OMB: PMA Overlaps, Yet Separate, from §200.109 Requirement

April 4, 2018 | By Jerry Ashworth | Post a Comment

OMB-SealAt the National Grants Management Association’s (NGMA) annual grants training conference this week in Arlington, Va., we attempted to get some clarification from an Office of Management and Budget (OMB) official on a question we had about the uniform guidance, and we think we have our answer. Sort of.

Section 200.109 of the uniform guidance simply states that OMB will review this part (i.e., the uniform guidance) at least every five years after Dec. 26, 2013. Therefore, our understanding is that this means that the first review of the uniform guidance would occur in December of this year. However, we have heard of no discussion as yet that this review was taking place.

However, in March, the Trump administration released the President’s Management Agenda, which includes a strategic initiative specifically focused on grants management. This initiative seeks to standardize federal grant reporting data to reduce recipient burden and would develop a risk management tool to encourage better program results. We here at Thompson have written extensively about the President’s Management Agenda on our grants website.

Because this agenda appears to present the federal government’s priorities going forward, we questioned OMB’s Rhea Hubbard, the plenary session speaker at the NGMA conference, whether the President’s Management Agenda effectively addresses the review requirement mentioned in §200.109, or if there would be a separate effort to review the uniform guidance. According to Hubbard: “I don’t think specifically that’s what we had in mind when we released the President’s Management Agenda, but I think certainly this would be supportive of that five-year review. I can definitely see some overlap. We were aware of the requirement [in §200.109] and any review of the uniform guidance would be in lockstep with this.”

Ok, so maybe the President’s Management Agenda won’t take the place of the review, but OMB only has nine months remaining to meet the requirement of §200.109. I’m sure the grants community would appreciate any information beforehand about any potential changes that could be coming to the guidance that could affect their award programs. Keeping an open dialog is key.

Let us know your reaction to the President’s Management Agenda and about the §200.109 requirement. We’d love to hear from you.

As a reminder, we have all of our Federal Funding Training Forums scheduled for 2018. Please let me know if you have questions or can make any of these. We hope to see you there!

  • Monday April 16 – Wednesday April 18 in WASHINGTON, D.C.

  • Wednesday May 1 – Friday May 4 in ST LOUIS

  • Wednesday July 25 – Friday July 27 in MINNEAPOLIS

  • Wednesday October 17 – Friday October 19 in ATLANTA


OMB Says PMA Overlaps, But Still Separate, from §200.109 Requirement


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