provided through the GPC website at...

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New Recovery Act Guidance Addresses Data Quality, Nonreporters, and Jobs

Posted by on Dec 21, 2009 in Grants & Assistance | 1 comment

Well, as most of the nation’s capital braced last week for a weekend blizzard, the Office of Management and Budget was busy releasing new guidance on the Recovery Act reporting requirements. The memo released late Friday afternoon targets three areas: steps that federal awarding agencies must take to ensure the quality of data being reported by Recovery Act recipients; how federal agencies are to deal with recipients who have not reported or who have persistent reporting problems; and how recipients are to calculate and report the number of jobs created or saved with Recovery Act dollars. For example, federal agencies are now required to provide recipients with a specific list of data about their awards, such as award type, amount, award number, CFDA number, federal agency number, and TAS (Treasury Account Symbol) code. OMB also offers guidance on how agencies are to assess late and non-reporters, and how to submit that list, which will be published on Recovery.gov. The interesting aspect of the guidance for recipients is that OMB has offered detailed, step-by-step instructions and examples for calculating jobs. Further, recipients are no longer required to report cumulative jobs data, but rather simply job information for the reporting period.  You can view the new memo...

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Grants Management Reform Bill On The Move

Posted by on Dec 15, 2009 in Grants & Assistance | 0 comments

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...

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States, Locals Invited To Comment on What Works

Posted by on Dec 11, 2009 in Grants & Assistance | 1 comment

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...

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OMB Again Tells Agencies to Focus on Recovery Act Reporting

Posted by on Dec 2, 2009 in Grants & Assistance | 0 comments

Once again, the Office of Management and Budget is directing federal awarding agencies to step up their efforts to ensure recipients meet their reporting responsibilities under the Recovery Act. And for those recipients who don’t comply, federal agencies will be taking action. In a new memo, OMB Director Peter Orzag says that while a large number of recipients did report on Recovery Act projects in the first reporting period, a significant number failed to do so. He reminded federal agencies that failure to report constitutes noncompliance with grant award terms and conditions, and may have serious consequences. To address the issue, federal agencies must take further steps to ensure Recovery Act recipients understand their reporting responsibilities as well as the consequences of noncompliance. Agencies must not only identify each recipient that has not submitted timely reports, but must also contact these organizations, assess the severity of the noncompliance and determine what corrective actions are to be taken – up to and including termination of funding. To read the OMB memo, click...

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Agencies May Still Have To Pay ACORN

Posted by on Dec 1, 2009 in Grants & Assistance | 0 comments

Just a quick follow-up to the ACORN posting from last week. The Justice Department in a new memo said the recent law that prohibits funding for the controversial nonprofit does not prevent federal agencies – specifically HUD – from honoring existing contractual obligations with ACORN. The fiscal 2010 Continuing Appropriations Resolution states, “None of the funds made available by this joint resolution or any prior act may be provided to [ACORN], or any of its affiliates, subsidiaries or allied organizations.” Justice said the language used by Congress is unclear and can be read several ways. The memo says lawmakers did not use correct appropriations terminology, instead relying on the word “provide” which has no specified meaning in federal appropriations law. For those of you interested in this and related topics, Management Concepts offers a a one-day course, Appropriations Law for Federal Grants.  ...

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Are There “Minimal” Value Single Audits?

Posted by on Nov 24, 2009 in Grants & Assistance | 0 comments

President Obama’s most recent Executive Order aimed at reducing improper payments by federal agencies includes an interesting item. Not only does it direct OMB to examine the effectiveness of single audits in detecting and preventing improper payments, but it also asks for recommendations on how to “streamline or eliminate single audit requirements where their value is minimal.” Most of the Executive Order is aimed at identifying which federal programs are most vulnerable to improper payments, setting targets and action plans for reducing those erroneous assistance awards, and establishing individual accountability responsibilities for federal agencies. But in Section 4 of the order, Obama tells OMB to work with state and local governments to reduce improper payments. The agency is to establish two working groups that include representatives from state, local, and federal government entities. One will make recommendations for administrative actions designed to improve the incentives and accountability of state and local governments for reducing improper payments. The other group will focus on single audits. Both working groups are to be established within one month and must submit their recommendations within six months....

