OMB Discusses Pending Grants Proposal, Revised FAQ Release

November 16, 2016 | By Jerry Ashworth | Post a Comment

question-icon-1147668-mThere still are a lot of questions left but at least we know a little bit more about the “what,” even though were are still left empty on the question as to “when.” Let me try to clarify a bit.

A week or so ago, we were told by the Office of Management and Budget (OMB) that they were planning to issue a proposed rule soon that would affect the OMB uniform grant guidance and other grant regulations under Title 2 of the Code of Federal Regulations (C.F.R.). At the recent Maryland Governor’s Grants Conference on Monday in College Park, Md., the OMB’s Gil Tran provided a few more details as to what will be included in the proposed rule.

Since OMB originally released the uniform guidance in December 2013, several recent pieces of legislation have emerged that have necessitated some adjustments to language in the uniform guidance. These include the Digital Accountability and Transparency Act (DATA Act) (Pub. L. 113-101), Grants Oversight and New Efficiency Act (Pub. L. 114-117), Never Contract with the Enemy Act, as well as Section 872 of the Duncan Hunter National Defense Authorization Act of 2009 (Pub. L. 110-417), which required integrity in grantmaking and the use of the Federal Awardee Performance and Integrity Information System (FAPIIS).

Tran also said that the OMB proposal also would implement consistent use of certain terms throughout Title 2 of the C.F.R., and seek to provide more clarity in the areas of grants procurement and subrecipient monitoring. However, the one piece of specific information Tran could not give us was when this proposed rule will be issued in the Federal Register. The proposal is still going through the federal clearance process. Tran had hoped that the proposal would be released by the end of the month, but that’s not certain. We here at Thompson will continue to track this on a daily basis.

Everyone in the grants community should stay abreast of this proposed rule and aim to understand how the proposed changes may impact their organizations. OMB will take comments on the proposal so your input could be critically important to help OMB properly address this wide range of matters.

Not to be forgotten, the OMB also is updating its Frequently Asked Questions (FAQ) document related to the uniform guidance. The current document, which has about 100 questions and answers, has not been updated since September 2015. In an earlier blog post, we questioned when this document was to be released, as we have heard for quite some time that it was to be issued this fall. Again we asked Tran if he had an expected date for this document to appear on the Council on Financial Assistance Reform (COFAR) website, and he maintained that he was hopeful that it would be released by the end of November. He was able to share that the document will contain 20 new questions, many of which pertain to indirect costs and the new 10 percent de minimis indirect cost rate. We also will be keeping our eye on this document to let our subscribers know what it contains and how these FAQs apply to your grants oversight.

Let us know what you would like to see addressed in the proposed rule or the revised FAQ. We’d love to hear from you.


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