Sneak Preview: Memo Addresses Disaster Fund Oversight, Waivers

April 13, 2018 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The Office of Management and Budget (OMB) recently issued guidance to federal agencies overseeing disaster relief funds available under the Bipartisan Budget Act of 2018 (Pub. L. 115-123), which, among other funding, provides about $84.4 billion in emergency supplemental appropriations for awards to respond to and recover from recent hurricanes, wildfires and other disasters. Agencies are to use the guidance to develop and submit internal control plans to OMB. займ без процентов поиск мфо

The act requires federal agencies to ensure that grant recipients expend all awarded disaster relief funds within the 24-month period following the agency’s obligation of those funds, unless waived by the OMB director. Further, each agency must include a term in the grant’s terms and conditions requiring the recipient to return to the agency any funds not expended within the 24-month period following the agency’s obligation of funds for the grant.

To help federal agencies respond to this requirement, OMB Director Mick Mulvaney issued a memorandum (M-18-14) stating that agencies in their internal control plans must specify the criteria they will use for approval of grant applications or proposed plans for the use of disaster relief grant funds, and ensure each proposed grant activity has clear timelines for completion within the period available for which grant recipients may expend funds. Although OMB may waive or extend this period for certain programs and expenditures, the guidance states that each agency must ensure that any such extension requests are limited to only those activities “that are long-term by design or where it is impracticable to expend funds within the 24-month period and still achieve program missions.” The guidance further notes that OMB will grant waivers “only on a case-by-case basis, where such requests are justified by compelling legal, policy or operational challenges and consistent with applicable laws.”

The guidance includes a “grant funds extension request note” and template that agencies may use for extension requests. The request note states that OMB will consider the following criteria when evaluating waiver requests: (1) the optimal timeline for achieving the stated objectives of the program or activity; (2) the historical outlay rate of the program; (3) the ability of the program to accelerate from its historical outlay rate; and (4) internal controls, including agency capacity for grant recipient oversight, that are likely to promote accountability in the event a waiver is granted. Each waiver request should specify the types of activities and associated funds within the program or activity that require a waiver, according to OMB.

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

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


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