Grants Management
Additional Actions Needed to Streamline and Simplify Processes Gao ID: GAO-05-335 April 18, 2005The federal government distributed about $400 billion in federal grants in fiscal year 2003 through about 1,000 different federal grant programs administered by several federal agencies with different administrative requirements. Congress, concerned that some of these requirements may be duplicative, burdensome, or conflicting--and could impede cost-effective delivery of services--passed the Federal Financial Assistance Management Improvement Act of 1999, commonly called P.L. 106-107, and mandated that GAO assess the act's effectiveness. This report addresses (1) progress made to streamline and develop common processes for grantees and (2) the coordination among the Office of Management and Budget (OMB), the agencies, and potential grant recipients.
More than 5 years after passage of P.L. 106-107, grant agencies have made progress in some areas of grant administration, but in other areas, particularly the development of common reporting systems, progress is just beginning. Grant-making agencies together developed a common plan for streamlining processes. Several cross-agency teams identified changes that should be made, and these plans are in various stages of completion. For example, a Web-based system, Grants.gov, is now available to help potential grantees identify grant opportunities and apply for them electronically. Common forms are being developed to eliminate duplication and unnecessary differences among agencies. However, efforts toward common electronic systems for reporting financial and performance information have not been developed, although the law requiring them sunsets in 2007. Further, individual agencies have not all reported on their progress annually, as required. The individual agencies and the cross-agency work groups have a mixed record of coordinating with grantees. For example, the cross-agency work groups solicited public input to their early plan. Grants.gov publicizes its plans and solicits ongoing grantee input through its Web site and user surveys. However, the work groups generally have not made information about their work public nor solicited ongoing grantee input. Without such input, reforms are less likely to meet the needs of grantees. In general, the oversight of streamlining initiatives has shifted, potentially contributing to the lack of progress on all aspects of grant management.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-335, Grants Management: Additional Actions Needed to Streamline and Simplify Processes
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Report to Congressional Committees:
April 2005:
Grants Management:
Additional Actions Needed to Streamline and Simplify Processes:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-335]:
GAO Highlights:
Highlights of GAO-05-335, a report to the Committee on Homeland
Security and Governmental Affairs, U.S. Senate, and the Committee on
Government Reform, House of Representatives:
Why GAO Did This Study:
The federal government distributed about $400 billion in federal grants
in fiscal year 2003 through about 1,000 different federal grant
programs administered by several federal agencies with different
administrative requirements. Congress, concerned that some of these
requirements may be duplicative, burdensome, or conflicting-and could
impede cost-effective delivery of services-passed the Federal Financial
Assistance Management Improvement Act of 1999 (FFAMIA), and mandated
that GAO assess the act‘s effectiveness. This report addresses (1)
progress made to streamline and develop common processes for grantees
and (2) the coordination among the Office of Management and Budget
(OMB), the agencies, and potential grant recipients.
What GAO Found:
More than five years after passage of FFAMIA, grant agencies have made
progress in some areas of grant administration, but in other areas,
particularly the development of common reporting systems, progress is
just beginning. Grant-making agencies together developed a common plan
for streamlining processes. Several cross-agency teams identified
changes that should be made, and these plans are in various stages of
completion. For example, a Web-based system, Grants.gov, is now
available to help potential grantees identify grant opportunities and
apply for them electronically. Common forms are being developed to
eliminate duplication and unnecessary differences among agencies.
However, efforts toward common electronic systems for reporting
financial and performance information have not been developed, although
the law requiring them sunsets in 2007. Further, individual agencies
have not all reported on their progress annually, as required.
The individual agencies and the cross-agency work groups have a mixed
record of coordinating with grantees. For example, the cross-agency
work groups solicited public input to their early plan. Grants.gov
publicizes its plans and solicits ongoing grantee input through its Web
site and user surveys. However, the work groups generally have not made
information about their work public nor solicited ongoing grantee
input. Without such input, reforms are less likely to meet the needs of
grantees. In general, the oversight of streamlining initiatives has
shifted, potentially contributing to the lack of progress on all
aspects of grant management.
FFAMIA Implementation and Oversight Groups:
[See PDF for image]
[End of figure]
What GAO Recommends:
To augment the progress toward streamlining grant administration, GAO
recommends that OMB ensure that (1) initiatives have clear goals for
completion, (2) agency annual progress reports are prepared, (3)
efforts toward common reporting continue on track, (4) OMB‘s
streamlining strategy integrate the three individual initiatives now
under way, and (5) grantee input is solicited on an ongoing basis. In
written comments on the draft report, OMB generally agreed with the
report.
www.gao.gov/cgi-bin/getrpt?GAO-05-335. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Paul Posner at (202) 512-6806 or posnerp@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Some Progress Made in Streamlining Grant Administration across
Agencies, but More Progress Is Needed:
Coordination Activities Established across Agencies, but Initiatives
Lack Continuing Input from Grantees:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: P.L. 106-107 Annual Reports Submitted to Congress as of
March 1, 2005:
Appendix II: Detailed Information on Grants.gov:
Appendix III: Comments from the Office of Management and Budget:
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Acknowledgments:
Tables:
Table 1: Current Cross-Agency Work Groups Addressing P.L. 106-107
Objectives:
Table 2: Status of Streamlining Initiatives and Their Expected Impact
on Grantees:
Table 3: P.L. 106-107 Annual Reports Submitted to Congress as of March
1, 2005:
Table 4: Status of Agency Participation in Grants.gov "Apply" Component
(as of April 6, 2005):
Figures:
Figure 1: Grant Life Cycle:
Figure 2: P.L. 106-107 Implementation and Oversight Groups:
Abbreviations:
FACA: Federal Advisory Committee Act of 1972:
OMB: Office of Management and Budget:
HHS: Department of Health and Human Services:
Letter April 18, 2005:
The Honorable Susan M. Collins:
Chairman:
The Honorable Joseph I. Lieberman: Ranking Minority Member:
Committee on Homeland Security and Governmental Affairs: United States
Senate:
The Honorable Tom Davis:
Chairman:
The Honorable Henry A. Waxman:
Ranking Minority Member:
Committee on Government Reform:
House of Representatives:
The federal government distributed about $400 billion in federal grants
in fiscal year 2003, which accounted for almost one-fifth of the
federal budget. Funds from these grants are used to implement about
1,000 different federal grant programs, administered and overseen by 26
different federal agencies as well as some smaller federal entities.
