Please, OMB, Put Me Out of Business

October 11, 2012 | By Thompson Education | Post a Comment

(The following post was published on Thompson’s education blog, Title 1-derland.) I think the Office of Management and Budget (OMB) is missing a good chance to put me out of business.

I’ve got a sweet little deal here, getting paid to explain the complexities of OMB administrative “circulars” to grants managers who are trying to find their way through intimidating regulations specifying everything from which costs are eligible to how to audit the grants.

It’s an honest day’s work, but, as a citizen, I admit it would be better if my function were unnecessary.

Hence, I was disappointed when OMB’s recent proposal to revamp some major policies in its cost and audit circulars said nothing about cleaning up longstanding ambiguities that have bedeviled grants managers for years. A prime example is the definition of “cost objective,” which I have written about for years (for examples, see here and here). The U.S. Department of Education (ED) recently issued its own clarification of the term. But ED is only one federal agency, and the circulars apply across the government. Why not spread the enlightenment to other federal agencies by incorporating ED’s common-sense interpretation directly into Circular A-87 (which governs cost objectives for state and local governments, including schools)?

And this might be a good time to fold in some of the explanations embedded in a useful but obscure document issued in 1997, A Guide for State, Local, and Tribal Governments (ASMB C-10). ASMB C-10 elucidates some of the trickier elements of Circular A-87. Although it helps explain an OMB document and was created at the direction of OMB, it was actually written and published by the Department of Health and Human Services (HHS), the largest grant-making agency.

The problem with ASMB C-10 is that most grant managers don’t know it exists. (You can tell someone is a real grants maven when you say “HHS Guide” or “ASMB C-10” and you get anything other than a blank stare.) In an audit performed by ED’s Office of Inspector General in 2007, the OIG referred repeatedly to ASMB C-10, but the state defended itself by asserting,

ED has not held the OMB Circular A-87 Implementation Guide out to the public as an important source for policy interpretation. The Implementation Guide has not been identified in ED’s Grant Award Notifications or referenced in the relevant ED policy letters. [Further], the Implementation Guide is not on either the ED or OMB websites.

One solution to this obscurity would be to include some of the guidance in this hard-to-find document directly in the circulars themselves, rather than exiling it to the HHS website. At the very least, an updated version of this aging document should be published — and adequately disseminated — in the wake of any new revision of the circulars themselves.

OMB’s proposed revisions, such as consolidating its cost circulars and lifting the “single audit” mandate for small grantees, are pretty revolutionary and, hence, have garnered all the publicity. But failure to perform a thorough house-cleaning of the circulars is a real missed opportunity.

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