Whatever Happened to Grant Uniformity?
Seven years ago, the Office of Management and Budget issued 2 C.F.R. Part 200, which we have come to know over the years as the uniform grant guidance. One of the key goals for bringing all the former circulars into one regulation was to encourage similarities in grants administration to reduce recipient burden, thus the terminology “uniform” right off the bat. Seven years later, grant recipients unfortunately are still facing challenges stemming from differences in grant program oversight. In some cases, this lack of uniformity results from pass-through agencies within a state having differing procedures.
During a session on grant implementation challenges as part of the National Grants Management Association’s 2020 Virtual Grants Training and Summit, Lisa Andrew, CPA, controller with Prevention First Inc., explained that her organization receives no direct federal dollars, but receives federal funds under eight subgrants from various Illinois state agencies. Illinois published administrative rules in 2017 under the state’s Grant Accountability and Transparency Act (GATA), which aimed to assist state agencies in implementing the uniform guidance, and to “eliminate duplicative grant requirements and reduce administrative burdens while increasing accountability and transparency.” GATA promotes a library of forms, such as a uniform notice of funding opportunity, uniform prequalification process, uniform grant application, uniform programmatic and financial risk assessments, uniform guideline for merit-based reviews and a uniform grant agreement.
Although Andrew said that the state, through GATA, is generally “making great strides in trying to achieve a better system for grants management,” her organization still his challenged by the lack of uniformity and technical assistance from various state agencies. She said that each of her organization’s eight grants have different grant managers who have provided inconsistent guidance. Even though the state, under GATA, developed a library of forms designed to encourage uniformity, Andrew said “not everyone is following suit,” adding that while some agencies have adopted the forms, some “have changed them to suit their own needs.” As a result, Andrew said her organization has to provide requested information under a different template, sometimes in a hurried timeframe.
In addition, pass-through agencies within the state want particular information under different line items, which hinders the use of automated reporting, Andrew noted. For example, one agency requests that postage costs be listed as “supplies”, while another wants it listed as “miscellaneous.” While most of the pass-through agencies in the state enable her organization to submit grant reporting documents electronically, Andrew said others still require a hard-copy report, signed and mailed.
“This lack of consistency is confusing and time-consuming,” she said. “It’s created a pile of frustration for those handling multiple grants.”
Co-presenter Carol Kraus, CPA, director of Illinois’ Grant Accountability and Transparency Unit within the Governor’s Office of Management and Budget, said that her state agencies are challenged in finding staff with the skill set necessary for grant management. She admitted there has been a lot of turnover at all levels, and they are sometimes “proving assistance to grantees who know more than the state agency staff.” Despite the amount of training her office provides to staff among the 32 state agencies, “we still have difficulty ensuring that the entities within the state are following the rules,” she said. The agencies “struggle with those pieces, but overall, [the state] still has good structure in place.”
This is an example of what is occurring for subrecipients in one state. Subrecipients in other states could find they are in the same situation. The need for uniformity, as well as continuous grants training, is critical to achieve the original intent of the “uniform” grant guidance.
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Federal Grants Forum: Chicago, IL | August 12 – 14, 2020
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Learn more at http://grants.thompson.com/conferences.aspx.