These grant programs generally have different objectives and strategies
that are reflected in their application, selection, monitoring, and
reporting processes. In seeking out, using, and reporting on these
grants, grantees--with a wide variety of resources and expertise--must
adapt to the different requirements, potentially spending valuable time
and resources on administrative issues rather than in advancing the
causes that the grant funds were intended to affect. Congress,
concerned that some of these administrative requirements may be
duplicative, burdensome, or conflicting and could impede the cost-
effective delivery of services at the local level, passed the Federal
Financial Assistance Management Improvement Act of 1999, commonly
referred to by the grants community as P.L. 106-107.[Footnote 1] The
act required coordination among federal grant-making agencies to
streamline administrative requirements and to improve coordination
among federal grantor agencies and their nonfederal partners.
When the act was passed, it specifically mandated a study by GAO that
would assess the act's effectiveness, make specific recommendations to
improve its implementation, evaluate each grantor agency's performance
in achieving its planned goals and objectives, and assess the
coordination among key players. In this report, we will address (1)
what progress has been made to streamline and develop common processes
for grantees and (2) the extent of coordination among the Office of
Management and Budget (OMB), the agencies, and potential grant
recipients. We plan to focus future work on assessing the impact of
grant-process reforms on the diverse array of grant recipients.
To address our objectives, we reviewed P.L. 106-107 to understand its
requirements. We also reviewed the common plan developed by the 26
grant-making agencies and the subsequent annual reports from the
agencies as submitted to OMB and Congress. We met with officials from
(1) OMB, (2) cross-agency work groups established to address the
objectives of P.L. 106-107, and (3) two specific initiatives that are
closely related to the law's streamlining objectives--a common Web
portal for potential grantees to identify and apply for grants
(referred to as Grants.gov) and an initiative to streamline grant
management within agencies (referred to as the Grants Management Line
of Business initiative). To assess agency progress we analyzed the
agencies' 2004 annual reports to identify significant progress. We
attempted to identify tangible and quantifiable results that met the
goals laid out in the common plan, as well as the objectives of the
act. To provide more in-depth perspective on the implementation of
grant streamlining efforts and coordination with other agencies and
grantees, we met with officials from four agencies--the Department of
Transportation, the Department of Health and Human Services (HHS), the
National Endowment for the Humanities, and the National Science
Foundation. In selecting these agencies, we considered the number of
subagencies, the types and amounts of grants dispersed, the types of
grant recipients, and the level of participation in specific
streamlining activities. To analyze the coordination within and among
agencies and with grantees, we compared agency coordination efforts
with criteria developed in our prior work, and we discuss the criteria
in the report. Although we had some initial discussions on grant
administration with organizations representing grantees, we plan to
obtain views from a wider spectrum of grantees in a second study
responding to the P.L. 106-107 mandate. We conducted our work in
accordance with generally accepted government auditing standards from
March 2004 through March 2005.
Results in Brief:
More than 5 years after passage of P.L. 106-107, cross-agency work
groups have made some progress in streamlining aspects of the early
phases of the grants life cycle and in some specific aspects of overall
grants management; however, efforts toward common electronic systems
for reporting financial and performance information have not
progressed, although the law requiring these improvements sunsets in
2007. After P.L. 106-107 was passed in 1999, OMB designated HHS as the
lead agency in implementing the act. Grant-making agencies provided
staff to work groups, which developed a common plan and set goals for
streamlining procedures related to all phases of grant management.
These plans are in various stages of completion. For example, a new Web-
based system, called Grants.gov, is now available to help potential
grantees identify grant opportunities more easily and apply for them
electronically. OMB has most recently initiated a major cross-
government effort called the Grants Management Line of Business
initiative, which seeks to provide a governmentwide solution to manage
agencies' grant activities. According to the cross-agency team
responsible for the initiative, it will attempt to consolidate grant
management systems across agencies and may include a common system for
financial and performance reporting, but development of such a system
has not begun. The cross-agency work groups have identified other
potential reforms. Some have been implemented, such as developing a
standard format for the announcement of grant opportunities. Other
changes have been proposed but have not yet been implemented, such as
developing standard reports for grantees to complete, which should
reduce the administrative burden of completing different reports for
each associated grant-making agency.
Several cross-agency groups have coordinated the grant streamlining
efforts of the federal grant-making agencies, but coordination with the
grantee community, required under P.L. 106-107, has been more limited.
The Grants Executive Board, which has members from 13 grant-making
agencies, oversees the implementation work groups and the Grants.gov
initiative. However, uncertainty about the roles of the various
implementation groups appears to have hampered progress. In their early
work, the groups undertook efforts to coordinate and consult with the
grantee communities; these efforts included public consultation
meetings and solicitations of public comments. The Grants.gov
initiative has built coordination with the users into the process;
users have been surveyed three times, and there have been continuing
efforts to publicize its availability and provide training to the
grantee community. However, as the work groups address other aspects of
streamlining, they have not been involving the grantee community to the
same extent.
