If you’ve ever purchased a home, you may have gotten this nervous feeling in your gut during the closing. Remember how you were presented with a stack of documents to sign with tons of legal language. Then you were asked to sign your name on the bottom line confirming that you agree with the aforementioned information. When we were buying our house, all I could think of was, “Should I really be signing this just because I was told to?”
Under the Office of Management and Budget’s new grants reform guidance, recipients of federal awards may experience that same sense of unease because of a new requirement regarding financial reports.
In §200.415, OMB sought to assure that expenditures are proper and comply with the award’s terms and conditions by requiring that project budgets, annual and final fiscal reports or vouchers requesting payment under the agreement include a certification, signed by an official who is authorized to legally bind the nonfederal entity, stating: “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award. I am aware that any false, fictitious or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.”
Did you catch that last part? “May subject me to criminal, civil or administrative penalties.” Yikes! Frankly, I feel for the entity official whose job it is to sign that certification. You may have instances where the official may be 98 percent certain that all the information was accurate, but that remaining 2 percent of uncertainty could rattle some nerves. True, the phrase “to the best of my knowledge,” may give the official something to fall back on, but this new requirement , although it has great intentions, definitely can create some grantee anxiety.
Ken Dieffenbach of the Department of Justice’s Office of Inspector General on Wednesday told attendees at the National Grants Management Association’s monthly training meeting that “this is a standardized, clearer certification that, at a minimum, will make grantees think twice to read the report and determine if it’s really accurate.” I certainly have to agree with him there.
What do you think about this new certification? Is it too harsh? Will it create grantee anxiety or am I off base? Let us know.