OMNICIRCULAR GRANT REFORM: Videos and Analysis

OMB recently issued new metrics to measure the impact of the Uniform Guidance via OMB Memorandum M-14-17. Federal agencies are required to issue implementing regulations effective December 2014. COFAR has established metrics to gauge how the guidance addresses its intended enhancements and to measure the performance of the Federal government’s work in the management of assistance in the form of Federal financial assistance. By January 2017, OMB with the COFAR will evaluate the initial impact of the guidance based on these metrics and determine what additional steps may be necessary to further deliver administrative efficiency.

  • By January 15, 2015: All CFO Act agencies must report required baseline data for administrative metrics to OMB. OMB will provide a framework for metric collection via MAX. The Federal Audit Clearinghouse will provide baseline data for the audit metrics.
  • By January 15th (or following business day) of each subsequent year: Federal agencies and Federal Audit Clearinghouse must provide implementation metrics to OMB where required by memo M-14-17, which will be evaluated by the OMB and the COFAR.
  • By January 15, 2017: OMB and the COFAR will evaluate the utility of these metrics for evaluation of the guidance and as sentinels to identify issues with the guidance and opportunities to enhance effective implementation. As part of this evaluation, the COFAR will consider whether it is appropriate to set goals or target outcomes for these metrics.

In the first year, the COFAR anticipates that there will be some additional administrative burden resulting from the transition to the new guidance which will decrease once the new policies are fully implemented. In order to minimize this burden, OMB intentionally developed metrics that may be predominately measured based on the information they already collect. Information to be collected from non-Federal stakeholders will be entirely optional. At this initial stage, metric collection is only to inform the COFAR about the current impact of implementation. Once the COFAR has reviewed the metrics for the first year, it will consider whether it is appropriate to establish goals or target outcomes for any given metric.

Administrative Metrics:

  1. Inventory of OMB-approved Information Collections for Grants and Cooperative Agreements
  2. Number of OMB-approved Exceptions Focused on Program Performance Over Compliance
  3. Number of Fixed Amount Awards Issued
  4. Number/Impact of Agency Exceptions to the Provision of Federally Negotiated Rates
  5. Number of Indirect Cost Rate Extensions Approved by Cognizant Agencies
  • Frequency: Annual
  • Baseline: Guidance under previous circulars
  • Data Elements and Sources of Data: HHS-led data standards repository, OMB records of exceptions, Federal agency records of fixed amount awards collected via MAX, and indirect cost rate negotiation agencies.
  • Burden of Obtaining Data: Moderate – this will require some data to be collected from Federal agencies.

Single Audit Metrics:

  1. Number of Modified Opinions for Higher Risk Major Programs
  2. Number of Audit Findings of Material Weaknesses in Internal Controls for Higher Risk Major Programs
  3. Number of Repeat Findings for Higher Risk Major Programs (Starting FY 2015)
  4. Number of Major Programs selected for audit
  5. Number of Audit Objectives in the Compliance Supplement
  • Frequency: Annual
  • Baseline: Audit Metrics FY 2014
  • Data Elements and Sources of Data: FAC data, Single Audit reports, and the Compliance Supplement
  • Burden of Obtaining Data: Low to moderate as data routinely collected in the regular FAC or Compliance Supplement processes

Overall Impact on Burden and Waste, Fraud, and Abuse:

  1. Policy change that most reduced administrative burden and dollar value of impact.
  2. Policy change that most increased administrative burden and dollar value of impact.
  3. Policy change that most reduced risk of waste, fraud, and abuse, and dollar value of impact.
  4. Policy change that most increased risk of waster, fraud, and abuse, and dollar value of impact.
  5. Stakeholder satisfaction with the opportunity to engage with the COFAR or Federal agencies during the policy development process.
  6. Stakeholder perception of whether the policy outcomes appears responsive to (if not 100% aligned with) their input.
  7. Opportunities for greater stakeholder engagement.
  • Frequency: Annual
  • Baseline: Guidance under previous circulars
  • Data Elements and Sources of Data: Key stakeholder groups that voluntarily submit aggregated information on behalf of their constituencies.
  • Burden of Obtaining Data: Low to moderate as data collected voluntarily.
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