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ACORN and Federal Grants

Posted by on Nov 23, 2009 in Grants & Assistance | 0 comments

Many of you may have been following the ACORN story with interest, but now I’m wondering if the actions of the beleaguered nonprofit might have a potentially broader impact on federal grants. ACORN is a nonprofit social justice organization that conducts voter registration campaigns, offers free tax return preparation for low-income individuals, provides low-income housing counseling and similar community development projects. In recent months, however, the group and its affiliates have come under fire after hidden cameras allegedly captured ACORN employees giving advice on how to operate a prostitution ring, avoid federal taxes, and engage in other illegal activities. As a result, among other things Congress stopped ACORN funding, and in turn, ACORN is suing the federal government. It is claiming that Congress is unconstitutionally convicting the organization of a crime without a trial. So I asked one of our instructors, Ed Levin, a lawyer who teaches  many of our grants law classes, what he thought about the case and its impact. Here’s what he said: “According to news accounts, the ACORN suit named as defendants a number of federal agencies (including OMB and HUD), in a case brought in Brooklyn federal court. As a result of the Congressional action, ACORN claimed, private funding and credit support has also been withheld, threatening the very survival of the organization. “The suit alleges that resolutions passed in the U.S. House of Representatives declare ACTION guilty of a crime and punishes the organization without a trial. If proven, this action would be a “bill of attainder” forbidden under the U.S. Constitution (Art. I, sec. 9, cl. 3). Most legal commentators sugggest it will likely be difficult for ACORN to prevail, because the Constitutional prohibition is aimed at punitive measures and presmedly would not apply to the government’s discretionary grant programs.” It will be interesting to see how this all turns...

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A New Look at Performance Measures?

Posted by on Oct 30, 2009 in Grants & Assistance | 0 comments

The newly formed bipartisan Senate Budget Committee Task Force on Government Performance held its first hearing yesterday, with testimony from several experts on government efficiency, including the new OMB Deputy Director for Management Jeffrey Zients. While several themes were discussed, most were not new ideas or concepts. However, there are two I thought interesting. First, legislators are attempting to play a role in measuring performance, not just in their role of developing the federal budget, but also to instill some form of continuity in the program management system. Several speakers noted the problems that arise when a new measurement system is implemented with each new administration. And in fact, Zientzs said the Obama administration is working to create a revamped system of setting goals and measurements that is more outcomes-based than previous efforts. But he said the administration doesn’t plan to “throw the baby out with the bath water” but will instead build upon and use those aspects of GRPA and PART that are effective. Second, the administration and legislators both agree there should be some form of accountability – and even penalties and incentives –  built into a new program management system. The task force hearing can be viewed online by clicking...

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What Will Become of GPC?

Posted by on Oct 23, 2009 in Grants & Assistance | 0 comments

It seems there are discussions about merging the Grants Policy Committee and the Grants Executive Board in an effort to coordinate the two aspects of the federal grants community. As its name implies, the GPC is in charge of establishing policies to implement grants streamlining efforts. The GEB, on the other hand, has authority over the business side of the streamlining effort, including Grants.gov and the Grants Management Line of Business. But soon the two boards may merge into one. Tom Cooley, chair of the GPC, said at a recent National Grants Partnership webinar that there are plans to merge the two so that policy people talk to program people, and they talk to IT people, etc. Sounds like a good idea to...