We are recommending that OMB take several actions to augment the
progress toward meeting the goals of P.L. 106-107. In its written
comments on our draft report, OMB generally agreed with our findings
and recommendations, and provided comments on its status related to the
recommendations. In addition, we received technical comments verbally
from OMB officials, which we incorporated in the report as appropriate.
Background:
Congress, concerned about the burden on grantees of multiple, varying
requirements imposed by different grant programs, passed P.L. 106-107
in 1999. The act's objective is to improve the effectiveness and
performance of federal financial assistance programs, simplify federal
financial assistance application and reporting requirements, improve
the delivery of services to the public, and facilitate greater
coordination among those responsible for delivering such services. The
act required agencies to establish common applications, systems, and
uniform rules to improve the effectiveness and performance of federal
grants with the goal of improved efficiency and delivery of services to
the public. Under P.L. 106-107, OMB is required to direct, coordinate,
and assist federal agencies in developing and implementing a common
application and reporting system, including electronic processes with
which a nonfederal entity can apply for, manage, and report on the use
of funds from multiple grant programs that serve similar purposes but
are administered by different federal agencies. The act sunsets in
November 2007.
The complexity and diversity of the grants system makes streamlining a
difficult endeavor. Multiple federal entities are involved in grants
administration; the grantor agencies have varied grants management
processes; the grantee groups are diverse; and grants themselves vary
substantially in their types, purposes, and administrative
requirements. The federal grant system continues to be highly
fragmented, potentially resulting in a high degree of duplication and
overlap among federal programs.[Footnote 2] Hundreds of federal grant
programs implement various domestic policies and have administrative
requirements that may be duplicative, burdensome, or conflicting--which
can impede the effectiveness of grants programs.
Multiple federal entities are involved in grants management. The
Federal Grant and Cooperative Agreement Act of 1977 gives OMB the
authority to issue supplementary interpretive guidelines to promote
consistent and efficient use of grant agreements.[Footnote 3] OMB
publishes this guidance to federal agencies in OMB circulars and
federal agencies issue regulations implementing the OMB guidance. The
General Services Administration is the lead agency in charge of
disseminating information on funding opportunities. It publishes, in
both electronic and print form, the Catalog of Federal Domestic
Assistance, a searchable database of federal financial assistance
programs.
There is substantial diversity among the federal agencies that
administer grants. Some agencies administer many grants through
multiple, decentralized subagencies, while other agencies have small,
centralized grant-making offices that administer only a few, small
grant programs. For example, in fiscal year 2003, HHS administered 282
grant programs that distributed approximately $246 billion through its
16 subagencies, while the National Endowment for the Arts administered
3 grant programs that distributed approximately $95 million.
Grant programs are diverse in their structure and purpose. Grants can
be grouped into three types based on the amount of discretion given to
the grantee for the use of funds. Each type strikes a different balance
between the desire of the federal grantor that funds be used
efficiently and effectively to meet national objectives and the desire
of the grantee to use the funds to meet local priorities and to
minimize the administrative burdens associated with accepting the
grant. Categorical grants allow the least amount of recipient
discretion, general revenue-sharing grants the most, and block grants
an intermediate amount. Grant funds may also be grouped by their method
of allocating funds, that is, by formula, through discretionary project
grants, or both. Formula grants allocate funds based on distribution
formulas prescribed by legislation or administrative regulation.
Project grants are generally awarded on a competitive basis to eligible
applicants. Grant programs fund a variety of types of programs,
including training, research, planning, evaluation, capacity building,
demonstration projects, construction, and service provision in many
different areas including health care, education, law enforcement, and
homeland security. The diversity of grant programs is matched by the
diversity of grant recipients. Grant announcements identify the
eligible recipients, which may include states and their agencies, local
governments, tribal governments, nonprofit organizations, research
institutions, and individuals.
The opportunities to streamline grants administration differ throughout
the life cycle of a grant. While there is substantial variation among
grants, generally grants follow the life cycle as shown in figure 1:
announcement, application, award, postaward, and closeout. Once
established through legislation, which may specify particular
objectives, eligibility, and other requirements, a grant program may be
further defined by grantor agency requirements. For competitive grant
programs, the public is notified of the grant opportunity through an
announcement, and potential grantees must submit applications for
agency review. In the awards stage, the agency identifies successful
applicants or legislatively defined grant recipients and awards
funding. The postaward stage includes payment processing, agency
monitoring, and grantee reporting, which may include financial and
performance information. The closeout phase includes preparation of
final reports, financial reconciliation, and any required accounting
for property. Audits may occur multiple times during the life cycle of
the grant and after closeout.
Figure 1: Grant Life Cycle:
[See PDF for image]
[End of figure]
Some Progress Made in Streamlining Grant Administration across
Agencies, but More Progress Is Needed:
To implement P.L. 106-107's requirement to improve the effectiveness
and performance of federal grants, a common plan was developed and
most, but not all, grant-making agencies have submitted reports
annually on their progress toward this plan as required by the law. The
work groups have identified several changes that should be made, but
many of these are still in the developmental or approval stages. One
particular extensive effort--the development of a Web portal called
Grants.gov that represents a common face to grantees--has enabled
grantees to identify relevant grant opportunities and, to a limited
extent, apply electronically for grants. For the later phases of the
grant life cycle, a new initiative is under way, the Grants Management
Line of Business, that will encompass all phases of the grant life
cycle and specifically address simplifying the administration and
management of grants.
