What’s New & What’s Next in Federal Grants Management March 22, 2013 ACT-IAC Grants Management Workshop Report Published: December 2013

SYNOPSIS On March 22, 2013, the Grants Management Working Group held a four-hour workshop attended by 39 government employees and 45 industry participants. Keynote speaker Norman Dong, Deputy Comptroller, Office of Management and Budget (OMB), discussed efforts to improve the management of federal grant dollars. Key OMB focus areas include reform of grants management guidance, data standardization, spending transparency, training and certification of the grants management workforce, and resolution of audit findings. Next, a panel of federal grants management experts discussed the challenges they face in managing grant programs in today’s federal environment. Agencies represented included the Departments of Justice (DOJ), Health and Human Services (HHS), Housing and Urban Development (HUD), Transportation (DOT), Agriculture (USDA) and the National Science Foundation (NSF). The workshop concluded with small, in-depth group discussions on four key grants management challenges: finance, transparency, risk, and professionalism. Attendees agreed that the OMB focus areas are important for improving federal grant programs. However, concerns over dwindling resources coupled with workforce challenges will make significant improvement difficult over the next several years. This document is a report on the activities and discussions that individual from government and commercial organizations had during this workshop. All information contained within this document does not reflect the official opinion of the Federal Government or any agencies thereof.

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

American Council for Technology-Industry Advisory Council (ACT-IAC) The American Council for Technology (ACT) is a non-profit educational organization established in 1979 to improve government through the efficient and innovative application of information technology. In 1989 ACT established the Industry Advisory Council (IAC) to bring industry and government executives together to collaborate on IT issues of interest to the Government. ACT-IAC is a unique, public-private partnership dedicated to helping Government use technology to serve the public. The purposes of the organization are to communicate, educate, inform, and collaborate. ACT-IAC also works to promote the profession of public IT management. ACT-IAC offers a wide range of programs accomplishing these purposes. ACT-IAC welcomes the participation of all public and private organizations committed to improving the delivery of public services through the effective and efficient use of IT. For membership and other information, visit the ACT-IAC website at www.actgov.org. Collaboration & Transformation SIG Grants Management Working Group The Collaboration & Transformation (C&T) Shared Interest Group (SIG) provides a forum for government and industry to identify and candidly discuss e-Government and to facilitate the realization of the concept's promise. The Grants Management Working group, a sub-element of the C&T SIG Financial Management Committee, provides a forum for on-going discussions, information sharing, and education for grants management professionals. The Working Group conducts research, identifies best practices and innovative and emerging technologies, provides clarity regarding potential future trends, and identifies performance improvement methodologies and metrics. Disclaimer This document has been prepared to provide information regarding a specific issue. This document does not – nor is it intended to – take a position on any specific course of action or proposal. This document does not – nor is it intended to – endorse or recommend any specific technology, product or vendor. The views expressed in this document do not necessarily represent the official views of the individuals and organizations that participated in its development. Every effort has been made to present accurate and reliable information in this report. However, ACT-IAC assumes no responsibility for consequences resulting from the use of the information herein. Copyright ©American Council for Technology, 2013. This document may not be quoted, reproduced and/or distributed unless credit is given to the American Council for Technology-Industry Advisory Council. Further Information For further information, contact the American Council for Technology-Industry Advisory Council at (703) 208-4800 or www.actiac.org. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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Table of Contents Executive Summary ........................................................................................................ 1 Keynote Presentation: Norman Dong, Deputy Comptroller, OMB ................................... 1 Panel Discussion ............................................................................................................. 3 Breakout Session Discussions ........................................................................................ 4 Transparency/e-Gov/Technology/Efficiency ......................................................... 4 Financial Management ......................................................................................... 4 Professionalism .................................................................................................... 5 Risk Management................................................................................................. 5 Workshop Format and Agenda ....................................................................................... 7 Appendix A: OMB Improving Management of Federal Grant Dollars Briefing ................. 9 Appendix B: Prepared Questions for Breakout Sessions .............................................. 16 Transparency/e-Gov/Technology/Efficiency ....................................................... 16 Financial Management ....................................................................................... 16 Professionalism in Grants Management ............................................................. 17 Risk Management............................................................................................... 17 Appendix C: Detailed Breakout Session Notes ............................................................. 20 Transparency...................................................................................................... 20 Financial ............................................................................................................. 21 Professionalism .................................................................................................. 21 Risk Management............................................................................................... 23 Matching and Improper Payments ...................................................................... 26 Duplication .......................................................................................................... 27 Grants Management and Acquisitions Management Comparison ...................... 28 Debarment and Suspension ............................................................................... 29 Matching ............................................................................................................. 29 High-risk Grantees.............................................................................................. 30 Improper payments............................................................................................. 30 Federal Audit Clearinghouse .............................................................................. 31 Audit ................................................................................................................. 31 Appendix D: Organizations Present At Conference ...................................................... 33 Appendix E: Workshop Attendee Feedback .................................................................. 34 Grants Management Workshop Report Authors & Affiliations ....................................... 36

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Executive Summary Recent policy initiatives, such as the proposed OMB “super-circular” and Public Law 106-107, have encouraged greater consistency across federal agency grant operations. As these and other policy initiatives are implemented, new challenges have surfaced that require interagency and government-industry discussion and sharing of best practices in order to be resolved successfully. On March 22, 2013 the ACT-IAC Grants Management Working Group staged a workshop attended by 39 government employees and 45 industry participants to discuss these new grants management issues, challenges, and trends. The workshop was keynoted by Norman Dong, Deputy Comptroller, Office of Management and Budget (OMB), who presented the Council on Financial Assistance Reform’s (COFAR) priorities for FY2013 to FY2015. With over $600B in funding, grants now exceed the amount of contract dollars spent by the Federal Government. OMB and COFAR have established a five-point agenda focused on improving the management of federal grant dollars: 

Reform grants management circulars to streamline and clarify guidance, provide consistency on indirect cost rates, and reduce administrative burden,



Standardize grants data by revising pre- and post-award data elements and allowing non-standard form approvals to expire, thereby reducing the over 700 distinct grant related forms approved in OMB’s database,



Increase spending transparency by publishing guidance on data oversight and internal controls, and by publishing a payment information repository,



Develop the grants management workforce by establishing core competencies for grants managers and by establishing a government-wide resource repository that agencies can leverage to train their workforce, and



Resolve audit issues by developing corrective action plans for material audit findings on High-risk programs and measuring agency progress on resolving the audit issues.

Next, a panel of five federal subject matter experts participated in a Q&A session focused on leadership challenges and best practices in grants management today. Key challenges were identified, including keeping pace with the volume of grants and dollars being awarded and hiring and training the pipeline of future federal grant program managers. Best practices discussed included mining grants data (i.e., analytics and big data) to help manage risk and applying technology to help address challenges across the full lifecycle of grants. The workshop wrapped up with small, in-depth group discussions on four key grants management challenges: finance, transparency, risk, and professionalism. The discussions generated many ideas on best practices and new policy/program considerations for grants management.

