Six Things To Watch For in Grants in 2017

December 28, 2016 | By Jerry Ashworth | Post a Comment

20172016At the end of the year, many news organizations often present a retrospective of what occurred the previous year. We prefer to look forward and provide an outlook as to what we think will be some of the biggest things to watch for in 2017. Here’s my list:

  1. Office of Management and Budget (OMB) proposed rule: Although we were expecting so see this proposed rule last fall, it has been delayed for several weeks now. We discussed this proposed rule in an earlier blog post. Since the release of 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, and the National Defense Authorization Act. The 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. Once the proposed rule is issued, the public will have an opportunity to comment on it so we here at Thompson will keep you abreast as to when it is actually released so that you can make your concerns heard.
  2. Revised Frequently Asked Questions to the uniform guidance: Again, we expected to see this last fall but we continue to wait for OMB and the Council on Federal Assistance Reform to issue it. The current document, which has about 100 questions and answers, has not been updated since September 2015. OMB officials have said that the revised 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.
  3. Incoming Trump administration: The effects on the grants community as a new presidential administration comes on board is currently still up in the air. However, there certainly will be change, and some current grant programs could be on the chopping block. Some experts anticipate that the federal government will need more revenues to cover the projected growth in mandatory spending, especially as more baby boomers file for social security, and that the Trump administration may also consider tax reform, spending cuts to discretionary programs and potentially implementing a federal government hiring freeze. Now is a good time to proactively tout the benefits of your programs with your awarding agency to avoid potential defunding when the Trump administration takes office, and make sure you have internal controls in place to avoid findings that could give awarding agencies a reason to defund your program. Following the guidance in Thompson’s publications can assist in that effort.
  4. DATA Act: Federal agencies are required to begin reporting spending data in accordance with the act by May 2017 and to publicly post spending data in machine-readable formats by May 2018. The agencies are still making preparations for this deadline and some agencies continue to struggle. Recipients of federal awards should be aware of the actions federal agencies are taking to comply with the DATA Act, as the DATA Act requires federal agencies to apply the governmentwide data standards to all grant recipients and contractor reporting by August 2018. Nonfederal entities also should investigate if their technology systems need any upgrades to ensure that they can produce data in consistent, open and machine-readable formats.
  5. Procurement grace period ending: Many research institutions are still following their procurement practices under the former OMB circulars, and are assessing the impact of the uniform guidance procurement provisions. Under the joint interim final rule in which OMB and 26 federal awarding agencies and offices adopted the uniform guidance into their regulations, OMB provided a procurement grace period of one fiscal year, specifically for nonprofit organizations, hospitals and institutions of higher education (IHEs), all of which previously followed Circular A-110 (§200.110). Through correcting amendments to the uniform guidance issued later in September 2015, OMB extended the grace period to two fiscal years. If a nonfederal entity has a June 30 fiscal year end, for example, the grace period has been extended from June 30, 2016, to June 30, 2017. Therefore, this grace period ends at the end of June and all awardees will now be required to follow the procurement provisions in the uniform guidance for awards received after Dec. 26, 2014.
  6. The Workspace requirement: Applicants for federal awards using Grants.gov have less than one more year remaining until they must prepare and submit their proposals and accompanying documents using Grants.gov’s Workspace portal, if they have not already done so. In December 2017, Grants.gov will phase out the legacy application package option most applicants now use when submitting proposals to the federal website. Grant applicants should take time during the upcoming year to become familiar with the Workspace portal, and Thompson’s publications can help keep you up-to-date with these changes.

This is what we see as big news in our crystal ball for 2017. We would like to hear your thoughts on other upcoming items of grants interest.

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