The Perils of Cut and Paste

May 10, 2013 | By Thompson Education | Post a Comment

imageSpeaking Wednesday at the annual Brustein & Manasevit spring grants forum in D.C., OMB official Gil Tran illustrated the perils of developing guidance by merging documents.

In the Office of Management and Budget’s so-called “super-circular,” the agency proposes a radical revamp of “time-and-effort” documentation in order to reduce the drain on grantee administrative resources and eliminate what has turned out to be the #1 source of audit findings.  This is one of the most important features in a mammoth project to merge several administrative circulars and establish consistent guidelines for all grantees. But the revision itself has people scratching their heads because it seems to set a lower standard for documenting the time of employees working on multiple federal programs than those working on a single program; this is the reverse of what you would expect.

The principle behind tracking time and effort is simple and commonsensical: Federal grantees must document how much time each of their federally funded employees spends on grants so the federal funds can be properly allocated to the appropriate program.  Under the current system, state or local employees who work full-time on a federal program (a single “cost objective”) need only file a semi-annual certification that they spent the previous six months solely that program. Anyone working on multiple cost objectives — that is, employees working on multiple federal programs or on one or more federal programs and a state or local program — must keep a monthly personnel activity report (PAR) tracking in detail exactly how much time they spend on each cost objective.

The complexities of this system have made it a nightmare to administer, and OMB proposes to replace the whole structure with “certified reports,” essentially an after-the-fact certification that the employee spent X percent of his time on cost objective(s) A, B, C, etc. Under the proposal, control systems to ensure the accuracy of the certifications must meet higher standards when the employee works on multiple cost objectives.  (See “General Provisions for Selected Items of Cost,” beginning on p. 86 of the super-circular.)

This seems simple enough (which is the point). But this is where things got strange with the proposal. If you work on a single cost objective, the certification may cover the previous six months. But if you work on multiple cost objectives, the certification may cover the previous 12 months. This has puzzled people from the day the proposed new circular came out in February.

It turns out that this is merely an “oopsy,” although a big one. According to Tran, this is the result of cutting and pasting from the various existing administrative circulars that will be replaced by the super-circular. Existing Circular A-21, which applies to colleges and universities, has long allowed a 12-month certification for “professorial and professional” staff, even if they work on multiple cost objectives. OMB mistakenly imported this 12-month period and applied it for all certified reports for multi-funded staff.

“The time periods will be aligned at six months,” Tran said.

Whew! Glad to get that sorted out! But it does indicate that OMB has a lot of work to do before the super-circular is ready for prime time. As he has before, Tran offered an optimistic projection for the date the revised document would go into effect: July 1, 2014. Attorney Michael Brustein said, “I’m not buying it,” and he said July 1, 2015, is more realistic.

Based on OMB’s history of missed deadlines, my bet is on Brustein.

What is your reaction to this? We’d love to hear it.

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