Keynote Presentation: Norman Dong, Deputy Comptroller, OMB In FY2010, grant spending totaled over $600B, exceeding federal contract spending. As grant funding continues to grow over time, federal agencies are facing significant challenges in effectively managing their grant programs. Mr. Dong discussed the importance of bringing ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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many voices to the table as OMB launches change in the grants management area. The Appendix A contains the keynote briefing. COFAR, formed in 2011 and comprised of the largest grant-making agencies, worked with OMB to develop a five-point agenda focused on improving grants management over the next three years, FY2013 through FY2015. The objectives of the agenda are to reduce administrative burden, ensure funds are used for their intended purpose, reduce the number of audit findings over time, minimize balances in expired grant accounts, implement timelier grant closeout, and improve overall program performance. The five point agenda includes the following focus areas: Grants Circular Reform Currently OMB has eight overlapping sets of guidance in its circulars, causing confusion and significant administrative burden in administering grants. Over 4,000 audited programs, or 3% of total audited programs, failed to receive clean opinions in 2011. The current guidance does not hold agencies and recipients accountable for effectively correcting financial integrity weaknesses. OMB has prepared a new “super circular” that combined the eight sets of guidance, reducing administrative burden and establishing more streamlined policies and procedures. In February 2013, OMB issued a notice of proposed guidance in the Federal Register to obtain public comment and intends to issue the updated guidance in December 2013. Grant Data Standardization Currently the Federal Government has over 700 grant related forms that have been approved by OMB. This morass of forms creates an inefficient use of federal and state resources that attempt to comply with the various forms required. Embedded in these forms are nonstandard data definitions that compromise the quality and utility of publicly reported financial data. By December 2013, OMB plans to issue pre and post-award standard data elements. In addition, by December 2014 OMB will let any non-standard form approvals expire, thereby eliminating many of the forms over time. Spending Transparency Grant financial data has some significant process problems that comprise the transparency of grant spending data for the citizen. Current processes lack simple checks like control totals to verify the accuracy of spending data and compromising the accountability to stakeholders. Different communities are working to standardize data elements but this work has not been properly aligned. The lack of high-quality information on which to base program management decisions also creates challenges with responding to requests for information. OMB will issue guidance on leveraging financial data oversight and implementing internal controls over grant data – all to be implemented by January 2014. OMB also plans to publish a payment information repository while attempting to improve the quality of publicly reported financial data by October 2015. Workforce Development Looking at the federal workforce in grants management, one finds a lack of consistent standards for qualifying people to perform grants management functions. Today there is no government-wide core training required of staff performing grants management functions. To bolster this area of workforce development and to attract new talent, OMB is establishing ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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core competencies for grants managers and establishing a government-wide resource repository for federal grants professionals so that agencies can begin leveraging these resources for training their grants workforce. Audit Resolution Major grant programs continue to report repeat audit findings causing material noncompliance issues. Unfortunately, there is currently no easy way to track these repeat items so they can be addressed effectively. Current guidance does not hold agencies accountable for correcting these audit issues and agencies lack prompt follow-up mechanisms, thereby increasing risks to program integrity. OMB plans to identify high-risk programs to baseline the “unclean” audit opinions and material audit findings, and then develop corrective action plans to resolve the issues. In August 2015, using the results of FY2014 audits, OMB will measure the reduction in “unclean” opinions on the high-risk programs. By December 2015, COFAR will review the results and recommend best practices for resolution of continuing audit issues. COFAR and OMB will continue to monitor progress across the five-point agenda and ask that grant-making agencies and ACT-IAC work collaboratively to help affect the needed change.

Panel Discussion The keynote briefing was followed by a panel discussion featuring subject matter experts and senior officials from several grant-making agencies. The members of the panel responded to several questions from the moderator and the audience related to the OMB/COFAR plans as well as topical areas related to grant performance, grants data and reporting, workforce/skill set challenges, the use of technology, and the challenges grantees face in complying with reporting requirements. The major takeaways from the Q&A session included: 

Grants process: those agencies with research-oriented grants, such as National Science Foundation (NSF), National Aeronautics and Space Administration (NASA), and the National Institutes of Health (NIH), do not expect or see much overlap with grants offered by HUD or DOJ’s Office of Justice Programs (OJP). There was much discussion about finding ways to create a basic workflow for common data across grants and building on the standard process for additional data elements specific to the unique purpose of a grant. For information to be meaningful it is important to standardize the data elements.



Data analysis and management: for some, big data provides answers to questions you didn’t know to ask, such as duplication and targeting the best place to invest resources. Big data deals with high-volume, high-speed, and high-velocity analytics. However, big data is not just the data you control, but all of the data relevant to a problem or issue. For example, big data that grant-making agencies don’t control or don’t currently have access to could be crucial in identifying emerging trends to inform program development and funding decisions as well as to detect fraud and misuse of funds.



Timeliness of data: for data to be most useful in program planning, driving funding decisions, and for preventing fraud and misuse, the data must be timely. Some standardized data collections produce results years after the actual collection, creating issues with reliability. Grant-making agencies would benefit from more timely data ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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collection and reporting from grantees and from outside of the grant-making world (e.g., crime data, economic data, etc.). 

Managing performance: dollars spent and value received need to be correlated with performance. Agencies need to define outcomes and not just focus on outputs. Developing performance models and measures presents challenges with impacts that are difficult to measure, because often the data collected doesn’t line up with the analysis.



Understanding the grantee perspective: one attendee proposed an “exchange” or experiential learning program for grants managers to submit and complete a grant to better understand the process from the grantee side. This type of learning can help grant program managers understand the challenges grantees face in complying with application and reporting requirements. Similar approaches have been successfully used to educate policymakers on challenges related to applying for and living on public assistance.

Breakout Session Discussions The breakout sessions addressed the topics of transparency, finance, professionalism, and risk. This section of the report provides a high-level summary of the takeaways from the discussions. Appendix B contains the list of suggested questions for discussion and Appendix C contains the detailed notes from the sessions.

Transparency/e-Gov/Technology/Efficiency Participants discussed a wide variety of challenges with making sure that grants data is transparent and identified the following core challenges/takeaways: Standardized data: standardization will improve data quality and lead to better information sharing. However, the data needs to be clean before it can be shared and that has been a problem. In addition, common data definitions are needed so agencies can “crosswalk” data and to make sure that grantors, grantees, oversight organizations, and the public all share the same understanding of what the data represents. Standards-based exchange models, such as the National Information Exchange Model (NIEM), would also improve reporting and sharing across agencies and with the public by allowing data to be shared more easily. Managing change: data collection has not been a priority, so consistent and high-quality historical data is not readily available. As an alternative to prescribing a very specific set of required data elements and collection processes and limiting collection to these elements and processes, it was suggested that a standardized core “à la carte menu” of data elements and reporting processes be available for agencies to choose from, reducing the need for customized collections and collection processes. Coupling the use of these standardized data with funding will assist in motivating grantees and grantors for this type of change.