In 2001 Agencies Developed a Common Plan to Guide Federal Grant
Streamlining Efforts:
P.L. 106-107 requires that under OMB leadership, agencies develop
common applications, systems, and administrative rules to improve the
effectiveness of federal grants. To implement this requirement, a cross-
agency committee established cross-agency work groups. The work groups
then identified needed changes and developed a common plan for
implementing P.L. 106-107. Twenty-six federal grant-making agencies
agreed to use this common plan to meet the law's requirements, since
meeting its objectives required them to work together to a large
extent. The plan, submitted to Congress and OMB in May 2001, was
developed under the oversight of the initial interagency governance
structure established to implement P.L. 106-107. A series of five
public consultation meetings was held with representatives from states,
local governments, Native American tribes and tribal organizations,
universities and nonprofit organizations that conduct research, and
other nonprofit organizations. Comments from these meetings were
considered in developing the plan.
The common plan contained goals and objectives intended to meet the
requirements of P.L. 106-107. It included progress, accomplishments,
and planned activities for streamlining and simplifying the award and
administration of federal grants. The plan addressed the life cycle of
the grant process, supporting processes, systems and standards, as well
as other issues. Some specific objectives included (1) streamlining,
simplifying, and improving announcements of funding opportunities and
related business processes, application requirements and procedures,
and award documents; (2) streamlining and simplifying standard and
unique report forms, allowing for electronic submission of reports,
achieving greater uniformity in federal business processes for
reporting, and improving reporting by recipients; (3) simplifying and
standardizing, to the extent appropriate, general administrative
requirements and agency treatment of them in the terms and conditions
of award; and (4) fully developing and implementing a portal for
identifying and applying for grants, and ensuring that any revised
electronic data standards are interoperable and present a common face
to grant-making agencies, applicants, and recipients.
The common plan also included some process improvements that began
before passage of P.L. 106-107 and were completed prior to adoption of
the plan or are still continuing today. For example, since 1998 the
federal government has required grant-making agencies to transition
from various payment systems to one of three designated systems. The
common plan included objectives and milestones directly related to such
past activities that have been incorporated into the plan. The plan is
also built on successful models resulting from earlier initiatives of
individual agencies or interagency groups. For example, one objective
of the common plan was to ensure that federal agencies' grant financial
systems comply with requirements established by the Joint Financial
Management Improvement Program.
Agency Progress Varies, and Not All Have Filed Annual Reports:
Annual governmentwide progress reports describe the collaborative
efforts of 26 federal agencies. Each agency also reports annually on
its progress implementing the plan, although not all agencies have
regularly submitted these reports. The annual governmentwide progress
report describes the collaborative efforts to streamline and simplify
the award and administration of federal grants. The report includes the
federal government's steps toward simplification of the grant policy
framework. For instance, the establishment of a central location for
OMB guidance to federal agencies and agency regulations implementing
that guidance will make it easier for the applicants and recipients to
find and follow administrative requirements. It also includes completed
initiatives, such as the development and use of a standard format for
agencies' funding announcements, which aims to make it easier for
potential applicants to quickly find specific information in the
announcements.
P.L. 106-107 requires each federal grant-making agency to provide an
annual progress report that evaluates its performance in meeting the
common plan's goals and objectives. However, only 22 of the 26 agencies
have submitted their 2004 annual report to Congress. (See app. I for
information on agencies submitting reports for 2002 to 2004.) Agencies
have reported progress in implementing some streamlining activities.
For example, HHS has worked toward the internal consolidation from nine
to two grant management systems, one primarily supporting research
grants and the other primarily supporting nonresearch, or service
grants. Another agency, the National Science Foundation, reported it is
conducting a comprehensive business analysis that will highlight areas
where grant processes can be streamlined and simplified. Also, the
National Endowment for the Humanities reported it has streamlined the
internal agency clearance process, which is the mechanism by which all
grant applications' guidelines and forms are reviewed and updated every
year.
Some factors, both internal and external to the grant-making agencies,
may have slowed agencies' progress in fully implementing streamlining
activities and have contributed to the lack of progress in adopting
common governmentwide systems. The different business processes at
various agencies was one reason agencies reported a hesitation to
migrate to a common grant management system. For example, the National
Science Foundation reported that it conducts peer reviews of broad
research grant programs, which require an entirely different type of
management system when compared to the Department of Transportation,
which generally manages noncompetitive formula grants to state and
local governments.
The structure and size of an agency's grant management program is
another factor that may affect the agency's progress toward grant
streamlining. For example, some smaller agencies such as the National
Endowment for the Humanities, which has a highly centralized grant
management operation, reported being able to more quickly adopt some of
the governmentwide grant streamlining initiatives. However, other
agencies that manage grant programs from many different operating
divisions may take longer to make changes due to the decentralized
organizational structure and the larger number of grant programs.
Lastly, some agencies had existing online grant management systems
before the passage of P.L. 106-107 and the development of Grants.gov.
The integration of preexisting grant streamlining achievements in some
agencies, such as the common announcement form adopted from National
Science Foundation and National Endowment for the Humanities work,
allows those agencies to realize more immediate benefits because much
of the work was completed prior to implementation of the common plan.
Agencies, such as the Department of Transportation, that have not fully
implemented internal streamlining initiatives need to do so before they
can fully benefit from the approaches adopted by other agencies or the
cross-agency work groups.
P.L. 106-107 also required agencies to establish performance measures
and a process for assessing the extent to which specified goals and
objectives have been achieved. In developing these performance
measures, the agencies were to consider input from applicants,
recipients, and other stakeholders. The annual agency progress reports
did not include any such performance measures or evaluations. Each of
the agencies' progress reports varied in detail and included a
narrative of some of the actions taken to meet identified goals and
objectives. Attempts to compare the progress of federal agencies to
each other are difficult due to the missing reports and the lack of
performance measures.
