The Time Is Now to Let Your Voice Be Heard!

February 28, 2012 | By Jerry Ashworth | 1 comment

It’s real simple — after reading this blog post, go directly to this link in today’s Federal Register and prepare to submit your comments on the Office of Management and Budget’s newly proposed guidance that could drastically change current grants management and single audit practices. This is the most earthshaking thing to hit federal grants since last summer’s D.C. earthquake!

Because the comment due date is March 29 at 5 p.m. EST, you don’t have much time. Comments can be sent directly to OMB at, or via the National Grants Management Association by sending an email to, which will be partnering with other professional organizations to synthesize and submit comments from across the grants community. Personally, I sincerely hope OMB realizes the magnitude of this proposal and offers to extend the comment period.

When we first brought this to your attention in a blog post last Friday, we gave you a taste of some of the proposed revisions to OMB Circular A-133 for single audits and to the three cost principle circulars. The proposed guidance also would alter requirements in the grants administrative circulars (Circulars A-102 and A-110). OMB is proposing to consolidate the two circulars into a uniform set of administrative requirements, although it would offer limited exceptions by type of recipient. It would also require grantor agencies to consider the merit of each proposal and each applicant’s financial risk to ensure greater transparent and encourage a higher quality of awarded projects to reduce the risk of fraud, waste and abuse.

Other proposed reforms to the grants administrative circulars include:

  • requiring agencies to provide a 90-day notice of funding opportunities in a new Catalog of Federal Financial Assistance that will replace the existing Catalog of Federal Domestic Assistance (stay tuned, this most assuredly will be discussed in a future blog post!);
  • providing a standard format for announcing funding opportunities that would require specific eligibility or qualification information and a clear description of all criteria used in agency review of applications; and
  • reiterating that information collections are subject to Paperwork Reduction Act approval.

The final section of the Federal Register announcement includes a long list of questions about the reforms that are of the most interest to OMB. Refer to that list and use it as your guide in letting OMB know your issues and concerns. OMB will subsequently review the comments before issuing its final guidance. The pace at which OMB will eventually develop final guidance will depend on the volume of comments it receives on the proposed reforms.

Organizations representing state and local governments, the professional grants industry, and audit/accounting firms are already preparing formal responses to the proposed reforms. Don’t let your voice go unheard! And stick with Thompson’s Federal Grants Management Handbook and Single Audit Information Service to get the latest developments and analysis.

Have you had a chance to review the proposal? Anything stick out as a major red flag or, on the other hand, a truly beneficial change? Let us know!


One Trackback

  1. By The Clock Is Ticking! | Funding Attractions on March 7, 2012 at 6:06 am

    [...] 29 to its recent advance notice of proposed guidance, which we’ve covered extensively in recent blog posts. I understand the typical federal comment period is 30 days, but there are many facets to this [...]

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