Financial Management Participants discussed financial management topics related to grants and highlighted several problem areas as well as some ideas they felt could help alleviate problems: Managing risk: inspectors general are finding issues through their audits that audit firms and grant staff are not finding or reporting. Pre-award audits may be a way to prevent future ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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problems with grantees. Based on pre-award audits performed at an agency, about 14% were found wanting and were not considered for awards. Small grant-making organizations: small organizations with smaller grants fall under the OMB A-133 threshold for required independent audits. These small organizations don’t have the skill sets to avoid problems, so the very small organizations that need audits the most get the least attention. However, the risk is low because the impact is low, but there are many of these small grants. As part of grant support, small business/grant consulting should be part of the requirement to receive a grant. Small organizations that fall under the audit threshold should have an audit every three years. One-year appropriations: one-year funding coupled with continuing resolutions can cultivate a culture that rushes to spend all available funds at fiscal end of year, compressing one year of spending into four to six months, creating additional risk in the process. Two-year or multiyear funding may be able to reduce these types of problems. Modernizing grants management: participants wanted to know what other organizations were doing to modernize the grants backend processes. Some felt consideration should be given to having Grants.gov do the backend process for small agencies to save on updating old systems. Government-wide focus on grants: the “Grants Management Line of Business” coordination and meetings were helpful and are missed. It is not clear who oversees grants now that the Grants Management Line of Business group is no longer active. Although the COFAR includes a focus on grant financial matters, the core grants management coordination function remains an area of needed attention.

Professionalism Participants discussed workforce challenges centered primarily on skills/competencies, training, and certification: Developing skills and competencies: many in the grants management field have to rely on self-learning, often bringing their passion about the grants program to bear. It is often a combination of hands-on experience with specific training that give staff an understanding of the basic language of grants. To standardize skills, the Government needs to control certifications, similar to how COTR training and certification is handled. Emerging skills and competencies: professionals that can manage a grant program are needed with key skill sets that include specific knowledge of the program and a grants certification. Accounting or engineering backgrounds are a positive. For those grant programs in the scientific area, invest in the development of soft skills training for non-science staff.

Risk Management Participants discussed many different challenges around risk in grants management programs, identifying several risk areas, best practices, and some ideas for long-term improvement. Designating high-risk recipients: some agencies have a formal process to designate highrisk recipients, as defined in the Code of Federal Regulations (CFR). DOJ developed a ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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process to identify a grantee as high-risk if they fall within a specific category. Example categories include having open audit findings for over a year that have not been remedied and closed, having questionable costs over $500K in a single audit or grant audit that has not been remedied, or if the grantee is suspended or disbarred. DOJ designates a grantee as high-risk for certain systemic problems and these recipients are kept on a high-risk list until the issues are satisfactorily addressed. Predicting risk: a multi-layered risk assessment process is the best way to leverage efficiencies and enables better mitigation. The sooner you can predict when a recipient is going to start having problems, the more likely it is that the Government can address or avoid making a poor award. From a program perspective, there are often signs at the outset of an award, such as weak capacity or a known history of problems, which may indicate that there will be challenges. Checklists can be developed for common triggers which help predict grantees that are high-risk recipients. This evaluation should start early in the process, before award of a grant, and should be monitored throughout the lifecycle. Duplication: agencies need to look at potential duplication of funding at the award level, not just at the program level. Difficulties preventing identifying duplication include limited resources and aggressive timelines made necessary by delayed appropriations. Automating data collection at the application level would assist in automating a review. FEMA is working to merge several systems and once that is complete applicants and recipients will be able select data from drop down lists for some data elements providing consistent data for analysis. Risks Introduced from timelines: as found in the acquisition world, risks are introduced when timelines are shortened. With delayed appropriations, agencies are often pressured to rapidly prepare solicitations and may not have the time needed to clearly and completely scope the work that needs to be accomplished. Timeframes that get cut are often in the application review and award preparation processes. In the acquisition or contracts world, agencies have been able to quantify the effects of shortened timelines. If that could be done in the grants world the problem could be better addressed or better understood. Debarment and suspension: debarment and suspension of grantees have been a priority at some agencies for many years. All entities and individuals that are debarred and suspended are posted on the Excluded Parties List System (EPLS) which was incorporated into SAM.gov. Agencies reported that reviews are conducted for every award package whether it is a new award or a supplement. In some agencies, this check is automatically conducted, but in the past it was a manual process. Agencies also check the “Do Not Pay” system which helps identify recipients with improper payments. “Do Not Pay” is a free service from Treasury which also offers data analytics. Matching funds: risks related to matching include supplanting of local funds and pledged matches not being provided as promised. One agency reported a problem on a construction project where land was pledged, but a year into the grant, the recipient was told that they would not be getting the land that was promised. Eventually, another parcel of land was provided, resolving the issue. There is also significant difficulty in tracking in-kind matches. Workshop participants agreed that a forum to share information would be of value and would provide a way to stay abreast of solutions that are working to reduce risk, support professional development, and help enhance outcomes of grants programs. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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Improper payments: participants stressed the importance of communication, a central website with grant compliance information, and monitoring what questions are most often searched. As a data source, it would be helpful to have agency-specific FAQs to identify what is unique from one grant agency to another. Webinars and training clips would provide the needed information to new grant recipients and should not require additional staff resources. The Department of Labor Employment & Training Administration (ETA), conducts post-award webinars for grantees, reviewing in detail what is not allowed in the Federal Register and the solicitation, so the grantees better understand the rules. Other agencies sometimes also conduct pre-award webinars for interested applicants, as well as post-award webinars for awardees. Audit: in at least one agency involved in the meeting, the grants office support resides in the CFO office. The agency has a mature risk assessment approach and conducts desk reviews to validate that funds are being used in a compliant manner. Prior to external audits being conducted, the agency conducts preliminary audits using oversight tools such as agency monitoring. Risk models target outstanding audit findings.

Workshop Format and Agenda Many topics were discussed related to grants management throughout the workshop. Some of the overarching questions that framed the agenda included:           

How do I stay abreast of changes in the federal grants management landscape? What risk mitigation strategies can I leverage to better manage grant programs? How can the risk of grant duplication be minimized? What challenges are agencies facing in collecting and evaluating performance data? How do I correlate grant dollars with the impact made? What are the best practices in effective grant monitoring? How can technology improve grants management? What can I expect to gain from consolidating grants management systems? What are the benefits and challenges of standardized application workflow? What value will I get from grants management data consolidation? What skills/credentials are required of grant professionals?

The workshop was conducted in two parts. The first part included a keynote presentation by Norman Dong, Deputy Comptroller, OMB, followed by a panel session featuring:       

James Burch, Deputy Assistant Attorney General, Office of Justice Programs, DOJ Amy Haseltine, Associate Deputy Assistant Secretary, Division of Grants, Health and Human Services Zuleika K. Morales-Romero, Director of Field Operations, Field Policy Management Office, Housing and Urban Development Kenneth N. Petty, FHWA, Office of Planning, Department of Transportation Mary F. Santonastasso , Director, Division of Institution and Award Support, Office of Budget, Finance, and Award Mgmt., National Science Foundation Tyson Whitney, Director, Transparency and Accountability Reporting Division, Department of Agriculture Moderator: David Fraley, ACT-IAC Grants Management Working Group Co-chair ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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The second part of the workshop divided attendees into small group discussions focusing on the following grants management challenges and opportunities: 

Transparency – open data/Data.gov, data quality, performance reporting, accuracy and assurance, duplicative systems/reporting, virtual interactions, and peer review,



Risk – high-risk grantees, improper payments, single audit, calculating risk, debarment and suspension, duplication, better monitoring, improved data, and audit clearinghouse, Finance – closeout, indirect grantee/grantor costs, data quality, and cross-system and agency sharing, and Professionalism – current and future skill sets and competencies, education, training, employee development, credentials, and certifications.

