are you ready for this? the new uniform grant guidance and movements in federal spending...
TRANSCRIPT
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:
Thank you!