Cross-Agency Work Groups Developed Policies to Streamline, but Many Are
Not Implemented Yet:
After P.L. 106-107 was enacted, several cross-agency work groups were
created to facilitate the law's implementation; while some of their
developments have been implemented, others are still in progress. The
teams, which focused on different phases of the life cycle of grants,
identified initiatives that should be undertaken. To identify
priorities for action, the teams relied on comments from the grantee
community on what streamlining should occur and on their own knowledge
of grants management. With many potential areas on which to focus, some
work group representatives commented to us that they addressed the "low-
hanging fruit," preferring to work on those tasks that were more
readily accomplished while yielding strong results. The current work
groups and their responsibilities are shown in table 1. In addition,
some groups have subgroups that have taken responsibility for key
products. The work groups are supported to some extent by additional
contract staff funded initially by the Chief Financial Officers
Council.
Table 1: Current Cross-Agency Work Groups Addressing P.L. 106-107
Objectives:
Work groups: Pre-Award;
Responsibilities: Identifying streamlining and simplification
opportunities in the phase of the grants life cycle during which
potential applicants for discretionary grants identify funding
opportunities, and prepare and submit applications, and applicants are
notified if their applications were unsuccessful or, if their
applications were successful, receive awards.
Work groups: Post-Award;
Responsibilities: Identifying streamlining and simplification
opportunities in the phase of the grants life cycle during which
recipients perform their awards and submit progress, financial, and
other required reports (other than audit reports) and request and
receive payment, and federal agencies monitor awards for compliance,
oversee progress, and provide technical assistance.
Work groups: Mandatory Grants[A];
Responsibilities: Identifying streamlining and simplification
opportunities for mandatory grants, which include block grants, some
formula-based grants, and entitlement grants.
Work groups: Audit Oversight;
Responsibilities: Improving the OMB Circular A-133 single audit process
to ensure that audits provide useful and reliable information to
federal agencies and pass-through entities and that recipient audits
are in compliance with federal audit requirements.
Work groups: Training and Certification; Responsibilities: Addressing
governmentwide issues concerning the grants management workforce.
Developing the grants management series as a professional series and
developing standards for grants management training programs. (This
group began organizing in January 2005.)
Source: Grants.gov.
[A] These are noncompetitive grants for which eligibility is defined in
statute.
[End of table]
The cross-agency work groups have accomplishments that are expected to
streamline grant activity for grantees, as described in table 2. For
example, the Pre-Award Work Group focused on reducing the time a
grantee must spend searching for information on grants. One concern was
inconsistent announcement formats. The team believed that a consistent
format for grant announcements would save time and reduce frustration
for grantees that applied to different programs. The group also
developed the standard set of data elements for the Grants.gov "find"
feature, thereby ensuring that users of Grants.gov will find similar
information in the same places for different grant descriptions. The
Audit Work Group developed and distributed a pamphlet clarifying the
single audit process.[Footnote 4] It also ensured that OMB Circular A-
133, Compliance Supplement, was updated annually. This update should
ensure that grantees' auditors can more easily identify the criteria
that they should use as they assess whether grantees are in compliance
with grant requirements.
One area on which the work groups made progress was establishing a
common electronic system through which information on available grants
could be found and applicants could apply for grants, now called
Grants.gov.[Footnote 5] At that point, identifying grant opportunities
required searching information from many agencies and applying for them
using a variety of application forms and processes. The work groups
developed a common format for the full announcement to be used
governmentwide and a related set of data elements for an electronic
synopsis of the announcement. Grants.gov, now administered by a program
management office based in HHS, has provided the ability for potential
grantees to search open grant opportunities by these key components,
such as by the type of activity funded (e.g., education or the
environment) and the agency providing funds. Grantees also can request
notification of grant opportunities that meet certain parameters that
they identify. Grant opportunities were initially provided on the
system in February 2003, and in November 2003, OMB required that
federal agencies post information on all discretionary grant-funding
opportunities at the Web site. The Grants.gov Program Management Office
reports that since October 2003 all 26 grant-making agencies have
listed their discretionary grant opportunities. They also report high
growth in usage of the portal; Grants.gov reports that in November
2004, the "find" activity on the site received about 2.2 million page
requests, up from about 633,000 in November 2003, and applicant e-mail
notifications have averaged 600,000 to 700,000 weekly.
More recently, Grants.gov has provided the capability to apply for
grants electronically at a common portal and, to some extent, use
common forms across agencies. Applicants can download an application
package; complete the application off-line; and submit it
electronically to Grants.gov, which transmits the application to the
funding agency. Grant-making agencies work with the program management
office staff to identify the forms needed, sometimes using the same
forms as other programs and other agencies use. Grant applicants are
notified electronically when agencies receive their applications. In
some cases, agencies can download the grant application data directly
to their own internal systems, thus eliminating the need for staff to
input data. Use of the online applications, however, has been slow to
grow. As of April 6, 2005, 6 of the 26 key grant-making agencies had
not yet posted "apply" packages, and about 2,600 electronic
applications had been received. Use of the system requires agencies to
set up internal systems and, to some extent, have their forms loaded
onto the site. Grantees must also complete a registration process,
which we were told is time-consuming and might be viewed by some
applicants as intimidating but is necessary, according to OMB
officials, to ensure privacy and to maintain the security of the
system.
Funding for Grants.gov has shifted from obtaining contributions from
key partners to obtaining a set amount from grant-making agencies. For
fiscal years 2002 through 2004, Grants.gov was funded by contributions
totaling about $29.4 million. Beginning with fiscal year 2005, it will
be funded with payments from 26 grant-making agencies, based on an
agency's total grant dollars awarded. For 2005 and 2006, the 6 large
agencies will be assessed $754,467, the 10 medium agencies will be
assessed $452,680, and the 10 small agencies will be assessed $226,340,
for a total of about $11,300,000 each year. Appendix II provides more
detailed information on Grants.gov and individual agency information on
progress toward implementing its "apply" component.
