The time to implement the new grant regulations is rapidly approaching.
Are you wondering about what the new OMB Super Circular means to your procurement department?
Let’s look at three myths about the new grant guidance so you can move forward into this brave new world for grant recipients with a clearer understanding of what’s changing…
Myth #1: It Will Be Soooo Much Harder Than Ever Before!
Oh my goodness. It will be soooo much harder than it used to be!
It will change EVERYTHING!
This myth is based on the old “nothing ever gets easier” mindset.
Deep Breaths in the Procurement Department
OK, the truth is that everything is NOT changing when it comes to procurement under the new grant regulations.
But there are lots of things that are.
Here are a few things to watch out for:
If you are a pass-through entity, you will now have a requirement to conduct a risk assessment prior to awarding work.
As the Federal funding agencies lead the way on this one, we will have further updates about what this may look like.
Potential conflicts of interest and violations of law affecting the Federal award move into the mandatory disclosure column.
No more waiting to see it they are “discovered” by auditors or other investigators.
Grant recipients now have the duty to disclose these types of issues and be alert to organizational conflicts of interest in addition to individual ones.
New Contract Provisions
More public policy requirements rear their heads in the new Super Circular.
>>New guidance on recycling and use of recovered materials may need to be included.
>>Protection of personally identifiable information (PII) is now part of the new electronic age we live in.
And yes, you will need to update your contracts provisions to be compliant.
(But at least the metric system is no longer our “preferred system” to the extent “practicable” so change can be good!)
Myth #2: It Will Be Soooo Much Easier when the New Grant Guidance Becomes Effective
Less administrative burden sounds great!
After all, that is one of the stated goals of the new grant regulations.
This myth is based on the “less is better” mindset.
But before you start the party, let’s look at some tweaks to the new guidance that may still apply to you.
Affirmative Steps vs. Positive Efforts
The new guidance calls the efforts to include women, minority-owned, small business and labor area surplus firms in procurement “affirmative steps” now.
But the requirement to actively include these types of business is still an important part of procurement with Federal funds.
Don’t miss it, just because the terminology has changed.
Checking for Suspension and Debarment Still Matters
The movement of the excluded parties list system from EPLS.gov to the System for Award Management (SAM.gov) didn’t stop the requirement to make sure funds don’t flow to excluded people and organizations.
And yet, missing this vital check and balance is so common that it has its own category in the list of audit findings that are submitted to the Federal Audit Clearinghouse.
Even Now Cost Principles Rule
The Cost Principles remain the governing document for what Federal funds can be spent on.
And fortunately, most of the selected items of cost remain pretty much the same.
But there are some new ones joining the party.
>>Expanded family-friendly policies add new areas in meetings and conference spending that both the program staff and procurement department should be aware of.
>>And at long last, purchases of computers that do NOT meet the definition of equipment are explicitly included with supplies, not equipment.
Let the cheering begin!
(This last item has been a topic of vigorous discussions between Federal funding agency staff and grant recipients ever since the price of computers plummeted.)
Myth #3: Nothing’s Changed-Also Called “SCDS or Super Circular Denial Syndrome”
La, la, la, la.
Is this the sound in your organization?
This is the sound of SCDS or “Super Circular Denial Syndrome.”
Though this may be hard to believe, some folks are not even aware there is a new set of grant regulations for grant recipients about to be unleashed!
(Could this be the same ones who still reference A-110, A-21, and A-122 instead of the NEWER references for 2 CFR, Part 220, 2 CFR, Part 215, and 2 CFR, Part 230?)
I meet them all the time.
I ask them what they are doing to transition and I get a blank stare.
This is the myth of “I’ll do it someday” mindset.
Yes, Virginia, there is a change to the grant regulations
It’s called the 2 CFR Part 200 also known as the OMB “Super Circular.”
It was released on December 26th 2013 and becomes fully implemented on December 26th, 2014.
The procurement standards (plus the rest of the Administrative Requirements and Cost Principles) are all rolled up into one big set of grant regulations for grantees.
>>No more having to manage multiple sets of OMB circulars.
Of course, you’ll still need to check out your funding agency guidance and your award terms and conditions for the specifics Three Myths .
But ignoring the shift to the new regulations is a poor choice, Three Myths especially as we get into the certification of costs phase.
(More about this to come in the future)
What Myths Do You Believe?
How about you?
Do you know people who believe one of these myths about the new grant regulations?
A little good information can go a long way.
Spread the word.
We are just 4 major holidays away from full implementation.
The 4th of July, then Labor Day, then Thanksgiving and “POOF” the day after Christmas Three Myths is the effective date of the new OMB Super Circular.
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
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.