Will Maintain Indirect Cost Data

OMB Memo M-21-03 Addresses Various Data-Related Topics for Federal Agencies
Jerry Ashworth
November 17, 2020 at 07:24:51 ET

The Office of Management and Budget (OMB), in a recently released memo to federal agencies, designated as the public website to maintain information about grant recipient federally negotiated indirect cost rates.

In the Aug. 13 revisions to the uniform guidance, which became effective Nov. 12 and apply to new awards or modifications to existing awards issued as of that date (see ¶101 in the Federal Grants Management Handbook), OMB included a new provision at §200.414(h), which states that “the federally negotiated indirect rate, distribution base and rate type for a nonfederal entity (except for the Indian tribes or tribal organizations, as defined in the Indian Self Determination, Education and Assistance Act, 25 U.S.C. 450b(1)), must be available publicly on an OMB-designated federal website.”

OMB on Nov. 12 issued Memorandum M-21-03, entitled “Improvements in Federal Spending Transparency for Financial Assistance,” which addressed several data-related topics. It requires that all information in signed and legally binding grant award agreements to be made public on to the maximum extent permitted by law, except for information that would be exempt from disclosure under the Freedom of Information Act. While designating as the official federal website for posting the indirect cost rates, the memo further explained that cognizant agencies, effective for federal fiscal year (FY) 2022, must report this information for each funded nonfederal entity to a central location for display on recipient profiles. The Grants Data Standards Element Working Group will provide details as to what data elements are needed to link this information to recipient data in the System for Award Management (

Standardizing Data

Federal processes to make indirect cost rates publicly available tie in with work OMB is conducting under the Grant Reporting Efficiency and Agreement Transparency (GREAT) Act (Pub. L. 116-103) (see ¶473 in the Handbook). By the end of November, OMB will assemble a working group to provide recommendations on a set of common standard data elements for award agreements and information related to indirect cost rates. This process aims to build on Version 1.0 of the Grants Standard Data Elements (see “OMB Issues Grants Management Standard Data Elements Version 1.0,” December 2019) and on the results of the Digital Accountability and Transparency Act (DATA Act) (Pub. L. 113-101) Section 5 pilot.

“At a minimum, the working group will consider the information in the awards agreement to include the terms and conditions, along with the notice of funding opportunity, the indirect cost rate, and intended performance results, or other data elements” that support implementation of the uniform guidance, the memo explains, adding that once OMB approves the standard data elements, it will work with the Department of the Treasury to establish technical standards.

By the end of February 2021, according to the memo, the working group will submit the revised grants standard data elements to the federal Business Standards Council for OMB approval. Once the standards are approved, federal agencies must adopt and implement them in their grants management systems so that spending and award data, including indirect cost rate information, can be displayed on beginning in FY 2022.

Award Description

The memo also sought to remind federal awarding agencies that they must report an award description for any actions associated with an award, and about existing guidance related to data quality pertaining to financial assistance award descriptions. Such descriptions should avoid acronyms or federal- or agency-specific terminology, and should identify in plain language the: (1) purpose of the award, along with specific performance goals, indicators, milestones or expected outcomes of the award (§200.301)); and (2) intended beneficiary or recipient of the funds.

“Strong award descriptions provide the reader with an understanding of the purpose of the federal financial assistance award being provided to the recipient and include a description of award-specific activities and purposes,” OMB explained. “Federal awarding agencies are discouraged from including general programmatic level information in the program description.”

Other Requirements

The memo also urged federal agencies to use existing data to develop a risk-based performance framework to better manage recipient risk and support successful results. The memo called for, in FY 2021, to display relevant recipient data and information that can be made available through certain links, such as the employer identification number. OMB also will bring together a working group to identify additional opportunities and recommendations to leverage and link existing recipient data.

OMB further explained that federal awards sometimes may be funded through multiple Assistance Listings numbers (formerly Catalog of Federal Domestic Assistance numbers), yet agencies currently are only required to report the predominant Assistance Listing to, as the others are now optional. The memo states that agencies, effective in FY 2022 for all new awards, must report all Assistance Listings and the associated funding for each federal financial assistance award to

Lastly, the memo also reminded agencies to review and ensure that they must have controls in place for providing transparent spending information to to meet the “strategic objective of providing reliable information connecting financial information to awards for management decisionmaking and for public accountability.” This includes maintaining a DATA Act Data Quality Plan through FY 2021 and until all COVID-19-related funding is expended.

For More information

OMB Memorandum M-21-03 is available at

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