Table 2: Status of Streamlining Initiatives and Their Expected Impact
on Grantees:
Grant phase: Announce/find grant opportunity:
Initiative: Standard announcement format; Status: Accomplished;
Expected impact on grantee: Enable potential grantees to find grant
information, such as eligibility requirements, in the full announcement
more quickly.
Initiative: Grants.gov "find" feature; Status: Accomplished;
Expected impact on grantee: Provide a common, searchable online
location for all open discretionary grant opportunities, with a link to
the full announcement, and reduce the administrative burden on
potential grantees of finding relevant grants.
Grant phase: Grant application:
Initiative: Data Universal Numbering System (DUNS) requirement; Status:
Accomplished;
Expected impact on grantee: No direct benefit for grantees.
Initiative: Grants.gov "apply" feature; Status: Accomplished;
Expected impact on grantee: Provide a common online location for
obtaining grant application forms and submitting a grant application.
Initiative: Update the debarment and suspension and drug-free workplace
common rules; Status: Accomplished;
Expected impact on grantee: Benefit applicants and recipients by
reconciling unnecessary differences, using plain language, and
simplifying the requirements of the rules.
Initiative: Adopt the SF-424 a standard federal form for research and
related grant applications; Status: In progress;
Expected impact on grantee: Reduce the number of different forms that
grantees need to complete when applying to different agencies.
Initiative: Expand Grants.gov "apply" feature to accept electronic
plans and applications for mandatory grants; Status: In progress;
Expected impact on grantee: Provide common location for submitting
annual plans and updates.
Grant phase: Application review and decision:
Initiative: None;
Status: --;
Expected impact on grantee: --.
Grant phase: Notification of grant award:
Initiative: Standard award notice and standard governmentwide terms and
conditions; Status: In progress;
Expected impact on grantee: Reduce unnecessary burden on recipients by
making federal agencies' awards as alike as practicable.
Initiative: Post announcement of mandatory grant awards on Grants.gov;
Status: In progress;
Expected impact on grantee: Enable potential grantees to find pass-
through grant funding opportunities. Increase the transparency of
federal grants policy.
Grant phase: Payment:
Initiative: Consolidate to three payment systems (applies only to the
agencies subject to the Chief Financial Officers Act); Status: In
progress;
Expected impact on grantee: Reduce the number of payment systems with
which grant recipients will need to interact, potentially saving
software and staff training costs.
Grant phase: Reporting:
Initiative: Streamline cost principles; Status: Accomplished;
Expected impact on grantee: Provide consistent descriptions and
clarifying language for similar cost items across the three OMB cost
principles circulars.
Initiative: Develop:
* Standard Federal Financial Report;
* Standard Non-research Performance Progress Report;
* Standard Research Progress Report;
* Standard Personal Property Report;
* Standard Real Property Report;
* Standard Summary Report of Inventions; Status: In progress;
Expected impact on grantee: Reduce the administrative burden of having
different reports to complete for each associated grant-making agency.
Initiative: Audit:
Initiative: Improve agency access to audit information, including
delinquent audits; Status: Accomplished;
Expected impact on grantee: No direct benefit expected for grantees.
(Primarily will benefit federal agencies by helping them to determine
whether certain grantees are delinquent in submitting their audits, and
enabling agencies to make better use of audit results in managing their
grant programs and awards.)
Initiative: Update the OMB Circular A-133, Compliance Supplement,
annually; Status: Accomplished;
Expected impact on grantee: Provide auditors with accurate and up-to-
date information for the conduct of single audits.
Initiative: Distribute a pamphlet, Highlights of the Single Audit
Process, to federal recipients and federal agencies; Status:
Accomplished;
Expected impact on grantee: Ensure a better understanding of the single
audit process and improve audit timeliness.
Initiative: Increase the audit threshold for single audits from
$300,000 to $500,000; Status: Accomplished;
Expected impact on grantee: Fewer grantees will be subject to single
audit requirements.
Grant phase: Closeout:
Initiative: None;
Status: --;
Expected impact on grantee: --.
Grant phase: Crosscutting issues:
Initiative: Colocate OMB guidance to agencies and agency regulations
implementing the guidance in Title 2 of the C.F.R; Status: In progress;
Expected impact on grantee: Make OMB guidance and agency regulations on
grants easier to find and use.
Source: GAO analysis of cross-agency annual reports and discussions
with agency officials.
[End of table]
Several reforms are partially under way but have not yet completed the
approval process or been implemented, as shown in table 2. For example,
a separate standard application form for research (and related) grants
has been proposed, which will ensure that multiple agencies will be
able to use the same application. This should simplify applications for
grantees who apply for grants at multiple agencies, but this form is
not yet approved. Similarly, the Post-Award Work Group has developed a
common Performance Progress Report for nonresearch grants and has
received agency comments on the proposed form. The group expects that
this will reduce the concern that too many different progress reports
are used, which poses a substantial administrative burden for grantees.
