Enhancing Accountability in Federal Grant Management
The OMB Open Comment Period focuses on updates to align with the President's Management Agenda, including increasing micro-purchase thresholds, aligning with NDAA section 889, and emphasizing stewardship and accountability in grant programs. The proposed changes aim to provide clarity, streamline processes, and improve monitoring of federal awards, aiming at effective results and accountability.
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Presentation Transcript
OMB Open Comment Period Why Now: 5 Year Lookback at OMB Uniform Guidance Offer More Clarity Align with President's Management Agenda Results Oriented Accountability What do we focus on: Subpart D, 200.3XX Post Award
OMB Open Comment Period Micro-Purchase Thresholds Raises micro-purchase threshold from $3,500 to $10,000 and simplified acquisition threshold from $100,000 to $250,000 for procurements under the FAR Apply to All Federal awards and All recipients OMB implementing an exception to the UG to allow use for Federal awards: 2 CFR 200.67 Micro-purchase 2 CFR 200.88 Simplified No provision for higher threshold request for all recipients through OMB but might be requested through local cognizant agency
OMB Open Comment Period Purchasing Bear Claw Source: Gil Tran Presentation at FRA March 2020
OMB Open Comment Period Other Purchasing Guidance Aligning 2 CFR with the 2019 NDAA section 889 Prohibition on certain telecommunication and video surveillance services or equipment, which prohibit Federal award recipients from using government funds to enter into contracts (or extend or renew contracts) with entities that use covered telecommunications equipment or services. Aligning 2 CFR with the General Accepted Accounting Principles conform with Generally Accepted Accounting Principles (GAAP) continue to claim pension costs that are both actual and funded
OMB Open Comment Period Other OMB Updates Emphasizing stewardship and results-oriented accountability for grant program results agency merit review process paperwork reduction strengthen the ability of the Federal awarding agency to terminate Federal awards Encouraging agencies to measure recipient performance to improve program goals and objectives, share lessons learned, and spread the adoption of promising practices. May ask recipients to link financial reports to performance, not required. Standardization of terminology and implementation of standard data elements brings us closer to standard grant formatting Some examples of proposed revisions include terms associated with time periods (period of performance, budget period and renewal), and financial obligation Making indirect cost rate agreements transparent
OMB Open Comment Period Subrecipient Monitoring NEW SUBPARAGRPH: (4) The pass-through entity is only responsible for resolving audit findings specifically related to the subaward (i.e., non-systemic) and not applicable to the entire subrecipient (i.e., systemic). If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding(e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient s auditors and cognizant agency for routine audit follow-up and management decisions. Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward issued by the pass-through entity.
