Are You Ready For This?The New Uniform Grant Guidance and

Movements in Federal Spending Transparency

May 20, 2014

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Increase in Federal Grants Activity

$7B$24B

$91B

$200B

$600B

The Catalog of Federal Domestic Assistance lists over 2,000 Federal grant programs

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Council On Financial Assistance Reform Priorities

Guidance Targets Risk & Minimizes

Burden

Standardized Business Processes

& Data

Well Trained Workforce

Strong Program Oversight:

Audit Resolution

Better Outcomes for Grants

EvidenceSpending

Transparency

Shared Services

Financial Management

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Guidance Reform History

Nov. 2009: Executive

Order: Reduce

Improper Payments

Feb 2011: Presidential

Memo: Reduce

Administrative Burden

Feb 2012: Advance Notice of Proposed Guidance

(public comments)

Feb 2013: Notice of Proposed Guidance

(public comments)

Dec 2013: Final

Uniform Guidance

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Diverse Range of Stakeholders Engaged

Type of Institution Represented ExamplesState Governments NASACT

NASCIONonprofits National Council of NonprofitsAuditors AICPA

CIGIE Indian Tribes NAFOA

GAOGrants Professionals AGA

NGMAUniversities COGR

AAUAPLU

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“OMB Simplifies Government-wide Grant

Guidance”

“A Whole New World: OMB Publishes New

Grants Reform Guidance”

December 2013: Final Uniform Guidance

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Eliminating Duplicative and Conflicting Guidance

AwardsReceiv

ed

•A-102 & A-89•A-87•A-133 &A-50Subawar

ds to universiti

es

•A-110•A-21Subawar

ds to nonprofi

ts

•A-110•A-122

INSERT YOUR STATE OR AGENCY

HERE

Now: All OMB guidance streamlined in 2 CFR 200.

Then:

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2 CFR 200 -Basic Layout

• 6 Subparts A through F– Subpart A, 200.XX – Acronyms & Definitions– Subpart B, 200.1XX – General– Subpart C, 200.2XX – Pre Award– Subpart D, 200.3XX – Post Award– Subpart E, 200.4XX – Cost Principles – Subpart F, 200.5XX – Audit

• 11 Appendices - I through XI

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Challenge & ImpactChallenge Under Previous Guidance Impact of New Uniform Guidance

1. Eight Overlapping Sets of Compliance Requirements

Eliminates Duplicative and Conflicting Guidance

2. High Levels of Administrative Burden Performance and Internal Controls Over Compliance for Accountability

3. Hundreds of Forms with Non-Standard Data Definitions

Provides Framework for Standard Business Processes & Data Definitions

4. Outdated Guidance Does Not Account for Modern Electronic Work Environment

Promotes Efficient Use of IT and Shared Services

5. Inconsistent and Non-Transparent Treatment of Costs

Requires Consistent and Transparent Treatment of Costs

6. Lack of Support for Policies with Work-Life Balance

Encourages Non-Federal Entities to Have Family-Friendly Policies

7. Audit Findings Repeated Each Year = Waste

Stronger Oversight & Target Audits on Risk of Waste, Fraud, and Abuse

8. Lack of Accountability for Effectively Correcting Financial Integrity Weaknesses

Increased Accountability for Effective Resolution of Weaknesses

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December 2013: Uniform Guidance Published

June 2014: Agencies Submit Draft Rules to OMB,

Continued Outreach on Implementation

December 2014: Final Guidance Effective,

Baseline Metrics Collected, Case Studies of Best Practices Published

Guidance Reform Future

Summer 2014: Federal Grants 101 Course Published

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Guidance Metrics

Metrics to gauge impact of guidance on reducing the risks of non-compliance and unnecessary administrative burdenPossible General Metrics:• Number of OMB Approved Exceptions • Number of fixed amount awards issued• Number of IDC rate extensions approved by

Cognizant Officials

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Guidance Metrics

Possible Audit Metrics:• # of major programs before and after

guidance effective• % of timely submissions of single audits • # of repeat findings• # of ‘unclean’ opinions for major programs• # of material audit findings in single audits

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Strong Program Oversight: Audit Resolution

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Challenge

• Over 4,000 audited programs failed to receive clean opinions in 2011 (3% of total audited programs)

• No existing guidance holds agencies and recipients accountable for effectively correcting financial integrity weaknesses

Accomplishments

• September 2013: High risk programs and recipients identified• November 2013: CAROI pilot results presented to COFAR principals

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Strong Program Oversight: Audit Resolution

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Short Term Deliverables

• December 2013: Document best practices on CAROI to contribute to resource repository• February 2014: Complete framework for 2014 Compliance Supplement (w/preview of guidance implementation)• March 2014: Finalize Single Audit Metrics• April 2014: Compile and publish existing Federal agencies’ audit resolution policies• April 2014: Publish 2014 Compliance Supplement • June 2014: FAC to deliver available standard and ad hoc reports and analytical tools

Long Term Deliverables

• July 2014: Reconvene to plan management decision letter pilot• December 2014: Publish any proposal to revise Data Collection Form and SEFA

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Workforce Development

Challenge

• Lack of consistent standards for qualifying people to perform the grants management function

• No government-wide core training requirement for people performing the grants management function

Accomplishments

• December 2013: Competencies established• December 2013: Resource repository built, available for use, and in testing phase

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Workforce Development

Short Term Deliverables

• April 2014: Knowledge-Sharing Resource Center available for sharing ideas and best practices

• Summer 2014: Publish Grants Management 101 Course

Long Term Deliverables

• October 2014: Reconvene to discuss long-term vision and possible industry-wide credentialing framework

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Grants Man-

agement

Laws, Regulations, and Guidelines

Financial Analysis

Financial Assistance Mechanisms

Compliance

Grants Workforce Competencies

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Federal Grants Workforce Training

GrantsWorkfor

ce

Grants 101 CourseKnowledge-

SharingUniform Guidance

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Grants Data Standardization

Challenges

• Over 700 distinct grant related forms approved in OMB database• No current process to vet and validate existing data elements nor to create and validate new data elements• Multiple stakeholders must be engaged to fully explore grants data standards and chart a successful path forward• Non-standard data definitions compromise quality of publicly reported financial data

Accomplishments

• September 2013: Preliminary analysis of 1100 data elements• September 2013: Contract awarded to support further analysis of data elements

and development of governance framework• December 2013: 99 standard definitions in final guidance

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Grants Data Standardization

Short Term Deliverables

• December 2013: Grants data standardization proposed vision, project outline, and governance framework

• March 2014: HHS to brief COFAR on grants data standards records repository functional requirements

Long Term Deliverables

• June 2014: Brief COFAR on proof of concept for grants data standards• July 2014: Reconvene to plan additional long term deliverables based on HHS and

Treasury short term deliverables.

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Federal Spending Transparency Now

• USAspending.gov: View all types of federal award spending

• Recovery.gov: View Recovery Act spending • Federal agencies validate the financial data,

per OMB’s June 2013 Memo • Treasury Department is the program manager,

per the FY14 Consolidated Appropriations Act

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The Path Forward on Transparency: FY14 and Beyond

- FY 14: Upgrade look & feel of USAspending.gov

- Beyond: DATA Legislation – Expansion of Data Posted on USAspending.gov – Establishment & Implementation of USAspending.gov

Data Standards – Recommendations for Streamlined Recipient Reporting

Burden – Establishment of a Data Analysis Center – Requirement to Report Non-Tax Debt

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Engage With COFAR

For More Information Visit: CFO.gov/COFAR

Send Questions To:

COFAR@omb.eop.gov

Thank you!