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First Agency to Incorporate New FFR

Posted by on Oct 8, 2009 in Grants & Assistance | 0 comments

In tomorrow’s (Thursday) Federal Register, the US Agency for International Development will publish a notice amending its grants management regulations to reflect the governmentwide switch to the new Federal Financial Report (SF-425/425A). OMB developed the new form as a standard reporting format for all federal assistance recipients, replacing the (Financial Status Report  (SF-269/269A) and the Federal Cash Transaction Report (SF-272/272A). Federal agencies were to begin using the new SF 425/425A no later than Oct.1 of this year, and several have. But as far as I know, AID is the first agency to officially amend its regulations to accommodate the new form. In the announcement, AID says, “As published, the regulation unduly limits the use of financial reporting forms to Standard Form 269 and Standard Form 270. The purpose of the amendment is to relieve this restriction and allow any such forms as OMB...

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A More Open Federal Register

Posted by on Oct 6, 2009 in Grants & Assistance | 0 comments

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...

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Are You Texting? Wait a Minute…

Posted by on Oct 5, 2009 in Grants & Assistance | 0 comments

President Obama has prohibited federal employees from texting while they drive, but the ban may not stop there: federal agencies will now be “encouraging” their recipients and subrecipients to also ban employee texting while on government (or company) business or in government vehicles. The Executive Order, issued October 2, prohibits federal employees from text messaging while driving on official government business or while in government-owned vehicles. It also directs federal agencies to consider adopting education and awareness activities about the dangers of texting while driving. But agencies now must also “to the extent authorized by applicable statutory authority” encourage recipients and subrecipients to adopt similar text messaging bans and to begin their own outreach and prevention  activities. I’m not sure how this will play out – or if we’ll see any impact at all on federal grants – but it will be interesting to...

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Agencies To Help Grantees Report on Recovery Act

Posted by on Sep 14, 2009 in Grants & Assistance | 0 comments

Registration on the new FederalReporting.gov website – where grantees must post information about their work under the Recovery Act – is lagging and OMB wants federal agencies to help. In a just-released memo to federal agencies, OMB outlined three steps that federal agencies must “take immediately” to help recipients and subrecipients register with and submit information to FederalReporting.gov. First, agencies are to begin targeted outreach to remind recipients of their reporting and registration obligations. OMB noted in the memo that current registration numbers on FederalReporting.gov are below expectations and that this could lead to underreporting as the October 10 reporting deadline approaches. Second, OMB has told agencies to provide in-kind resources for a new government-to-government initiative set up by OMB and the Recovery Act Accountaiblity Board. This effort will  supplement existing technical assistance resources to specifically help state and local governments meet their reporting responsibilities. Finally, agencies must label recipient registration and reporting delays as a potential agency risk and idenitify steps to mitigate that risk. To read the full OMB memo to federal agencies, click...

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Just a Reminder…

Posted by on Aug 20, 2009 in Grants & Assistance | 0 comments

That the new website FederalReporting.gov is now live and both federal agencies and recipients of Recovery Act funds are being encouraged to complete the one-time registration. Although reporting will not begin until October, agencies are encouraged to register now, well in advance of the October date. The new site is where recipients will submit the required Recovery Act funding and project reports and where federal agencies will review and comment on the information before it is posted to the public Recovery.gov website. FederalReporting.gov has an FAQ section, a page where you can download reporting templates, general information about the site and about the Recovery Act, and  a live chat feature for those who need assistance...

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Here’s a Handy Recovery Act Checklist

Posted by on Aug 6, 2009 in Grants & Assistance | 0 comments

The online newsletter Government Executive has posted a checklist that may be useful for those responsible for monitoring or administering Recovery Act grants. The list summarizes the major reporting requirements for the next three months, organized by deadline date. You can view the checklist...

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OMB Posts New Recovery Act Audit Guidance

Posted by on Aug 6, 2009 in Grants & Assistance | 0 comments

OMB has published additional guidance for auditing Recovery Act programs and signaled that even more is on the way. The guidance was published as an addendum to the 2009 OMB Circular A-133 Compliance Supplement and is now available on OMB’s website. The guidance goes into detail on a number of issues  related to auditing these new programs, such as checking allowable and unallowable activities. However, it still does not address one of the more complicated areas of Recovery Act program administration: reporting. OMB says “at this time, the reporting area indicates only that more substantive coverage of ARRA reporting will be covered in the next Compliance Supplement addendum.” We’ll let you know as soon as that additional addendum is released. If you’re interested in learning more about federal grants auditing, check out Management Concepts’ two-day course, Audit of Federal Grants and Cooperative Agreements. Also, our annual Federal Grants Update course is still being offered in locations around the...

