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Grants – Under the PMA 2 CFR 200 Update

Grants – Under the PMA 2 CFR 200 Update. Grants Management. Source: The Pew Charitable Trusts – August 2016. Distribution of Grants by Function (in Billions). Total Federal grants = $821 Billion (includes some R &D contracts). Budget. Office of Management and Budget.

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Grants – Under the PMA 2 CFR 200 Update

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  1. Grants – Under the PMA 2 CFR 200 Update

  2. Grants Management

  3. Source: The Pew Charitable Trusts – August 2016

  4. Distribution of Grants by Function (in Billions) Total Federal grants = $821 Billion (includes some R &D contracts)

  5. Budget Office of Management and Budget Fiscal Year 2019 Budget Reduced Grant Dollars and Programs Elimination of some Agencies New Management Chapter – President’s Management Agenda

  6. -$65 Billion +$88 Billion 2019 Budget Change - Major Agencies

  7. Some Examples of Proposed Program Eliminations - $48.4 Billion Education – “To eliminates the 21st Century Community Learning Centers program given performance data demonstrates that the program is not achieving its goals…Less than 20% of program participants improved from not proficient to proficient…in reading and mathematics.” <$1.2 Billion> HUD – “To eliminate funding for the Community Development Block Grant program. The program is not well-targeted to the neediest populations and has not demonstrated a measurable impact on communities.” <$3 Billion> DHHS – “LIHEAP is a Federal program that has been known to have sizeable fraud and abuse, leading to program integrity concerns…the program lacked proper oversight, which resulted in a significant number of improper payments.” <$3.4 Billion>

  8. Government modernization will be rooted in the intersection of transforming technology, data, process, and people rather than working in silos. What Is Different? Performance.gov

  9. Cross Agency Priority (CAP) Goals

  10. Overview - Results Oriented Accountability for Grants Overview - Results Oriented Accountability for Grants Goal Statement Maximize the value of grant funding by applying a risk-based, data-driven framework that balances compliance requirements with demonstrating successful results for the American taxpayer. Challenge The Federal government uses grants to invest approximately $700 billion each year in mission-critical needs for American taxpayers, but managers report spending 40% of their time using antiquated processes to monitor compliance instead of analyzing data to improve results. Opportunity Identify, open, standardize, and link critical data sets to power data analytics to enhance financial stewardship, performance management, and accountability. Use digital tools to modernize antiquated compliance processes. Leverage available data such as those produced by annual audits of recipients to drive a risk-based framework for performance management that drives results.

  11. Grants Challenges by Stakeholder Community Oversight Community • Weak internal controls • Funds mismanagement • Fraud • Improper payments Recipients and the Communities they Serve • Burden • Fragmentation • Conflicting guidance Federal Awarding Agencies • Need for improved coordination across lines of businesses and program • Opportunities to improve access to and quality of data • Unstandardized business process

  12. Past Reforms and Initiatives • Single Audit Act of 1984 • Federal Financial Assistance Management Improvement Act of 1999 (P.L. 106 – 107) • Council on Financial Assistance Reform (2011 – 2017) • Uniform Guidance – finalized in December 2013 • DATA Act Section 5 Pilot & Report (2015 – 2017)

  13. Goal Structure - Results Oriented Accountability for Grants Better Results Goal Structure - Results Oriented Accountability for Grants

  14. CAP Goal #8 Governance • EXECUTIVE STEERING COMMITTEE (ESC) • Doug Webster, ED | Sheila Conley, HHS | Fred Nutt, OMB

  15. A New Risk-Based, Data-Driven Framework Data generated throughout that may be leveraged for improved performance management

  16. The “Graduation” • Top Ten Impact • Procurement Standards - NDAA • FAQs – July 2017

  17. Shirakawa-Go

  18. Grant Haiku Grant chaos without Uniform guidance Even more chaos with Uniform guidance, yes? CPAs thrive on chaotic life ….and keep Grants achieving

  19. 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 - Federal • Subpart D, 200.3XX – Post Award – Recipients • Subpart E, 200.4XX – Cost Principles • Subpart F, 200.5XX – Audit • 12 Appendices - I through XII • “Should” and “Must”

  20. “Should” and “Must” Shall it Out – Yes, Shout it Out But Should is In May will be back So are April and June Orange is the new Black Must is the new Shall

  21. Top Ten UG Impact • Standard data • Definitions, NOFO, Application, Award Notice • Computing devices as supplies – 200.94 • Fixed award amount – 200.201 (b) • Internal Controls – 200.303 • Procurement standards – 200.320

  22. Top Ten UG Impact • Subrecipient Monitoring – 200.331 • Direct charges of administrative SW – 200.413 • IDC Rate acceptance – 200.414 • Documentation for personal services -200.430 • Internal controls – 200.430 (i) • Outcome based – 200.430 (i) (6) • Blended funding – 200.430 (i) (7) • Audit report transparency- 200.512

  23. FAQs • 4th Set – 24 New (and 4 Revised) July 2017 • 5 @ Definitions • 1 @ Section 200 • 6 @ Section 300 • 5 @ Section 400 • 5 @ Section 500 • 2 @ Appendix III *331.10 …Are pass-through entities required to assess the risk of non-compliance for each applicant prior to issuing a subaward?

  24. National Defense Authorization Act 2017 • Raises micro-purchase threshold to $10,000 for certain recipients only: • IHEs • Independent research institutes • Nonprofit research orgs • Apply to ALL Federal awards • Effective December 23, 2016 • Can receive a higher level by request to the cognizant agency for indirect costs if: • Low risk auditee, or • Internal institutional risk assessment, or • Consistent with state law for public orgs • Agencies to implement a process for approval 2018 • Raises micro-purchase threshold to $10,000 and simplified acquisition threshold to $250,000 for procurements under the FAR • Apply to All Federal awards and All recipients • Effective when FAR is updated • OMB implementing an exception to the UG to allow use for Federal awards: • 2 CFR 200.67 Micro-purchase • 2 CFR 200.88 Simplified Acquisition Threshold • No provision for higher threshold request for All recipients

  25. > $250 K > $250 K $250 K 10K

  26. What’s Ahead?

  27. What’s Ahead? • Future changes to the UG • Performance Focus – PMA • GONE Act • E.O. Buy American Hire American • Research Policy Workgroups – CURE ACT and AICA • Free Grant 101 Training • https://cfo.gov/grants/training/

  28. Kiyomizudera Temple, Kyoto

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