Say Goodbye to 2015 and Hello to 2016!

December 30, 2015 | By Jerry Ashworth | Post a Comment

confetti-2-1299806-mWe are counting down the final hours of 2015 and preparing for a bright new 2016! It will be interesting to see what changes are in store for grant applicants and recipients next year. Maybe next year won’t be quite as challenging as the last couple of years with all the changes we’ve experienced under the Office of Management and Budget’s uniform grant guidance, but who knows what we shall expect.

Let’s look back at some of the key moments in grants from 2015. Because the uniform guidance became effective for nonfederal entities as of Dec. 26, 2014, that meant that all funding received on or after that date — thus all 2015 award funding — must follow the uniform guidance. For those entities more familiar with guidance under the former OMB circulars, this may have been quite a challenge to get up to speed on the new guidance. We here at Thompson did our best to make the uniform guidance easier to understand and inform you of its intricacies.

And then this July, OMB came out with a final rule implementing Section 872 of the Duncan Hunter Act. This act requires federal agencies to qualify federal contractors based on integrity data and to post their determinations in a federal web portal and repository, currently the Federal Award Performance Information and Integrity System, or FAPIIS. The final rule extended Section 872 from the federal contract community to the grants community. Applicants, therefore, will now be subject not only to merit and risk reviews, but also to integrity reviews. Recipients will face both risk and integrity reviews. A poor review can label you as “not qualified” for federal funds, and will be posted publicly in FAPIIS for five years. The uniform guidance and the Code of Federal Regulations (C.F.R.) were revised on July 30 to incorporate language from the Section 872 guidance, and these provisions will become applicable Jan. 1, 2016 – that’s this Friday!

Because this “not qualified” designation will be posted in FAPIIS for five years, any federal agency planning to make a federal award will see that designation. This new protocol is not an official suspension or debarment, but it sure can affect a nonfederal entity’s eligibility, not only for one award, but for all federal awards.

OMB and the Department of Treasury also took their first steps in implementing provisions under the Digital Accountability and Transparency Act (DATA Act). Check out more about this by going to our blog post here. In addition, the Department of Health and Human Services also is leading a pilot to test ways to use standard data elements to improve grants management. We will be monitoring the DATA Act progress closely over the next few years.

And now we’ve come to 2016. One thing for auditors to note now is that for all audits they conduct of fiscal years ending Dec. 26, 2015, or later, these audits must now follow Subpart F of the uniform guidance rather than Circular A-133. Grant recipients should be aware of the new threshold requirement under Subpart F, which is $750,000 in federal awards spent annually, rather than $500,000 in federal award spent annually.

Subscribers of Thompson’s grants publications will be up to speed on anything new affecting the grants community in 2016. Let us know how we can continue to provide the information you need.

What events in 2015 had a great effect on your grants and what are you looking forward to in 2016?


Post a Comment

Your email is never shared. Required fields are marked *