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OMB Clarifies Recovery Act Lobbying Restrictions

Posted by on Jul 28, 2009 in Grants & Assistance | 0 comments

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...

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Get Ready To Register

Posted by on Jul 21, 2009 in Grants & Assistance | 0 comments

I’m listening to one of OMB’s Recovery Act reporting training webinars and wanted to alert everyone to an important upcoming date they just announced: on August 17, registration will open on the new FederalReporting.gov site. All federal awarding agencies, prime recipients, and designated subrecipients must register with the system in order to submit, review, post, and correct the reports required under the Recovery Act. Entities are encouraged to register early on FederalReporting.gov; ideally at least 45 days before the Ocotber reporting period begins. I’ll post any additional information about the Recovery Act training webinars throughout the...

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Grants.gov: Good, but Could be Much Better

Posted by on Jul 15, 2009 in Grants & Assistance | 0 comments

While Grants.gov has made the grants process somewhat easier for both federal awarding agencies and potential applicants, the Government Accountability Office says the web portal has systemic problems that need to be addressed. GAO’s report echoes many previous reports about Grants.gov. For federal agencies, the benefits of using Grants.gov include eliminating the need to develop agency-specific electronic systems and making their funding opportunities available to a wider audience. For grantees, the online search and apply portal reduces paperwork and offers access to a wider array of grant opportunities. And both benefit from faster application processing. But a “cumbersome” registration process and “uneven” system performance often result in frustration for grantees and late applications. At the federal level, a lack of clear, written policy regarding who is responsible for what on Grants.gov, as well as the “pass-the-hat” voluntary method of funding the system often cause problems, GAO says. In the report, GAO makes four recommendations, again, most of which may sound familiar to those in the grants world. They include for example, urging OMB to work with federal agencies to ensure that Grants.gov is properly funded, and establishing a stakeholder group to improve communications.  To read the full report, click...

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Recovery Act Training Details Announced

Posted by on Jul 10, 2009 in Grants & Assistance | 0 comments

OMB has just announced the dates (July 20-23), topics, and registration information for the Recovery Act reporting webinars. The two-hour sessions are intended for federal agencies, prime recipients, and subrecipients,  and will focus on major sections of the reporting guidance published on June 22. For information or to register, go to the Recovery.gov...

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Training on Recovery Act Reporting Coming Soon

Posted by on Jul 8, 2009 in Grants & Assistance | 0 comments

During the week of July 20, federal officials plan to conduct a series of web-based training sessions covering the recently issued Recovery Act reporting guidance (see blogs below). The sessions will be aimed at helping recipients and subrecipients understand the new reporting guidance issued June 22 and the online technologies that will be used for the reporting. We have no information yet on when, where, or what these sessions will entail, but we wanted to give everyone a heads-up about the training. I’ll post more information once it’s...

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Some Notes About the New Reporting Guidance

