Sneak Preview: Agencies Failing To Comply with GPRMA Requirements

July 22, 2016 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) A recent Government Accountability Office (GAO) report found that many federal agencies did not properly report their major management challenges or their performance goals as required under the Government Performance and Results Modernization Act of 2010 (GPRMA) (Pub. L. 111-352). In response, GAO recommended that the Office of Management and Budget (OMB) clarify its guidance to federal agencies related to GPRMA requirements, and made other specific recommendations for the agencies it reviewed.

GPRMA, which amended the Government Performance and Results Act of 1993 (Pub. L. 103-62), requires federal agencies to identify and report on how they will resolve major management challenges (i.e., programs or management functions with a higher vulnerability to waste, fraud, abuse). Agencies are required to describe their major management challenges and provide a strategy for addressing them in their Annual Performance Plans (APPs). They also must report on their progress toward resolving these major management challenges in their Agency Performance Reports (APRs). OMB provides guidance to agencies on implementing these requirements in Circular A-11, Preparation, Submission and Execution of the Budget.

In addition, GPRMA also requires each agency’s Office of Inspector General (OIG) to prepare an annual statement summarizing what it considers to be the most serious management and performance challenges facing the agency and briefly assess agency progress in addressing those challenges. Agencies are also required to include these statements in their Performance and Accountability Report (PAR) if they prepare one, or alternatively, their Agency Financial Report (AFR). OMB guidance on preparing PARs and AFRs is contained in Circular A-136, Financial Reporting Requirements, which states that agencies should take steps to address challenges mentioned by the OIG.

After assessing APPs and APRs issued for federal fiscal year (FY) 2016 by the 24 federal agencies it reviewed, the GAO found that only 10 agencies described their major management challenges in their APPs as required. Six of the remaining agencies described their challenges in other publicly-available documents, such as their AFRs, GAO said, adding that while this may be transparent, it was not consistent with GPRMA requirements. GAO noted that OMB guidance addressing how agencies should report this information is unclear.

“We found that A-11 guidance creates ambiguity when the law is clear about expectations,” GAO explained. “Specifically, the guidance permits agencies that have provided information about their major management challenges in their AFRs to not report on major management challenges in their APPs.”

GAO further found that seven of the agencies it reviewed did not list major management challenges in their APP, AFR or other publicly available documents. GPMRA offers agencies discretion when identifying programs or management functions they deem to have greater vulnerability, and some agencies told GAO that it was not clear what to report if the agency determined it did not have issues that rose to the level of a major management challenge. GAO added that Circular A-11 provides no guidance on this.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

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