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Reducing Red-Tape to Improve Outcomes The Council on Financial Assistance Reform Initiatives. March 12, 2014. Increase in Federal Grants Activity. The Catalog of Federal Domestic Assistance lists over 2,000 Federal grant programs. $600B. $200B. $91B. $24B. $7B.
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Reducing Red-Tape to Improve Outcomes The Council on Financial Assistance Reform Initiatives March 12, 2014
Increase in Federal Grants Activity The Catalog of Federal Domestic Assistance lists over 2,000 Federal grant programs $600B $200B $91B $24B $7B
December 2013: Final Uniform Guidance “A Whole New World: OMB Publishes New Grants Reform Guidance” “OMB Simplifies Government-wide Grant Guidance”
Eliminating Duplicative and Conflicting Guidance Then: INSERT YOUR STATE OR AGENCY HERE Now: All OMB guidance streamlined in 2 CFR 200.
Performance Over Compliance for Accountability • Emphasis on strong internal controls and reduction in specific compliance requirements • Example: Specific examples of justification for salaries and wages eliminated for more flexibility in implementing a strong system of internal controls • Alignment with M-13-17 encouraging innovative program design based on evidence • Performance measurement aimed at developing lessons learned • Fixed amount awards aimed at performance milestones
Consistent and Transparent Treatment of Costs • Voluntary Committed Cost Sharing is not expected under research awards • Pass-through entities must provide an indirect cost rate for subawards • Standards for treating admin costs as direct • High bar for circumstances where agencies may deviate from Federally negotiated rates • Option to extend rate for up to 4 years • De minimis rate of 10% of MTDC for entities without a Federally negotiated rate
Standard Business Processes & Data Definitions • Sets framework for standardizing data definitions in all grants-related forms governmentwide • Standardizes format for notices of funding opportunities w/60 days to apply • Standardizes Information to be provided in all Federal Awards and Subawards • Highlights areas where specific agency approval is needed
Family-Friendly Policies • Where 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 travel • Allows family leave as a fringe benefit
Stronger Oversight • Requires mandatory disclosures for conflict of interest and criminal violations • Requires pre-award review of merit of proposal and risk of applicant • Federal agencies may assign specific conditions for awards based on risk • Strong focus on internal controls
Targeting Waste, Fraud, and Abuse • Single 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 tribes • Senior Accountable Official to implement metrics and encourage cooperative resolution • Strong requirement to rely on existing audits first
Stakeholder Reactions • Significant interest in training webcast held January 27, 2014 & future outreach • Over 5,000 registrations for mailing list • Recorded version will be available at CFO.gov/COFAR • General recognition of significance of reform • Interest in resources to assist in smooth implementation
Guidance Metrics Metrics to gauge impact of guidance on reducing the risks of non-compliance and unnecessary administrative burden Possible General Metrics: • Number of OMB Approved Exceptions • Number of fixed amount awards issued • Number of IDC rate extensions approved by Cognizant Officials
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
Council On Financial Assistance Reform Priorities Spending Transparency Evidence Better Outcomes for Grants Financial Management Shared Services
Framework for 2014 COFAR Activities All deliverables will be strategically aligned to support effective implementation of guidance reform with minimum resource burden to Federal agencies and non-Federal entities.
Federal Spending Transparency • Quality: Improving data integrity • Completeness: Expanding the focus to include obligations and expenditures • Functionality: Providing a one-stop location for all Federal spending • Utility: Linking spending information to program activity
Engage With COFAR For More Information Visit: CFO.gov/COFAR Send Questions To: COFAR@ omb.eop.gov Thank you!