 

The agenda for the event was as follows: Time

Topic

7:00am - 8:00am

Registration, Continental Breakfast & Sign-In All Participants

8:00am - 8:10am

Welcome & Panel Introduction Moderator

8:10am - 8:30am

Key Note Speaker Norman Dong, Deputy Comptroller, OMB

8:30am - 9:45am

Facilitated Discussion with Panelists The panel will collaboratively discuss key issues. Questions from the audience will be taken. All Participants

9:50am - 10:00am Transition to Breakout Sessions 10:00am 11:20am

Breakout Sessions Government and industry participants will join breakout sessions to discuss the challenges, opportunities and innovations discussed during the panel session and others, identifying areas for further exploration and collaboration. Topics are Finance, Transparency, Risk, and Professionalism. All Participants

11:20pm 12:00pm

Breakout Group Back - Briefs & Closing Comments

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Appendix A: OMB Improving Management of Federal Grant Dollars Briefing

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Appendix B: Prepared Questions for Breakout Sessions The following are the “primer” questions that were used during the breakout session.

Transparency/e-Gov/Technology/Efficiency Information Technology   

Do you use a shared grants management system with another agency? If so, how much policy change did you have to make to comply? Are there multiple grants management systems used at your agency? Has your agency tried to consolidate and if so what is the status and any success/failure factors? How big are the differences between the systems, assuming your agency is using multiple grants management systems? What would be needed to migrate to one system?

Related Business Process Improvements    

What major issues exist with document management and collaboration? How have agencies solved these issues? What are the lessons learned? How do you share documents and collaborate for peer review? Do you us a shared central file system? What are the benefits and challenges of standardizing the application workflow? What are the benefits and challenges of standardizing the grant evaluation scoring and the decision methodology?

Data Sharing in Support of Transparency and Accountability      

What mechanisms are in place to ensure data reliability, quality, and integrity? What are the most critical needs in this area? We hear a lot about big data. What, if any, additional value can be realized from the big data being collected as part of the grants management process? What are the major challenges of collecting and evaluating performance data? How important is a common taxonomy? What are the major challenges of collecting and evaluating performance data?

Financial Management     

The proposed OMB reforms to the guidance for federal policies relating to grants was recently published (OMB-2013-0001). To what extent are you familiar with these reforms and the impact these reforms will have on your agency? What common themes in the financial management and oversight of grants contribute to internal control and other material weaknesses? What best practices are you embracing in addressing these challenges and can you share any success factors with the group? What performance measurements do you use to manage grants and what are you tracking? How will your performance measurements alter the way your agency reports on successes or failures?

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     

What monitoring and program management techniques do you employ and what changes are needed to increase the effectiveness of these techniques? Do you use a performance management system to track performance data? What are the challenges you face in order to correlate the dollars spent with impact made and how have you addressed them? What are the lessons learned based on common findings in audits and have any checks been automated through a system? To what extent do you seek deviations from the negotiated rate and what is necessary to bring greater transparency in the amount of spending related to indirect costs? What are some best practices in addressing COI, fraud, waste, abuse, etc.?

Professionalism in Grants Management              

What positions in your agency are covered as “grants management”? What are the skills/competencies that are most important for grants management specialists, management officers, and program officials? Are these skills/competencies standardized across the organization? What are the emerging or future skills/competencies required? How are you upgrading the skills/competencies of your current staff? How do you support continuing education/training and development? Does your grants management staff participate in any associations? If so, which ones? Do you require credentialing for your employees or contractors? National Grants Management Association (NGMA), Grants Management Certificate programs, etc.? Are there differences in the skills/competencies for your staff and contractors? How do the skills/competencies change with the support required for the various phases of the grants or are all of the same skills/competencies required for all phases of the grant lifecycle? What are the most critical program areas for a meaningful certification for your agency grant personnel, e.g., cost evaluation, monitoring, etc.? Are there agency specific requirements? How should certification programs be designed to create more effective grants managers? What are key attributes for grants professionals? How do these grant professionals keep abreast of changes in federal policies and what’s happening in the community? Are there conferences/workshops or other ways in which exchange of information occurs across grant-making organizations?

Risk Management Risk is broadly defined as anything that prevents an awardee from achieving the project’s intended objectives and goals. Awardee attributes, objective evaluations, and judgment are used to evaluate the program risk. As discussed during the meeting, “risk” also includes the risk to the grant-making agency, created by the factors described above and others, including those noted below. Duplication: ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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Please provide examples on how your federal agency evaluates risk at the awardee and program level.



How can a grantor identify, communicate, and then eliminate grant duplication with its grantees? What is sufficient evidence to prove there is no duplication of federal funds?

• Audit •

What are key responsibilities that federal agencies should emphasize to grantees to promote successful grantee audits?



What are key resources that federal agencies should direct grantees to obtain additional information on audit requirements?

High-Risk Grantees •

What are effective mitigation strategies, actions, and activities to manage high-risk grantees?



When would you recommend that a federal agency take an awardee off of a high-risk designation?

Debarment and Suspension: •

What are requirements to suspend or debar a business or individual from doing business with the Government?



What other systems and data feeds can be incorporated into the Excluded Parties List System (EPLS) to ensure those that are not authorized are not grantees?

Match: • • • •

How can federal agencies be confident that awardees are ensuring that all awardee, sub-recipient, and third-party match contributions are secure? How should federal agencies evaluate the methodology that awardees use to arrive at the valuation of their proposed in-kind matches? How should federal agencies ensure that awardees have documented any match changes (i.e., additions, replacements, or removals) and have documented the valuation and existence of cash and in-kind matches? What if an awardee is unable to timely deliver the match, unable to secure the match, or has not properly valued the proposed match planned for a project?

Improper Payments: •

How can federal agencies direct awardees to the guidance (cost principles) that detail what costs are allowable, allocable, and reasonable for a federal project? How should federal agencies review an awardee’s expenditures (especially for high-risk awardees)?

More efficient/effective/innovative monitoring: •

Please provide some examples of risk mitigation strategies and analyses that your federal agency has implemented to promote effective grants monitoring.

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

• • •

Does the current Federal Audit Clearinghouse site provide adequate transparency to grants/audit activity for all stakeholders? If not, what data improvements should be made? Have the programs thought of harnessing their grants data for predicting likelihood of a grant/project to fail or succeed? Are there training programs/training collateral to help grantees avoid common risks and pitfalls?

