In February 2013, the Office of Management and Budget (OMB) issued its report “Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements” after a year of comments and feedback.
While the proposed changes for Grants and Cooperative Agreements have not been enacted yet, we’ve boiled it down to this summary view to keep you informed about the potential changes.
Part I: The Minimalist Guide to Proposed Changes of the Grant and Cooperative Agreement Regulations
5 Reforms to Administrative Requirements–under consideration
#1 Create a consolidated, uniform set of administrative requirements for all entities
Status: Consolidated regulations being drafted, but OMB is still soliciting comments on the potential impact particularly with regard to organizations subject to A-110.
#2 Require pre-award consideration of each proposal’s merit and each applicant’s financial risk
Status: The OMB understands that reviews like this could be time-consuming but believes that they can design regulations that are not be too difficult for both agencies and recipients.
#3 Require agencies to provide 90-day notice of funding opportunities
Status: The agencies felt this requirement would be extremely hard to comply with, so instead the OMB wants to list the minimum amount of time for the solicitation on grants.gov
#4 Standardize Date Collection
Status: Reiterate that information collections are subject to Paperwork Reduction Act and wants to encourage agencies to use standardized data collection methods when possible Cooperative Agreement Regulations.
#5 Additional other areas for consideration
• Map out more uniform requirements for agencies to provide certain types of information to recipients when an award is made
• Consolidate information on subaward monitoring so it is easy for grantees to find the relevant oversight expectations
• Line up the objectives for performance monitoring and measurement Cooperative Agreement Regulations
• Update the threshold for small purchase procedures to match with the simplified acquisition threshold-which is currently $150,000
• Spell out that the record and retention requirements for a 3-year period starts when the recipient submits their final expenditure report
• Specify that federal agencies should also complete their closeout activities 180 days after the final closeout report is received from the recipient
Stay tuned for more updates…
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Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.