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Many of the rescinded requirements relate to agency compliance with information technology guidance.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 the 4-digit suffix number would allow for the expansion for future programs. M-17-26 eliminated agency compliance with this requirement.

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Check back soon (or subscribe using the form at the top-right of the page) for Part Two of our midsummer summary of changing grant policy. And in the meantime, stay up to date on all things Federal Grants & Assistance by signing up for our training courses in Grants Management Processes & Techniques; Laws, Regulations, and Policies Affecting Grants; and Grants Financial Practices, Assessments, and Audits.