The Future Is Kind of Cloudy Right Now

May 14, 2013 | By Jerry Ashworth | 1 comment

1388426_crystalballOh, to have a crystal ball. We could look into it to determine how the Office of Management and Budget’s proposed grants reform guidance would turn out, and we could identify which grant programs drew the short end of the stick — or should I say by how much – due to budget cutting from the sequestration.

Alas, we here have no such thing. And even if we did, I’m not so sure a clear answer would be revealed.

Currently, what we do know is that OMB’s comment period for the proposed guidance ends on June 2. OMB officials have said that they hope to analyze the comments and finalize the guidance by the end of the year. That may or may not come to fruition. Even if it does, it still is “guidance,” and must be adopted by the federal agencies into their regulations. That process could take several months. We could be talking well into 2014 or even 2015 before grantees will have to comply with the new regulations, whatever the final product may be.

One of the interesting things to watch will be auditor reaction. Let’s assume they are finalized next year and adopted by agencies, will auditors immediately begin following the new requirements and audit programs from the prior year accordingly, even though the new requirements weren’t in effect during the period of the audit? All I know is that whenever this whole thing does go into effect, that particular year’s Circular A-133 Compliance Supplement is going to be a doozy!

Meanwhile, while grantees are clamoring to know how much funding their programs will have for the next year, the sequestration is causing agency officials pause as they struggle to deal with shrinking allocations themselves. Covering a couple of local conferences over the last week, I’ve noticed that the sequestration is causing almost every statement to have a caveat. Harkening back to the old saying “the days of wine and roses,” the new saying is now “in these days of sequestration, …” Whatever comes after that caveat generally is not great news.

I want to put out yet another pitch for grants and audit stakeholders to make sure they comment on the OMB’s proposal. Go to under “OMB-2013-0001” and let your concerns be known. There is less than three weeks left.

What do you anticipate will happen with the timing of the proposal, or the effects of the sequestration? We’d like to know what you think.


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