Posted by on Jun 30, 2009 in Grants & Assistance | 0 comments

Tucked inside OMB’s latest guidance on Recovery Act reporting are several items of interest that I wanted to point out. First, there should be an addendum to the 2009 Circular A-133 Compliance Supplement coming out very soon. OMB provided a list of all Recovery Act guidance, including an “Addendum to the Single Audit Compliance Supplement – American Recovery and Reinvestment Act” that should be out by June 30. I haven’t seen it yet, but will let everyone know when it appears. OMB’s new guidance also said it reviewed the Obama Administration’s new policy on communications with lobbyists regarding Recovery Act funds and is preparing to issue revised guidance. Although there is no official word on what the revisions will be, in In a blog post on May 29, Norm Eisen, Counsel to the President for Ethics and Government Reform, said the ban on oral communications will be expanded to include not only federally registered lobbyists, but other individuals who have already submitted applications for Recovery Act funds. It’s not quite clear what exactly this means or what impact it will have on applicants, but Management Concepts will be analyzing this when it happens. Finally, under the new reporting guidance, there is no “global requirement” for reporting data for the period ending June 30 but the information must still be collected. This will give federal agencies, OMB, and recipients a chance to clarify logistics and correct problems before the October reporting period. OMB and the Recovery Act Board say they will host forums, meetings, and pilots relating to Recovery Act reporting in July. At the Association of Government Accountants conference in New Orleans last week, my colleague heard that OMB would be presenting a series of training webinars on each “topic” in the Reporting guidance. As always, our Federal Grants Update course will give you more detail on the ever-changing Recovery Act guidance, as well as other developments in the grants management...

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OMB Aims to Clarify Recovery Act Reporting

Posted by on Jun 23, 2009 in Grants & Assistance | 0 comments

On 22 June 2009, the Office of Management and Budget issued additional guidance intended to help recipients, pass-through entities, subrecipients, and federal agencies meet the reporting requirements of Section 1512 of the American Recovery and Reinvestment Act. The guidance was issued as a memorandum to federal agencies, and is available at the OMB website . From this site you can also download a list of the programs that are subject to the Recovery Act’s reporting requirements, as well as a sample Excel spread-sheet that can be used as a model for reporting. The guidance addresses an array of issues, ranging from federal agencies’ oversight responsibilities and prime recipients’ responsibilities, to ensuring data quality and defining “jobs” for reporting purposes. I’ll be posting more information about the new guidance very soon, but I wanted to give everyone a heads-up about the new release. Stay...

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OMB Moves Drug-Free Guidance to Title 2

Posted by on Jun 17, 2009 in Grants & Assistance | 0 comments

The Office of Management and Budget has placed the final drug-free workplace guidance for grants and cooperative agreements in a new Title 2 CFR Part 182, a move that continues the government’s efforts to consolidate grants policy into one central location. The drug-free workplace guidance in Part 182 is virtually the same as the common rule currently being used by federal agencies and makes no substantive change to existing policies and procedures. The office originally announced its intention to move the governmentwide guidance in September 2008. Now with the issuance of the final guidance, each federal  awarding agency will publish a rule in its own chapter of 2 CFR to adopt the OMB governmentwide guidance and remove the full text of the November 2003 common rule from its CFR chapter. This agency codification gives OMB’s guidance the force of regulation on that agency’s grants and recipients. The Federal Register notice announcing the drug-free guidance final move to 2 CFR Part 182 was published June 15 and is available by clicking...

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OMB Advises on Federal Recovery, Transparency Reporting

Posted by on Jun 3, 2009 in Grants & Assistance | 0 comments

The Office of Management and Budget just gave federal agencies guidance on how to report both Recovery Act and Transparency Act data to USAspending.gov, the site created as a searchable, single database where the public can find detailed information about federal awards. Much of the new “operational guidelines” are technical in nature, dealing with issues such as required formatting and submission methods. However, OMB also  explains one reporting question that arose under the Recovery Act: aggregate reporting for small awards. The Recovery Act requires reporting on all funding, but allows for reporting of awards under $25,000 and awards to individuals as aggregates. According to OMB’s guidance, an aggregate record is created by taking a group of similar records and tallying the dollars based on a specific set of data fields to create one summary (or aggregate) record. Agencies should strive to submit as much information as possible under $25,000 at a transaction level, OMB says, but if reporting information under $25,000 poses a significant administrative burden on agencies, they can also report these amounts as county aggregates instead. While aggregate reporting is only required for Recovery Act funds, and not under the Transparency Act, OMB advises agencies to begin including aggregate information for all funding types to provide maximum transparency to the public. You can read the OMB memo to federal agencies by clicking...

