Reducing Red-Tape to Improve Outcomes The Council on Financial Assistance Reform Initiatives March...

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Reducing Red-Tape to Improve Outcomes The Council on Financial Assistance Reform Initiatives March 12, 2014

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Reducing Red-Tape to Improve OutcomesThe Council on Financial Assistance Reform Initiatives

March 12, 20141Increase in Federal Grants Activity

$7B$24B$91B$200B$600BThe Catalog of Federal Domestic Assistance lists over 2,000 Federal grant programs #2Guidance Reform History #3Diverse Range of Stakeholders EngagedType of Institution RepresentedExamplesState GovernmentsNASACTNASCIONonprofitsNational Council of NonprofitsAuditorsAICPACIGIE Indian TribesNAFOAGAOGrants ProfessionalsAGANGMAUniversitiesCOGRAAUAPLU #4

OMB Simplifies Government-wide Grant Guidance

A Whole New World: OMB Publishes New Grants Reform Guidance

December 2013: Final Uniform Guidance #5Challenge & ImpactChallenge Under Previous GuidanceImpact of New Uniform Guidance1. Eight Overlapping Sets of Compliance RequirementsEliminates Duplicative and Conflicting Guidance2. 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 Definitions4. Outdated Guidance Does Not Account for Modern Electronic Work EnvironmentPromotes Efficient Use of IT and Shared Services5. Inconsistent and Non-Transparent Treatment of CostsRequires Consistent and Transparent Treatment of Costs6. Lack of Support for Policies with Work-Life BalanceEncourages Non-Federal Entities to Have Family-Friendly Policies7. Audit Findings Repeated Each Year = WasteStronger Oversight & Target Audits on Risk of Waste, Fraud, and Abuse 8. Lack of Accountability for Effectively Correcting Financial Integrity WeaknessesIncreased Accountability for Effective Resolution of Weaknesses #6Eliminating Duplicative and Conflicting GuidanceINSERT YOUR STATE OR AGENCY HERE

Now: All OMB guidance streamlined in 2 CFR 200.Then: #7Performance Over Compliance for AccountabilityEmphasis on strong internal controls and reduction in specific compliance requirementsExample: Specific examples of justification for salaries and wages eliminated for more flexibility in implementing a strong system of internal controlsAlignment with M-13-17 encouraging innovative program design based on evidencePerformance measurement aimed at developing lessons learnedFixed amount awards aimed at performance milestones

#8Consistent and Transparent Treatment of CostsVoluntary Committed Cost Sharing is not expected under research awardsPass-through entities must provide an indirect cost rate for subawardsStandards for treating admin costs as directHigh bar for circumstances where agencies may deviate from Federally negotiated ratesOption to extend rate for up to 4 yearsDe minimis rate of 10% of MTDC for entities without a Federally negotiated rate #9Standard Business Processes & Data DefinitionsSets framework for standardizing data definitions in all grants-related forms governmentwideStandardizes format for notices of funding opportunities w/60 days to applyStandardizes Information to be provided in all Federal Awards and SubawardsHighlights areas where specific agency approval is needed #10Family-Friendly PoliciesWhere consistent with non-Federal entity policy:Allows costs of conference hosts to identify locally available child care Allows temporary dependent care costs that meet specified standards for travelAllows family leave as a fringe benefit #11Stronger OversightRequires mandatory disclosures for conflict of interest and criminal violationsRequires pre-award review of merit of proposal and risk of applicantFederal agencies may assign specific conditions for awards based on riskStrong focus on internal controls

#12Targeting Waste, Fraud, and AbuseSingle Audit Threshold raised from $500,000 to $750,000 reducing burden for 5,000 entities while maintaining coverage for 99% of current dollars covered.Publication of single audit reports online with safeguards for PII and optional exception for Indian tribesSenior Accountable Official to implement metrics and encourage cooperative resolutionStrong requirement to rely on existing audits first #13Stakeholder ReactionsSignificant interest in training webcast held January 27, 2014 & future outreach Over 5,000 registrations for mailing listRecorded version will be available at recognition of significance of reformInterest in resources to assist in smooth implementation #14Guidance MetricsMetrics 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 issuedNumber of IDC rate extensions approved by Cognizant Officials

#15Guidance MetricsPossible 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

#16Council On Financial Assistance Reform PrioritiesBetter Outcomes for GrantsEvidenceSpending TransparencyShared ServicesFinancial Management #17Framework for 2014 COFAR ActivitiesAll deliverables will be strategically aligned to support effective implementation of guidance reform with minimum resource burden to Federal agencies and non-Federal entities. #18Strong Program Oversight: Audit Resolution19 #19Strong Program Oversight: Audit Resolution20 #20Workforce Development #21Workforce Development #22Federal Grants Workforce Training #23Grants Data Standardization #24Grants Data Standardization #25Grants Data Standardization #26Federal Spending TransparencyQuality: Improving data integrityCompleteness: Expanding the focus to include obligations and expendituresFunctionality: Providing a one-stop location for all Federal spendingUtility: Linking spending information to program activity

#27The Road Ahead: Implementing Grants Reform #28Engage With COFARFor More Information Visit: Questions To: [email protected] you! #29Chart170080024003000500197891198219829519861986150199019902001994199425019981998325200220024502006200660020102010

Constant 1992 $

Sheet11960196619701974197819821986199019941998200220062010Constant 1992 $782430509195150200250325450600