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Appendix C: Detailed Breakout Session Notes Transparency   



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Data needs to be addressed first to help transparency. Without clean data, any kind of standardization will be difficult, if not impossible. One agency acknowledged originally wanting to create an in-house tool, but eventually internal pressure from the grants team allowed them to go with GrantSolutions.gov. HHS is leading the effort on standardization from their role as the administrator of GrantSolutions.gov and the work being conducted at NIH on the Information for Management, Planning, Analysis, and Coordination (IMPAC II) grant information database. They have great insight into the depth, breadth, and complexity of the data being pushed through their solution. There is a push away from using Social Security Numbers as any kind of national identifiers and there is currently no agreed upon system for financial standardization. Some entities are using a universal award ID number, but that is not yet an agreed upon standard. Up until now, standardization has not been a high priority, which makes it hard to produce anything of value from the data. Conversely, standardization will limit variability in the data being produced. Once you ask grantees to fill in 20 boxes, those are the only boxes that you will get filled in, regardless of the program. Right now, there is almost no way to hold a grant program accountable until re-award and, even then it can be too late because data takes time to assemble and process. Especially when it comes to non-discretionary programs, the money is getting awarded no matter what. Until data can be cleaned up, leaders are going to be leery of putting it out to the public or to other agencies. With “dirty data,” you can’t say with certainty how much of the data is good versus bad, and that is important before sharing it, even in raw form. There are currently no checks in place to verify data, data sources, or data usability. One way to help clean up the data is to release the data sets to the public. They will tell you where your data is bad or unusable. Instead of forcing agencies to comply with one common data set, there should be a mandate to create a crosswalk to one common dataset used as a common language by all agencies. It will be easier to share when everyone is speaking a common language, something like a National Information Exchange Model (NIEM) for grants. Instead of programs and processes, the first step should be the analysis of existing performance data. Right now, there are multiple reporting burdens for grantees when funding sources vary. It is tough to link programs to goals and measures when the goals and measures are different for each source. One theory is to create a “bank” of common data sets that are managed and monitored by an independent agency or entity. Data use would then be à la carte, creating data sets from approved modules that can then be put together to create whatever the user wants, including forms. The only time customization would be needed would be if information being collected doesn’t fit into an existing data set. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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A big challenge is that every agency wants to claim outcomes to maintain funding for their agency. So if multiple agencies fund a project (e.g., recovery from Hurricane Sandy), each wants to track their own outcomes to justify future spending.

Financial 

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DOJ’s OIG only gets to see failed programs but would like to get into an organization before there are complaints. Recently a program asked for pre-award audits. About 14% were found wanting and were not considered for awards. Re-award audits could potentially avoid later problems. OIG has new power and can now suspend and debar. This results in much more responsive action. OIG has found through their audits that audit companies and grant staff are not reporting the significant findings that the OIG finds. Auditors are getting too familiar with their clients, similar to what happened between Arthur Anderson and Enron. A suggestion would require that auditors rotate every year or two. In small organizations with smaller grants, the grantees fall under the OMB Circular A-133 threshold. These very small organizations don’t have the skill sets to avoid problems. Thus, the very small organizations that need audits the most get the least attention. The group agreed the risk is low, because the impact is low, but there are many of these small grants. The reason why many small businesses fail could be that they lack the skill sets to avoid the many pitfalls. As part of grant support, small business/grant consulting could be part of a requirement to get the grant. Recommend requiring the very small organizations that fall under the audit threshold to have an audit at least every three years. National security can affect transparency as a result of limitations of information sharing. One-year funding coupled with continuing resolutions can cultivate a culture that rushes to spend all available funds at fiscal end of year, compressing one year of spending into four to six months, creating additional risk in the process. Two-year or multi-year funding may be able to reduce these types of problems Should there be a part of the applicant process for a pre-award audit and/or Google search that needs to be standardized that could help weed out high-risk grants or point out high-risk grantees? The “Grants Management Line of Business (LOB)” coordination/meetings are missed. Could Grants.gov do backend for small agencies and save having to update old systems? Who in the Government oversees grants now that the Grants Management LOB is gone? Grantees don’t have the support tools to help sub-grantees and these should be provided.

Professionalism  A variety of positions in participating agencies are covered as “grants management”: o Grants office - executes o Government technical representative - monitors and implements o Program reviewer o Program officer o Grants management specialists ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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o o o o o o

Program specialists Management and administration Grants managers IT General counsel Program analysts/grants coordinators

 What are the skills/competencies that are most important for grants management specialists, management officers, and program officials?  It is important for those in the grants management field to “learn on their own” o It’s important to be passionate about the field and seek out advice/mentorship o Common sense and energy go a long way  Training was also discussed o Although training is important, it should serve as a supplement to hands-on experience o Those that had taken grants training noted that the training gave them a better perspective of the grants management world o Training was cited as good to obtain an understanding of the basic language of grants  It’s important for a grants management professional to go through the entire lifecycle of a grant to learn the ropes of grants management  Are these skills/competencies standardized across the organization?  It appears that skills/competencies are not standard across the organization  Standardization of skills/competencies would be beneficial for grants management professionals  The Government should control grants management certifications, like it does with COTR training o There is no standard grants management certification o OPM needs to define the competencies  Certifications are not mandatory for jobs in grants management o Skills need to be defined and a competency dictionary is needed  What are the emerging or future skills/competencies required?  The Government needs to hire individuals with the proper skill sets; professionals that can actually run a grant program are needed  Some agencies have new grantee training/conferences  Key skill sets include: o Grants certification o Specific knowledge of the program o Accounting or engineering background is a plus  New staff members at some grant-making agencies are given rigorous training  One agency noted that it has invested in “soft-skill” training for non-science staff and this training has made staff members more effective  Some federal staff that are not grants management specialists, such as scientists, do not often have strong grants-related managerial skills  There can be a disconnect between non-science and science staff ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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Science staff may have the view that grants work is administrative work

 How are you upgrading the skills/competencies of your current staff?  Several participants noted that their agencies are developing individual training plans o Some training is offered online o Some annual training is provided o Some agencies have put their staff members (federal program officers) through management concepts training  How do you support continuing education/training and development? Does your grants management staff participate in any associations? If so, which ones?  Development is supported through organizations such as: o NGMA o ACT-IAC o Grants Professionals Association  Employees are encouraged to participate but are not required to join organizations  Are there differences in the skills/competencies for your staff and contractors?  There is dual accountability, as both consultants and federal staff need to be aware of the grant rules and regulations  In general, contractors are needed to assist with technical writing  It is important to attract new professionals to bring a fresh perspective  There is much movement between jobs, so documentation and processes need to be documented  Each administration has its own key agenda items which could be covered by contractors since those agenda items vanish after the administration leaves