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A-133 Compliance Supplement Addresses Recovery Act , Sort of

Posted by on May 27, 2009 in Grants & Assistance | 0 comments

The Office of Management and Budget on Tuesday released the annual Circular A-133 Compliance Supplement, offering auditors and federal assistance recipients an updated resource for meeting their responsibilities under an A-133 audit. However, because of the “limited time” between enactment of the American Recovery and Reinvestment Act and the issuance of the 2009 supplement, the guidance does not fully incorporate the requirements resulting from the massive economic stimulus package. Instead, OMB has included a brief appendix (Appendix 7) that highlights some areas of importance to A-133 audits, such as the impact on determining major programs, reporting on the Schedule of Expenditure of Federal Awards, and award terms and conditions and related compliance requirements. As additional information becomes available, OMB plans to issue addenda to the supplement. A link to the online Compliance Supplement Table of Contents is available by clicking here. If you’re interested in learning more about A-133 audits, check out Management Concepts’ Audit of Federal Grants and Cooperative...

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Obama Outlines PART Overhaul

Posted by on May 12, 2009 in Grants & Assistance | 0 comments

In his 2010 budget proposal released this week, President Obama sketched a broad outline of the steps he plans to take in an effort to “fundamentally reconfigure” how the federal government assesses program performance. One of the six cornerstones of the administration’s plan for improved government management and performance is replacing the Program Assessment Rating Tool (PART) with a new “performance improvement and analysis framework.” Instead of grading individual programs as “successful” or “unsuccessful” Obama plans to ask agency leaders to set priority goals, demonstrate progress in achieving goals, and explain performance trends. As a first step,  over the next few months each major agency will identify a limited set of high-priority goals that will guide meetings with cabinet officers. In his budget, Obama also said he wants to streamline reporting requirements under the Government Performance and Results Act (GPRA). To read the text of the budget proposal relating to government management, click here. Management Concepts’ Accountability for Federal Grants course offers more insight into this topic, helping you apply performance-based principles to grants projects.  To learn more, click...

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CFDA Is Back Online!

Posted by on May 4, 2009 in Grants & Assistance | 0 comments

As the General Services Administration promised, the Catalog of Federal Domestic Assistance website is now back – with a new look. Although much of the information that was posted on the previous site is still available, there are some new enhancements. For example, at www.cfda.gov you can now find an entire section devoted to programs funded under the Recovery Act, as well as an enhanced search tool. You can also access links to resources such as a print version of the 2008 catalog, Grants.gov, an overview of the CFDA, and tips for writing grant...

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A-133 Compliance Supplement Coming Soon

Posted by on Apr 24, 2009 in Grants & Assistance | 0 comments

Here’s some information I picked up at the recent National Grants Management Association annual training conference. According to Terry Ramsey of HHS (formerly of OMB), the draft Circular A-133 Compliance Supplement is being circulated and should be released “soon” and will include an appendix dealing with the Recovery Act. OMB also plans to release an addendum to the Compliance Supplement with more specific Recovery Act information as close as possible to June 30 so that auditors can get started on auditing the Recovery Act funds. We’ll let you know when we learn...

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2 CFR Part 176 in Today’s FR

Posted by on Apr 23, 2009 in Grants & Assistance | 0 comments

Just a quick note for those of you interested in the Recovery Act. OMB published 2 CFR Part 176 – the requirements for grant and assistance reporting, Buy America and Davis Bacon – as interim final guidance in today’s Federal Register. Comments are being accepted until June 22. To read the announcement, click...