The work group also developed several common forms, such as a Real
Property Report (which addresses real property built with grant funds)
and a federal financial report, which, as of December 22, 2004, was
with OMB for approval. The Mandatory Work Group is developing a set of
core data elements that could be used to post mandatory awards to the
Grants.gov Web site, which an OMB official commented would enable
potential contractors to be aware of funds that states and other
entities were receiving. Additionally, based on an initiative begun by
the Pre-Award Work Group, OMB has moved one of its circulars, which
provides guidance, to a newly created Title 2 of the Code of Federal
Regulations and plans that agencies will eventually colocate their
grant regulations in the same title.[Footnote 6]
Common Systems for Managing Later Parts of Grant Life Cycle Are at
Early Stages of Development:
Although the Grants.gov portal has provided a common, electronic system
for helping grantees identify and apply for grants, development of
common, electronic systems for managing later stages of the grant life
cycle has not progressed. When originally planned, the Grants.gov
portal was envisioned as providing a common face to grantees for
managing all phases of grants, from grantees' identification of
appropriate grant opportunities through application, awarding, and
management of the grants. However, in early 2004, OMB instructed
Grants.gov officials to cease their efforts to develop common systems
for the grant phases beyond application and to concentrate on ensuring
that electronic applications were fully implemented at all grant-making
agencies, since some agencies still were not participating or were
participating at minimal levels.
In March 2004, OMB initiated a governmentwide analysis of five lines of
business that would support the President's Management Agenda goal of
expanding electronic government, with one of them focusing on grants
management.[Footnote 7] The team was to draft and finalize common
solutions and a target architecture and present them for the fiscal
year 2006 budget review. The grants management initiative was headed by
representatives from the Department of Education and the National
Science Foundation.
The Grants Management Line of Business initiative has the specific
objective of developing a governmentwide solution to support end-to-end
grants management activities[Footnote 8] that promote citizen access,
customer service, and agency financial and technical stewardship. To
provide information, the team requested and analyzed information from
interested parties on possible solutions and approaches. The team also
surveyed grant-making agencies on their internal grant-making systems
and found that about 40 different internal agency systems were
operating, ranging from systems operating with almost no automation to
systems that are fully automated. In evaluating the information, the
team did not identify any end-to-end business or technical solution for
grants management that would be able to meet the needs of all 26
agencies without large investments in configuring and customization.
Further, it found that while the early stages of the grant life cycle
(i.e., connecting potential grantees with grant opportunities and the
application process) were already handled consistently across grantor
agencies, postaward activities are handled less consistently across
agencies and would require flexibility in business rules.
As a result, the team is proposing a consortia-based approach to
continue streamlining and consolidating the end-to-end grant management
process, but development of this system is not yet under way. It would
use Grants.gov as a "storefront" to support grantees and would expand
it beyond the current processes to include additional functions that
interface with the grantees. Rather than develop one system that all
agencies would use to manage grants internally, consortia of agencies
with similar systems, such as agencies that primarily fund research
grants, would be formed. Government, industry, or both will provide
information technology service centers for agencies throughout the
grant life cycle, an approach that is expected to reduce or eliminate
the costs of multiple agencies developing and maintaining grants
management systems.
Coordination Activities Established across Agencies, but Initiatives
Lack Continuing Input from Grantees:
As P.L. 106-107 and the common plan emphasized, coordination among the
agencies and with grantees in the planning and implementation of grant-
streamlining initiatives can increase the likelihood that the standard
processes and policies developed will meet the diverse needs of all the
stakeholder groups. While the agencies have established cross-agency
processes to facilitate coordination activities, progress has been
hampered by frequent changes in the groups that are implementing and
overseeing the implementation of P.L. 106-107. The various grant-
streamlining initiatives have had different levels of coordination
activities with grantees. The P.L. 106-107 work groups solicited input
from the grantee community during their early planning stages, but do
not have ongoing coordination activities. The Grants.gov initiative
solicits ongoing input from grantees in a variety of ways. It is not
yet clear if the Grants Management Line of Business initiative will
include coordination activities with grantee groups.
P.L. 106-107 requires OMB to direct and coordinate the federal agencies
in establishing an interagency process for achieving grant streamlining
and simplification. Furthermore, the act directs the federal agencies
to actively participate in this interagency grant-streamlining and
simplification process. Because the agencies are developing common
policies and processes to meet their diverse grants management needs, a
well-implemented interagency process can improve the likelihood of
success of the grant-streamlining initiatives. In examining
coordination issues, we have identified key practices that affect the
likelihood for success of cross-organizational initiatives.[Footnote 9]
These practices include establishing a collaborative organizational
structure, maintaining collaborative relationships, and facilitating
communication and outreach.[Footnote 10]
Agencies and OMB Coordinated Initiatives to Implement P.L. 106-107:
A collaborative organizational structure, characterized by strong
leadership and a comprehensive structure of participants' roles and
responsibilities, can facilitate coordination activities. As shown in
figure 2, OMB established several groups to lead and coordinate the
effort to implement P.L. 106-107. The act allows OMB to designate a
lead agency and establish interagency work groups to assist OMB in
implementing the requirements of the act. OMB designated HHS as the
lead agency for the implementation of P.L. 106-107. In the spring of
2000, OMB charged the Grants Management Committee of the Chief
Financial Officers Council with coordinating and overseeing the
governmentwide implementation of P.L. 106-107. The Grants Management
Committee included two representatives from each of the grant-making
agencies. The committee established four working subcommittees: the Pre-
Award Work Group, the Post-Award Work Group, the Audit Oversight Work
Group, and the Electronic Work Group. In addition, the committee
established the General Policy and Oversight Team, which was co-chaired
by OMB and HHS, and included the chairs of each of the work groups. The
team was intended to oversee the progress of the work groups and
examine issues that cut across the responsibilities of the individual
work groups.