Risk Management  What are your major areas of concern regarding risk? o When this question was asked, the first topic explored was the early evaluation and identification of grantees which pose risk to the program(s). From a program perspective, there are often signs at the outset of an award – weak capacity or a known history of problems – that may indicate that there will be challenges. Several members discussed that checklists can be developed for common triggers which help predict grantees that are high-risk recipients. This evaluation should start early in the process, before award of a grant, and monitored throughout the lifecycle. A few examples of questions include:  Has this grantee applied for multiple grants? Are these applications across multiple agencies? This can help identify those who may be using federal money to gain additional federal money, or leveraging several grants to accomplish the same outcomes.  Is there a previous history of problems? Just like other contracts, look at how they have executed work under previous grants.  Look closely at and verify the investments that the grantee is committing to the program. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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 Does the grantee clearly identify how they will meet the goals of the grant? o The sooner you can predict when a recipient is going to start having problems, the more likely it is that the Government can address or avoid making a poor award. There will likely be problems if there is an organizational disconnect between the people who applied for the grant and those that will be running the program. If there is any confusion regarding the purpose of the grant program, then there is probably some confusion about the rules. o New grantees often run into problems. Some agencies require new grantees to fill out a financial profile. This informs grantors and grantees about their financial systems and provides an online financial management training program. The online version allows you to see where the user had problems so you can focus technical assistance in that area. The training is also offered at in-person conferences. At least one agency also requires anyone that has been designated a high-risk grantee to go through this training again.  What are the things that are happening in the years before serious problems are discovered and how can we catch them earlier? o This led into a discussion about monitoring and other processes that are used to identify high-risk behaviors throughout the grant lifecycle. By monitoring performance and establishing a formal process to identify high-risk recipients, it is easier to focus technical assistance and avoid making payments where inappropriate. o Some agencies have a formal process to designate high-risk recipients, as defined in the Code of Federal Regulations (CFR). The guidelines in the CFR are somewhat general in nature. Agencies looked at those guidelines and how they would implement or operationalize them in terms of what they were seeing with their recipients. The result is a process that can be accomplished in one of two ways. One is an automatic high-risk designation for a grantee that falls within any one of several categories. The categories include things such as having an open audit with finding(s) for over a year that has not been remedied and closed, having questioned costs over $500K in a single audit or grant audit that have not been remedied, or if the grantee is suspended or disbarred. o The second way that a grantee is designated as high-risk is through a referral process. Program offices or financial analysts can submit a referral. Some agencies are also looking at even more sophisticated methods of identifying high-risk grantees by looking at Duns and Bradstreet credit ranking as well as looking for financially distressed or bankrupt jurisdictions and entities.  Is the high-risk designation done through the CFO or program office? o At DOJ, there is an oversight office, the Office of Audit, Assessment, and Management (OAAM), that administers the high-risk process, not only for OJP, but for the Office on Violence Against Women (OVW), and the Office for Community Oriented Policing Services (COPS Office). The Director of OAAM is the person that signs the letter designating the grantee as high-risk. When the grantee resolves the issues, the designation is removed.

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o When you set up the high-risk designation process, it is most helpful to have the automatic process. o In some agencies, a distinction is made between a high-risk grant and a high-risk grantee. For example, a grantee may receive several awards from many components from within the department. Their financial systems may be fine, but they may be highrisk because they are not implementing a certain regulation or a law as part of an award. o At the Department of Education, the Risk Management Services Office (RMSO) has a similar role to DOJ’s OAAM and is more involved if an institution is designated as highrisk. o Some agencies consider a high-risk designation for systemic problems and these recipients are kept on a high-risk list. All employees involved in the award process must go to that list to see if an individual or entity is, or is not, on the list. If a recipient is on the list, the oversight office assesses the risk, reasons for being designated as high risk, and recommends special terms and conditions that will be applied to that grant. This may include withholding of funds until the issues are corrected. o There is some resistance to designating recipients as high-risk on a published listing. o The key advantage to keeping and communicating this information is that recipients with this high-risk designation know they are being monitored and action will be taken and in turn are responsive and resolve the issues quickly to avoid punitive actions. o Because there are so many different stakeholders in the grant-making process, it can be challenging to keep everyone up to date and aware of the rules and regulations that govern the process. Additionally, it is important that everyone understand their roles and responsibilities in order that information is properly communicated both among the stakeholders and the grantees. Without proper training and communications, misinformation or lack of knowledge can create risks to the program. o There is a common issue for all government agencies regarding conference and training costs – these costs must now be approved before the meeting. In response to this requirement, one agency built a workflow process where all the logistical and financial details associated with any meeting will come up to the agency head as required by Office of Management and Budget (OMB) guidance. It becomes evident during the review process if a recipient is following the OMB guidance fully or if they are trying to merely check a box and appear that they are following the guidance fully. When this occurs, the agency reviewers will flag that grant for close monitoring because it may be an indication of risk.  Is the application of a flag for monitoring based on an individual’s interpretation of the facts? o Yes – it becomes evident in many ways. For example, a common issue that will stand out is when a recipient does not get three bids for work. Another indicator may be that the numbers just don’t seem to add up; or when reviewing the agenda, it seems that something else is going on that they are not telling you about; or the number of attendees seems inappropriate for the stated agenda. The person reviewing the ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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material must have enough experience and developed a certain level of skill or competency to identify those areas of concern. o The workflow process at one agency allows the information to be reviewed by program staff as well as financial staff. Each person reviewing the material brings to bear their expertise. So in the case where a program person may not be aware that the numbers are not appropriate for a certain location, when it gets to the financial staff, they are more attuned to this and are constantly looking for anomalies so they are able to flag it before it reaches the agency head for approval.

Matching and Improper Payments  As acknowledged by several participants, factors that increase risk are limited resources and aggressive grant-making timelines. Events such as Hurricane Sandy often require expedient responses through grants and delays in appropriation approvals exacerbate the problem. Having the time and resources to complete sample testing, for example, becomes difficult.  In some agencies, if there is any indication of improper payments, spending funds on unallowable costs for example, there are several payment flags that can be applied and monitored. The grants manager may do a random sample based on that flag where they identify one particular drawdown and request that the recipient provide all receipts. This has proven very helpful as a mitigation strategy.  Is that part of a formal monitoring plan? o There is a formal monitoring plan, but in this case, the payment flags are used as part of the risk assessment plan which is separate from the monitoring plan. At the time of award, the risk office does a huge data analysis process and returns risk indicators (red, yellow, and green) that indicate which recipients will need the most attention and require additional follow-up. These indicators will be used to plan what is necessary from formal monitoring to ad hoc sampling. o There are multiple layers to the process that includes data analysis, monitoring, and random sampling of a particular recipient. o A similar process is used in other agencies, but the risk assessment and monitoring processes are not separated. The process starts with risk assessment that evaluates every recipient on nearly thirty factors, pulling information automatically from the grants management and financial systems. The result is a ranking of risk (high, medium, low) that provides the information needed for a decision on what type and level of monitoring is most appropriate – that is, programmatic, financial, or both in the form of on-site monitoring, enhanced desk reviews, or desk reviews. to assess programmatic  Does the ad hoc review enable the agency to reach or test a larger number of grantees than simply monitoring? o Probably not. However in the risk assessment, data on every recipient is pulled from D&B, past audits, and the financial system. Based on the assessment, a recipient is designated as high-risk or it’s noted that there is evidence of some risk that may need

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further follow-up, such as the random sampling of their drawdown, or perhaps they are put on a reimbursement route payment.  Who decides which course of action is taken? o It is done in an oversight office in coordination with other offices. o It may be a good practice to apply random sampling to recipients that fall in the middle of the risk scale as a way to best use resources. o Regarding monitoring, there has been a shift in the focus of the protocols from compliance to technical assistance moving away from compliance and focusing on technical assistance. This provides a greater focus on the outcomes. o Perhaps there would be a way to leverage best practices across the Government and streamline risk management by taking advantage of some of the systems in place, such as Grants.gov.  Is there a difference in the administrative costs of doing more technical assistance than compliance? And is compliance truly facilitating the desired results? o These questions were raised at the Department of Defense (DOD) when looking at information technology (IT) in order to ensure that the outcomes were the higher priority. Limited budgets and things like sequestration will require a closer look at all costs and evaluating whether or not a cost makes sense and provides value.