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Be On the Lookout for A-133 Changes

Posted by on Apr 10, 2009 in Grants & Assistance | 0 comments

According to a new report from the Government Accountability Office, there could be significant changes to the federal government’s single audit process in 2009. At the request of members of Congress, GAO took a look at how the OMB Circular A-133 single audit process could be revised to improve federal oversight and accountability of grant funds. The current process, GAO reported, offers no way to ensure how or even if federal agencies implement single audit requirements. Further there are variations among federal agencies as to how they carry out their oversight responsibilities, such as quality control reviews. GAO went on to describe current efforts to improve the audit process. OMB anticipates that revisions to Circular A-133 and the checklist for performing quality control reviews will be completed in the fall of 2009. Also, the AICPA plans to finalize applicable auditing standards and the AICPA Audit Guide, and to develop illustrative practice aids in 2009, GAO reported. GAO’s report is available here. For those interested in A-133, Management Concepts offers a two-day course, Audit of Federal Grants and Cooperative Agreements. For information about this training, click...

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Recovery Act Guidance Just Keeps Coming…

Posted by on Apr 6, 2009 in Grants & Assistance | 0 comments

The Office of Management and Budget has just added a new part to Title 2 of the Code of Federal Regulations to establish a standard award term for grants, cooperative agreements, and loans funded with American Recovery and Reinvestment Act dollars. The new interim final guidance and award term was released late Friday as part of OMB’s second installment of the more comprehensive guidance to federal agencies on implementation of the Recovery Act. The new 2 CFR Part 176—which should be published in the Federal Register in the next day or so—covers several issues related to the receipt of grants and other assistance under the Recovery Act: reporting, Buy America, wage rates, and single audits. Management Concepts is currently working to sift through the new guidance and the standard award term to understand its impact on grants administration. We’ll keep you updated here on the blog, as well as in our classroom and online courses. In the meantime, you can view the entire OMB implementation guidance, including the new standard award term, by clicking...

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OMB Details Proposed Recovery Act Reporting

Posted by on Apr 1, 2009 in Grants & Assistance | 0 comments

The Office of Management and Budget today issued the proposed data elements that would be required for recipient reporting on projects funded under the American Recovery and Reinvestment Act. OMB is proposing four basic sets of data. Grant recipients would provide fairly standard  information about themselves and their Recovery Act award. They would also have to describe the funded project or activity and its current status. Things get a little more complicated in the third and fourth sets of required data elements. Recipients would have to provide detailed information about their subrecipients, including, for example, the entity’s DUNS number and organization type. But OMB is also proposing that recipients list the total amount of funding awarded, as well as the total amount they expect to give to the subrecipient over the course of the project, among other things. One interesting requirement being proposed by OMB is that recipients list the names and salaries of the five most highly compensated officers of the entity, if that information is not otherwise available to the public. Comments on the proposed data elements are due May 1. To view the proposed data elements, click here. You can learn more about the Recovery Act and its impact on federal grants administration at our Federal Grants Update 2009 seminars, which are now running in locations around the country. Click here for additional...

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Who’s Reviewing the Reviewers?

Posted by on Mar 31, 2009 in Grants & Assistance | 0 comments

The system created to review and monitor clinical trials involving humans is vulnerable to “unethical manipulation,” and government officials admit they don’t assess whether some parts of the system are adequate or even factual. In a recent investigation of the Institutional Review Board (IRB) system, the Government Accountability Office (GAO) created a fake company with a fake review board, received approval to test a nonexistent medical device, and falsified documents—all with the approval of federal agencies. An IRB is an entity formally designated to review and monitor research involving human subjects. IRBs have traditionally been part of large research universities, but private companies have started playing a greater role in creating IRBs to oversee clinical trials. The Department of Health and Human Services’ Office for Human Research Protections and the Food and Drug Administration are responsible for overseeing the IRB system. In its undercover investigation, GAO created a “bogus” company and IRB. It appeared so real that a private research company contacted the GAO’s IRB about reviewing its surgical procedures. In addition, GAO filed an assurance statement with HHS, promising to protect human subjects. That HHS assurance application, which was approved, would have allowed the fake company to receive HHS research funding. And the last part of the investigation? GAO was able to get approval from an actual IRB to test a fake medical device. In response to GAO’s investigation, the director of the Office of Human Research Protections said when reviewing assurance applications, HHS does not consider whether the IRBs listed are “adequate” nor does it review applications to determine whether the information is true. The results of GAO’s investigation were presented recently in testimony before the House Subcommittee on Oversight and Investigations, Committee on Energy and Commerce. To read the full GAO report, click here.  ...

