The Time is Now for Feds To Submit Grant Draft Guidance Implementing Regulations

June 26, 2014 | By Jerry Ashworth | Post a Comment

PB270341When I was a kid growing up near Atlanta, we took many family trips to Stone Mountain Park. A highlight of the trip was going to the top of the mountain, and you had two options to get there. You could take the easy way out and ride the cable car to the summit, or venture up the rugged mile-long walking path to the top. Always up for a challenge, I preferred the latter option, even though hiking a mile uphill (often on a hot summer day) was never easy. Halfway to the top along the path, there used to be a structure known as the “Halfway House.” Although it no longer exists, seeking the halfway house always gave me a mental boost to know that the beginning of the journey was over and the summit was now within reach.

Ladies and gentlemen, we’ve now reached the halfway house in terms of the Office of Management and Budget’s uniform grant guidance, which was issued on Dec. 26, 2013. In the supplementary material with the guidance, OMB states that federal agencies must submit draft implementing regulations to OMB no later than six months from the date of publication of the guidance, unless different provisions are required by statute or approved by OMB. That six month date is today. We know that the National Science Foundation as already submitted its draft policy, with two relatively minor deviations from the uniform guidance, and has received OMB approval. We’re waiting to see what is included in the draft regulations from the other agencies.

Just to clarify: Even though the agencies are submitting draft regulations to OMB, they are not considered final and effective. All agency regulations implementing the guidance will become effective on Dec. 26, 2014. We may see some agencies posting their draft regulations in the Federal Register for public comment on certain provisions. However, these agency regulations are not expected to differ greatly from the uniform guidance, but will explain how the uniform guidance will apply to their particular programs. OMB must approve any deviations.

Now that we’ve reached the uniform guidance “halfway house,” let that serve as a reminder for nonfederal entities out there to get up to speed with the changes and requirements in the uniform guidance and to update their internal policies. Now is not the time to read the guidance for the first time. Traditional grants processes will change so don’t get left behind. The Dec. 26, 2014, summit is closer than you think!

What are you waiting to find out in the agency regulations? Let us know.

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