Duplication  Is the issue of duplication impacting all agencies? o Yes, to some extent all agencies have to address this issue. Some agencies have an interagency agreement (e.g., the HHS Grant Alignment Program) that allows them to evaluate programs at an announcement level and assure that programs do not provide duplicative funding. o There is also a need to look at potential duplication of funding at the award level, not just the program level. Big data analysis of program and grant level data from all areas would be very useful for all grant-making agencies. o Common forms across all agencies would also assist in identifying duplication. o One difficulty of preventing potential duplication is limited resources and aggressive timelines. Automating data collection at the application level would assist in automating a review. Some agencies are working to merge several systems and once that is complete, applicants and recipients will be able select data from drop down lists for some data elements providing consistent data for analysis.  Is DOJ OJP’s Grants Management System (GMS) used for electronic records storage? o Yes, it is. GMS has NARA approval. o DOJ is conducting a duplication study among the three grant-making components of DOJ. One solution that has been suggested for addressing duplication is a web-based repository of information on all solicitations. The database would run some analysis on which programs may likely have some overlap. If this works, it may be good to share ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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certain data elements with other agencies to see if there are likely overlaps among those agencies. o Another element that must be considered is whether or not there will be overlap at the sub-recipient level. o GAO has a statutory mandate that they must do an annual duplication report, whereby many of their ongoing reviews are focused on overlap, duplication, and fragmentation. o USASpending.gov can be used to get some information on sub-recipients, but there is no guarantee that the data is complete and accurate. o It is clear that all agencies are facing similar challenges and that sharing information at a conference like this is very helpful. o Having a voice on the Council on Financial Assistance Reform (COFAR) would also be very beneficial to all agencies. The COFAR replaces two federal boards – the Grants Policy Council and the Grants Executive Board. One shortcoming of the COFAR is that it only replaces part of the function of those two federal boards because it does not have representatives from all grant-making agencies and because it focuses on both acquisitions and grants. o There is a MAX site for the COFAR that contains minutes and other information. o Interior has nine bureaus and uses the PRISM system for grants to eliminate duplication. The agency considers the risk, pre-award and looks at the recipient level, not the program level. o Another agency relies on the merit review process to eliminate duplication, but at the same time investigating the role of IT and automation. o One example would be creating templates for evaluation looking at risk in the preaward phase. o Another agency discussed looking at recipient-level duplication and program-level duplication. Agencies discussed that, if a site visit is needed, collaboration is required between bureaus.

Grants Management and Acquisitions Management Comparison  Grant management work is not as codified as acquisition management work. At some agencies, program, policy, and finance functions are handled by one person, and at other agencies, these responsibilities will be handled by different people and different offices. The definition of job requirements and training requirements in the acquisition management world could serve as a model for the grants management world. Training and development in core competencies may help reduce some risks and facilitate crossgovernmental discussions and solution generation.  What risks are introduced as a result of timelines? o As was found in the acquisition world, risks are introduced as timelines are shortened. This pressures agencies to rapidly prepare solicitations and not necessarily spend the time needed to clearly and completely scope the work that needs to be accomplished. The timelines are frequently governed by the budget process and statutory ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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requirements. Timeframes that get cut are often in the application review and award preparation processes. o In the acquisition world, they have been able to quantify the effects of shortened timelines. If that could be done in the grants world, perhaps the problem could be addressed better. For example, if you could demonstrate that the number of high-risk grantees goes up when timelines are shortened, you could work to address the issue of shortened timelines. o At one agency in particular, they have implemented many tools and techniques to educate project staff on the impact of schedule changes in the award process. Heads of departments are held accountable to the plan and it is tracked closely week by week. o An agency may have many regulations that require that rule changes that must go through a public comment period that also puts pressure on timelines. o Awardees have terms and conditions in their award. The agency needs to determine how grossly negligent was the awardee in administering the money. One participating agency discussed how it monitors SAM.gov, the EPLS list and CCR and checks SAM and D&B, prints a hardcopy, and puts it in the file. o The suggestion came up to run pre-award clearances, criminal and credit checks similar to the security clearance process, but the question of who bears the cost for that investigation was a concern. o One suggestion was to conduct research on entities that had been debarred to identify common characteristics, looking for indicators in historic data.

Debarment and Suspension  Debarment and suspension actions have long been a visible priority in the contracts community and are now being used more frequently in the grants world.  How would other agencies know that an agency debarred that grantee or individual? All entities and individuals that are debarred and suspended are posted on the Excluded Parties List System (EPLS) which was incorporated into SAM.gov.  In some agencies, the EPLS is checked for original awards, but not supplements. Do other organizations review the EPLS for supplements? In others, reviews are conducted for every award package whether it is a new award or a supplement. Several agencies also check the Do Not Pay system which helps identify recipients with improper payments. Do Not Pay is a free service and it also offers data analytics which are also free. D&B is also used.

Matching  One risk related to matching is federal funds supplanting funds from other sources. There is also a risk of pledged matches not being provided to the recipient. One agency ran into a problem on a construction project where land was pledged, but a year into the grant, the recipient was told that they would not be getting the land. There is also a difficulty in tracking in-kind matches. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

 Participants agreed that the discussion was informative and that having an on-going forum to share information would be of value. It would provide a way to stay abreast of solutions that are working to reduce risk, support professional development, and help enhance outcomes of grants programs.

High-risk Grantees  Surveys for new grantees can help identify high-risk grantees. The Government relies on self-certification.  How do you marry what is on the form to what actually is happening? Perhaps the cost sharing did not meet the number. Agencies don’t have sufficient resources and the Paperwork Reduction Act creates another issue.  What is the defining line for high-risk designation? Those without a track record of getting awards or big dollars?  One challenge noted was lack of resources for staff to effectively monitor. One agency discussed its monitoring strategy to deal with their lack of staff resources and they monitor work plans to target low, moderate, and high-risk.  A participant discussed how their agency uses factors to determine a high-risk portfolio include lack of experience with federal funding, coop agreement and cost sharing. They maintain an eight+ year monitoring program and have a set of organizational factors in an automated database.  One agency met resource constraints using virtual site visits, piloted last year which included webinar, video conferencing, and secure SharePoint for document sharing. One challenge is a participant’s reluctance to be on video camera. Virtual versus in-person loses some things like hallway conversations. Some agencies indicated that they are using virtual technologies for merit review panels.  As to cost savings, there are “back of the envelope” type numbers. Out of 30 site visits, seven to eight were virtual producing about a 25% reduction in cost due to elimination of travel cost including staff travel time. One participating agency is evaluating if this produces less burden on a research organization.  The group was consistent that there is a transition period with technology and some paper and pencil activity is still happening. Senior management in general is more comfortable with paper and pencil and the newer generation is more adaptive to technology.