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“Imprudent” Projects Will Not be Funded Under the Recovery Act

Posted by on Mar 25, 2009 in Grants & Assistance | 0 comments

The American Recovery and Reinvestment Act specifically prohibits funds from being used to support any gambling establishment, aquarium, zoo, golf course, or swimming pool. But according to President Obama and Vice President Biden, similar projects also will be on the forbidden list. Speaking to members of the National Conference of State Legislatures, Obama said “whenever a project comes up for review, we will ask a few simple questions: Does it advance the core mission of the Recovery Act? Does it jumpstart job-creation? Does it lay the foundation for lasting prosperity?” Biden added, “There is the letter of the law and then there is the spirit of the law. And we intend to make sure the spirit of the law is what’s actually followed here, in addition to the letter.” So, no Recovery Act funding for dog parks or skateboard parks. And no funding for new lights in the White House. The president went on to provide an example of what he considers an imprudent project. He said the East Wing, where the first family lives, needs repairs to the electrical and heating systems. However, the work would not meet the economic recovery goals of the new law, so Recovery Act funding will not be used for the project. Obama issued a memo to the heads of federal agencies on March 20, outlining specific steps that should be taken when reviewing and funding Recovery Act projects. It requires the creation of merit-based review criteria and outlines agencies’ and grantees’ responsibilities for ensuring funds are not used for imprudent or prohibited projects. But it goes even further: recipients who use funds for excluded projects and activities face specified penalties such as additional reporting and oversight requirements, rescission of funds, and even possible suspension and debarment. To view the memo, click here. Management Concepts’ Federal Grants Update 2009 course offers a discussion of the Recovery Act and its impact on grants management. For information about upcoming sessions, click...

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NIH Joins Twitter

Posted by on Mar 23, 2009 in Grants & Assistance | 1 comment

Looking for a quick, easy way to track funding opportunities from the National Institutes of Health? Try Twitter. In mid-March NIH began using the social networking and blogging service to provide information about funding opportunities. Using Twitter, NIH will post links to Funding Opportunity Announcements in a condensed format, about the size of a typical text message. The Institute will “tweet” announcements once a week. (Twitter enables users to send and read other users’ updates known as tweets. Tweets are text-based posts that can be accessed via the Twitter website, RSS feeds, cell phone text message systems, and similar services.) NIH is also using Twitter to post general health news updates. To learn more and to sign up for Twitter, visit the NIH Twitter page at...

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Welcome to the Grants Blog!

Posted by on Mar 23, 2009 in Grants & Assistance | 0 comments

Welcome to Management Concepts’ Grants Blog. We created this site as a tool to help you stay up to date on the latest information that affects the administration of federal grants and assistance programs. You’ll find posts about new governmentwide policies and directives, congressional activities, federal awarding agency issuances, answers to common grants management questions, and much more. We’ll also be passing along grants management tips, helpful resources, interesting facts and news briefs, and other tidbits that can help you in your daily work. And occasionally you’ll find a posting by a grants management subject matter expert who will share some real-life experiences, thoughts about current developments, and insights into federal grants management issues. A little bit about me… My name is Lisa Hayes, and I’ll be posting most of the entries for the Management Concepts Grants Blog. I’m a curriculum developer in Management Concepts’ Grants division – which basically means I help write and update our training materials. One of my responsibilities is to constantly monitor developments affecting federal grants management, and this blog will offer me an opportunity to share some of that information with you. As we developed this blog, I envisioned that its contents would span three c’s: current, constructive, and casual. If you have questions or comments about anything you read on the blog, please feel free to email me at grantsblog@managementconcepts.com. For more information about Management Concepts, visit us online at...

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