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THE NEW OMB SUPERCIRCULAR: WHAT DOES IT MEAN TO

THE NEW OMB SUPERCIRCULAR: WHAT DOES IT MEAN TO. YOU?. OMB SUPERCIRCULAR. UPERCIRCULAR “ UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES & AUDIT REQUIREMENTS FOR FEDERAL AWARDS” Federal Register Vol. 78, No. 248 December 26, 2013

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THE NEW OMB SUPERCIRCULAR: WHAT DOES IT MEAN TO

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  1. THE NEW OMB SUPERCIRCULAR: WHAT DOES IT MEAN TO YOU?

  2. OMB SUPERCIRCULAR UPERCIRCULAR “UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES & AUDIT REQUIREMENTS FOR FEDERAL AWARDS” Federal Register Vol. 78, No. 248 December 26, 2013 Codified as: 2 Code of Federal Regulations, Part 200

  3. TRADITIONAL APPROACH TO FEDERAL GRANTS • Assistance to others in accomplishing their own purposes • “Gifts with strings attached” • “Best efforts” are good enough • The SUPERCIRCULAR changes all this!

  4. COMMITTEE ON FINANCIAL ASSISTANCE REFORM (COFAR) Comprised of major federal grant making departments and agencies: • Department of Health & Human Services • Department of Housing & Urban Development • Department of Labor • National Science Foundation • Others

  5. COFAR’S STATED REASONS FOR THE SUPERCIRCULAR • to eliminate duplicative and conflicting guidance found in the various older OMB circulars, • to provide for consistent and transparent treatment of costs, • to encourage efficient use of information technology and shared services, • to set standard business process using data definitions, • to target audit requirements on risk of waste, fraud and abuse • to limit allowable costs to make the best use of federal resources, • to encourage non-federal entities to have family-friendly policies, • to strengthen oversight, • to focus on performance over compliance

  6. COMMENTS SUBMITTED ON THE DRAFT SUPERCIRCULAR • 360 organizations and individuals submitted written comments on the draft SUPERCIRCULAR • No comments were received from the: National League of Cities, the National Governors Association or the ICMA

  7. SUPERCIRCULAR REPLACES EIGHT (8) OMB CIRCULARS

  8. CROSSWALK: OLD OMB CIRCULARSTO SUPERCIRCULAR

  9. SUPERCIRCULAR CHANGES • PROCEDURAL • MINOR • MAJOR (FOCUS ON • PERFORMANCE)

  10. PROCEDURAL CHANGES • Moving furniture - a rule, definition, concept, guidance, etc. has been moved from an Old OMB Circular to the SUPERCIRCULAR • One stop shopping center

  11. MINOR CHANGES • Definitions (99 standard definitions) • Cost Policies • Grant Administration Requirements • Audit Requirements • Other Requirements Note: the cumulative impact of these “minor changes” could be a major change for any particular state or local government

  12. MAJOR CHANGE: FOCUS ON PERFORMANCE • The SUPERCIRCULAR trades financial compliance for performance accountability • The word performance appears 177 times • The word outcomes appears 22 times • The word contract appears 265 times

  13. MOVING TO PERFORMANCE • Government Performance & Results Act of 1993 (GPRA) • OMB Circular A-76 & Federal Acquisition Regulation (FAR) • OMB Memorandum M-13-17: Next Steps in the Evidence & Innovation Agenda

  14. GPRA • Requires federal departments and agencies to report annually on their performance • Focus on outcomes • Federal problem with grants to: states, local governments, universities, others

  15. OMB CIRCULAR A-76 & FAR Federal departments and agencies are to use performance - based contracting to the maximum extent possible

  16. OMB MEMO M-13-17 • Guidance on FY 2015 federal budget • Agencies are encouraged to allocate resources to programs and practices backed by strong evidence of effectiveness (outcomes) • “Because many Federal dollars flow to states, locals, others, grants reforms are an importance component . . .”

  17. SUPERCIRCULAR GRANT REQUIREMENTS • Federal agencies must include the performance to be achieved • Federal agencies must require recipients to relate financial data to performance • Federal agencies may include specific performance goals, indicators, milestones, or expected outcomes

  18. SUPERCIRCULAR GRANT REQUIREMENTS • Federal agencies are required to provide recipients (grantees) with clear performance goals, indicators and milestones

  19. SUPERCIRCULAR GRANT REQUIREMENTS Federal agencies may structure grant funding to include: • progress payments based on accomplishing milestones • unit price payments (unit of output, unit of service, outcome unit) • fixed price payments (one payment at end of grant)

  20. SUPERCIRCULAR IMPACT ON STATE & LOCAL GOVERNMENTS • The days of “gifts with strings attached” and “best efforts” are over • Grants will function more like contracts • Grant recipients will act more like administrative arms of the federal government • Grant recipients will have more responsibilities for sub-recipients

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