Are You Ready For This? The New Uniform Grant Guidance and Movements in Federal Spending Transparency May 20, 2014

2 Increase in Federal Grants Activity $7B $24B $91B $200B $600B The Catalog of Federal Domestic Assistance lists over 2,000 Federal grant programs

3 Council On Financial Assistance Reform Priorities Guidance Targets Risk & Minimizes Burden Standardized Business Processes & Data Well Trained Workforce Strong Program Oversight: Audit Resolution Better Outcomes for Grants Evidence Spending Transparency Shared Services Financial Management

4 Guidance Reform History Nov. 2009: Executive Order: Reduce Improper Payments Feb 2011: Presidential Memo: Reduce Administrative Burden Feb 2012: Advance Notice of Proposed Guidance (public comments) Feb 2013: Notice of Proposed Guidance (public comments) Dec 2013: Final Uniform Guidance

5 Diverse Range of Stakeholders Engaged Type of Institution RepresentedExamples State GovernmentsNASACT NASCIO NonprofitsNational Council of Nonprofits AuditorsAICPA CIGIE Indian TribesNAFOA GAO Grants ProfessionalsAGA NGMA UniversitiesCOGR AAU APLU

6 “OMB Simplifies Government-wide Grant Guidance” “A Whole New World: OMB Publishes New Grants Reform Guidance” December 2013: Final Uniform Guidance

7 Eliminating Duplicative and Conflicting Guidance Awards Received A-102 & A-89 A-87 A-133 &A-50 Subawards to universities A-110 A-21 Subawards to nonprofits A-110 A-122 INSERT YOUR STATE OR AGENCY HERE Now: All OMB guidance streamlined in 2 CFR 200. Then:

8 2 CFR 200 -Basic Layout 6 Subparts A through F – Subpart A, 200.XX – Acronyms & Definitions – Subpart B, 200.1XX – General – Subpart C, 200.2XX – Pre Award – Subpart D, 200.3XX – Post Award – Subpart E, 200.4XX – Cost Principles – Subpart F, 200.5XX – Audit 11 Appendices - I through XI

9 Challenge & Impact Challenge Under Previous GuidanceImpact of New Uniform Guidance 1. Eight Overlapping Sets of Compliance Requirements Eliminates Duplicative and Conflicting Guidance 2. High Levels of Administrative BurdenPerformance and Internal Controls Over Compliance for Accountability 3. Hundreds of Forms with Non-Standard Data Definitions Provides Framework for Standard Business Processes & Data Definitions 4. Outdated Guidance Does Not Account for Modern Electronic Work Environment Promotes Efficient Use of IT and Shared Services 5. Inconsistent and Non-Transparent Treatment of Costs Requires Consistent and Transparent Treatment of Costs 6. Lack of Support for Policies with Work-Life Balance Encourages Non-Federal Entities to Have Family-Friendly Policies 7. Audit Findings Repeated Each Year = Waste Stronger Oversight & Target Audits on Risk of Waste, Fraud, and Abuse 8. Lack of Accountability for Effectively Correcting Financial Integrity Weaknesses Increased Accountability for Effective Resolution of Weaknesses

10 December 2013: Uniform Guidance Published January-April 2014: Training Webcasts, Single Audit & Other Metrics, Publish 2014 Single Audit Compliance Supplement June 2014: Agencies Submit Draft Rules to OMB, Continued Outreach on Implementation December 2014: Final Guidance Effective, Baseline Metrics Collected, Case Studies of Best Practices Published Guidance Reform Future Summer 2014: Federal Grants 101 Course Published

11 Guidance Metrics Metrics to gauge impact of guidance on reducing the risks of non-compliance and unnecessary administrative burden Possible General Metrics: Number of OMB Approved Exceptions Number of fixed amount awards issued Number of IDC rate extensions approved by Cognizant Officials

12 Guidance Metrics Possible Audit Metrics: # of major programs before and after guidance effective % of timely submissions of single audits # of repeat findings # of ‘unclean’ opinions for major programs # of material audit findings in single audits

13 Strong Program Oversight: Audit Resolution 13 Over 4,000 audited programs failed to receive clean opinions in 2011 (3% of total audited programs) No existing guidance holds agencies and recipients accountable for effectively correcting financial integrity weaknesses Challenge September 2013: High risk programs and recipients identified November 2013: CAROI pilot results presented to COFAR principals Accomplishments

14 Strong Program Oversight: Audit Resolution 14 December 2013: Document best practices on CAROI to contribute to resource repository February 2014: Complete framework for 2014 Compliance Supplement (w/preview of guidance implementation) March 2014: Finalize Single Audit Metrics April 2014: Compile and publish existing Federal agencies’ audit resolution policies April 2014: Publish 2014 Compliance Supplement June 2014: FAC to deliver available standard and ad hoc reports and analytical tools Short Term Deliverables July 2014: Reconvene to plan management decision letter pilot December 2014: Publish any proposal to revise Data Collection Form and SEFA Long Term Deliverables

15 Workforce Development Lack of consistent standards for qualifying people to perform the grants management function No government-wide core training requirement for people performing the grants management function Challenge December 2013: Competencies established December 2013: Resource repository built, available for use, and in testing phase Accomplishments

16 Workforce Development April 2014: Knowledge-Sharing Resource Center available for sharing ideas and best practices Summer 2014: Publish Grants Management 101 Course Short Term Deliverables October 2014: Reconvene to discuss long-term vision and possible industry-wide credentialing framework Long Term Deliverables

17 Grants Workforce Competencies

18 Federal Grants Workforce Training Grants Workforce Grants 101 Course Knowledge- Sharing Uniform Guidance

19 Grants Data Standardization Over 700 distinct grant related forms approved in OMB database No current process to vet and validate existing data elements nor to create and validate new data elements Multiple stakeholders must be engaged to fully explore grants data standards and chart a successful path forward Non-standard data definitions compromise quality of publicly reported financial data Challenges September 2013: Preliminary analysis of 1100 data elements September 2013: Contract awarded to support further analysis of data elements and development of governance framework December 2013: 99 standard definitions in final guidance Accomplishments

20 Grants Data Standardization December 2013: Grants data standardization proposed vision, project outline, and governance framework March 2014: HHS to brief COFAR on grants data standards records repository functional requirements Short Term Deliverables June 2014: Brief COFAR on proof of concept for grants data standards July 2014: Reconvene to plan additional long term deliverables based on HHS and Treasury short term deliverables. Long Term Deliverables

21 Federal Spending Transparency Now USAspending.gov: View all types of federal award spending Recovery.gov: View Recovery Act spending Federal agencies validate the financial data, per OMB’s June 2013 Memo Treasury Department is the program manager, per the FY14 Consolidated Appropriations Act

22 The Path Forward on Transparency: FY14 and Beyond -FY 14: Upgrade look & feel of USAspending.gov - Beyond: DATA Legislation – Expansion of Data Posted on USAspending.gov – Establishment & Implementation of USAspending.gov Data Standards – Recommendations for Streamlined Recipient Reporting Burden – Establishment of a Data Analysis Center – Requirement to Report Non-Tax Debt

23 Engage With COFAR For More Information Visit: CFO.gov/COFAR Send Questions To: omb.eop.gov Thank you!