Improper Payments  Need to determine that the right recipient is getting funds (first issue) and that nonallowable costs are not being permitted such as receptions with alcoholic beverages.  Several agencies have instituted programs and monitoring, e.g., baseline, advanced, and multi-tier monitoring as additional controls to transactional sampling, tracing, and reconciliation.  The suggestion was made to make the Pre-award SF-424 more detailed and not just a summary. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

 It is also critical to communicate, pre-award, what is allowable. The group stressed the importance of communication, proposing the creation of a central website with grant compliance information that is monitored to identify which questions are most often searched and rolling those up to the top. This could be another source of big data. Agency specific FAQs could also identify what is unique from one grant agency to another and which FAQs are similar. Webinars and training clips could provide the needed information to new grant recipients, creating a self-service education model.  Several agencies reported conducting post-award webinars for grantees, reviewing in detail what is not allowed in the Federal Register and the solicitation so the grantees better understand the rules.

Federal Audit Clearinghouse  Awardees do not have access to the clearinghouse. The biggest problem is the lag time, not the quality of the data. It is not clear what is being done with the audit findings. There is a need for follow-up and closure but there is also an issue as to the responsibility for the follow-up.  One agency reported developing a report to help with audit follow-up.  Several awards under the threshold can result in an A-133 audit. The awardee is responsible for the third-party audit but there are coordination issues with the cognizant agency. It is hard for small agencies to take the lead.  How does an awardee lose their high-risk designation? They have to show a compliance program has been put in place. Generally they are informed they are designated high-risk for a specific period of time.  Single audits is the area where grants managers have the least training and knowledge. What is the programmatic output vs. the administrative burden of the Single Audit Act, A133 audit?  Standardized reporting helps with accountability.

Audit  One participating agency reported that its grants office support resides in the CFO office. They have mature risk assessments and desk reviews to validate that funds are being used in a compliant manner. Prior to external audits, the agency conducts preliminary audits using oversight tools such as agency monitoring. Risk models target outstanding audit findings.  Smaller grants need to demonstrate responsible accounting, e.g., the use of QuickBooks. Reading the grant award document is important to know what is allowed and what the dollars are supposed to be used for.  A smaller grant-making agency participating in the meeting noted that they don’t have the infrastructure in place for instituting virtual reviews but the suggestion was made that potentially in line with the ShareFirst policy, this infrastructure could be offered as a service from another larger agency or designated grant LOB partner. The virtual meeting approach also helps to fortify the COOP program for grants management. ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

Appendix D: Organizations Present At Conference The following organizations had representatives present at the conference:  AAC Inc.

 Institute of Museum and Library Services

 Accenture Federal

 Kearney & Company

 ACT-IAC  Administration for Children and Families  AFA

 KGS  KPMG  LexisNexis

 Appian Corporation

 Lockheed Martin

 Booz Allen Hamilton  BroadPoint Technologies, Inc.  CGI

 Master Key Consulting  MicroPact, Inc.  National Endowment for the Arts

 Citizant

 National Endowment for the Humanities

 Compusearch

 National Science Foundation  Corporation for National and Community Service  Northrop Grumman Information Systems  Department of Agriculture  NTT DATA Federal Systems  Department of Education  Office of Community Oriented Policing  Department of Health and Human Services Services  Office of Justice Programs  Department of Housing and Urban Development  PricewaterhouseCoopers  Department of Interior  Department of Labor  Department of State  Department of Transportation  Federal Emergency Management Agency

 Recovery Accountability & Transparency Board  REI Systems  Robbins-Gioia  Small Business Administration  Social Security Administration

 General Services Administration

 SRA International

 Grant Thornton

 STG International

 GSA

 U.S. AbilityOne Commission

 HVD

 XLA

 IBM ACT-IAC, 3040 Williams Drive, Suite 500, Fairfax, VA 22031 www.actiac.org ● (p) (703) 208.4800 (f) ● (703) 208.4805 Advancing Government Through Collaboration, Education and Action

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

Appendix E: Workshop Attendee Feedback As part of the workshop, attendees were asked to complete a questionnaire at the end of the event. This questionnaire asked the following questions: 1. What are the top three grants management issues that you face in the execution of your daily job responsibilities? 2. What is the number one issue or challenge facing Federal grants management today (at the collective level)? 3. What is the number one issue or challenge facing grants management professionals (at individual level)? 4. Did you learn something today that you will be able to use in the execution of your daily job responsibilities? The following summarizes findings associated with the questions. Question 1 – Top Grant Issues In Daily Job Responsibilities. Across the survey results, the most common responses were:      

Need for data standardization and improvement of data quality Importance of training Importance of attracting and retaining high-quality grants management resources Need for consistency across federal agencies Need for streamlining grants management processes for effective grant monitoring and the need for robust grants management systems for effective records management Need for standard forms and documentation across agencies

The following pictorial highlights the words used most often in responses. The larger and more prevalent the word, the more times that word was used in responses. For example, in the pictorial below, the word “management” is the largest word shown. This indicates that this word was used more often by respondents than any other word.

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

Question 2 – Collective Level Top Issues. The issues and challenges that respondents described included:          

Lack of a common grants methodology Resource and training constraints Lack of structured training credentials or certificates for grants management specialists Reliability, consistency, and transparency of data Lack of standard training or certifications across agencies Accountability Lack/uncertainty of funding Demonstrating impact Interpretation of guidance Making the right award choices (during the pre-award process)

The following pictorial highlights the words used most often in responses.

Question 3 – Individual Top Issues. Respondents were asked to share the number one issue or challenge facing grants management professionals. The most common responses included:     

Time, resource, and budget constraints Lack of training programs Need for standardization of training curriculum, training programs, and certifications across federal agencies Staff retention and support from leadership Communication of circular changes, changing policies, and what’s occurring in the grants management community

The following pictorial highlights the words used most often in responses.

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2013 Grants Management Workshop Report: What’s New & What’s Next in Federal Grants Management

Grants Management Workshop Report Authors & Affiliations Primary Contributors      

James Burch, Office of Justice Programs, DOJ David Fraley, Executive Consultant & Grant Industry SME Robin S. Gardner, REI Systems Tim Lawler, Grant Thornton Meghan Hoffer, Booz Allen Hamilton Noah Nason, Northrop Grumman

Table Moderators:             

Barbara Allen, AAC Inc. Linda Radford, STG International, Inc. Lisa Miller, Dynaxys Matt Hoyle, CGI Federal Brad Barker, Master Key Consulting Meghan Hoffer, Booz Allen Hamilton Paul Albert, Pegasys Federal Richard “Rick” Schrader, Appian Corporation Susan T. Morrison, Attain, LLC Thom Robison, Accenture Wendy Murphy, Dell Services Federal Government Carla Saia, SRA International, Inc. Noah Nason, Northrop Grumman

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