Figure 2: P.L. 106-107 Implementation and Oversight Groups:
[See PDF for image]
[End of figure]
According to officials involved with P.L. 106-107 implementation, the
Grants Management Committee was ineffective, creating a stumbling block
for the initiative. In May 2004, the Grants Executive Board assumed the
responsibility for the coordination and oversight of P.L. 106-107
initiatives. In an update to its charter, the Grants Executive Board
(previously the Grants.gov Executive Board) expanded its oversight to
include both the Grants.gov initiative and the P.L. 106-107 initiative.
The Grants Executive Board has 13 members, one representative from each
of the 11 larger grant-making agencies and two seats that rotate among
the other 15 grant-making agencies. The Grants Executive Board meets
monthly and, with the assistance of the HHS-led grant streamlining
Program Management Office, oversees the work of the interagency grant
streamlining work groups. The board's oversight duties include
reviewing work group recommendations to determine if they should be
referred to OMB for governmentwide implementation, defining
accountability and reporting requirements to be met by the work groups,
and preparing the annual progress reports for Congress. The Grants
Executive Board also oversees the Grants.gov initiative, which is
charged with implementing the grant-streamlining policies in the
preaward phase of grants administration.
The P.L. 106-107 Planning and Oversight Committee is the coordinating
body for the grant-streamlining work groups and advises the Grants
Executive Board. Its membership consists of the chairs of each of the
work groups, a representative of the Grants.gov Program Management
Office, the P.L. 106-107 Program Manager, and an OMB representative.
Agency volunteers staff the work groups. Volunteer staffing is a
challenge for the work groups because the volunteers maintain their
regular agency responsibilities. According to work group chairs, the
volunteer staff members are dedicated, knowledgeable, and experienced
in grants policy and processes. HHS selects the chair of each work
group, but does not limit the size of the work groups so that all
interested agencies may participate. According to the P.L. 106-107
Program Manager, not all agencies are participating in the work groups.
Agencies that do not participate will not have input into the design of
governmentwide grant policies, increasing the risk that the new
policies will not meet the needs of all grant-making agencies.
Interagency efforts toward a second key element of coordination--
maintaining collaborative relationships--have been mixed. The major
elements of maintaining collaborative relationships include a shared
vision among participants and formal agreements with a clear purpose,
common performance outputs, and realistic performance measures. The
agencies helped to establish a cooperative, shared vision by jointly
developing the initial implementation plan, which establishes goals and
objectives to meet the requirements of P.L. 106-107. However, while the
plan outlines preliminary steps toward achieving its objectives, it
does not outline a comprehensive plan beyond those first steps.
Furthermore, the time targets in the plan are primarily short-term
targets related to preliminary steps. The annual cross-agency progress
report can be a tool to maintain the shared vision established in the
initial plan. According to work group leaders, the work group
volunteers from the agencies are committed to the goals of grant
streamlining and simplification. In addition to the cross-agency
progress report, each agency is required to submit an annual agency
progress report. This requirement has the potential to be an effective
management tool for monitoring the compliance and progress of
individual agencies. However, because the reports do not frame annual
achievements in the context of a comprehensive plan and use performance
measures to track progress, they are not an effective management tool.
Furthermore, not all the agencies have submitted their annual reports,
and OMB's position is that it is not their role to police agency
compliance with this requirement. Because the agencies have not
developed a comprehensive plan and are not reporting on their progress
using common performance measures, they are less likely to maintain the
shared vision that was established with the common plan.
Implementation of a third key element of coordination practices,
communication and outreach, has not always been effective. Leaders of
the initiatives hold regular meetings to share information with one
another. For example, the P. L. 106-107 Planning and Oversight
Committee meets monthly to facilitate coordination between the work
groups. However, the Audit Oversight Work Group Chair position has been
vacant for the past 18 months, so although the audit subgroups continue
their work, they have little contact with the other grant-streamlining
groups. Informal coordination between the various grant-streamlining
initiatives occurs because often the same people serve on multiple
committees. Outreach from the initiatives to the agencies has also not
always been effective. For example, the Post-Award Work Group sends
proposals or draft reports to the agencies, but they do not always
reach the necessary people because some agencies are very large and
have complex organizational structures.
OMB and Grant Executive Board Working on Resolving Governance Issues,
but Overlapping Responsibilities and Lack of Clarity Are Hampering
Progress:
The future relationship between the Grants Management Line of Business,
P.L. 106-107 work groups, and the Grants.gov Program Management Office
is unclear. This management situation appears to have hampered
progress. OMB plans to form a Grants Governance Committee to oversee
three program management offices working on grant streamlining and
simplification. The Grants Governance Committee will oversee the
Grants.gov initiative, the P.L. 106-107 initiative, and the Grants
Management Line of Business initiative. However, there will be a
separate program management office for each initiative, and there
appears to be overlap between the responsibilities of the three
initiatives. Representatives of two of the work groups reported that
there has been little communication between the Line of Business
initiative and the P.L. 106-107 work groups. Work group members said
they are reluctant to go forward with new projects because they do not
know if their priorities will be consistent with those of the Line of
Business initiative. For example, the Line of Business initiative
appears to be planning to rely on Grants.gov for its "find" and "apply"
functions, but it is not yet clear if Grants.gov will be the portal
used by the grantee in the later stages of the grant life cycle. In
anticipation of the start of the Line of Business initiative, OMB has
directed Grants.gov to focus its efforts on the functionality of the
"find" and "apply" functions. The Grants.gov Program Manager reported
that, accordingly, the Grants.gov office is holding off on efforts to
incorporate processes related to the later stages of the grants life
cycle. Because grant management and reporting rely on information
gathered in the "apply" stage, there should be some integration between
these functions.
Efforts to Solicit and Use Input from Grantees Have Been Mixed:
P.L. 106-107 obligates OMB and the agencies to consult with
representatives of nonfederal entities during the development and
implementation of grant-streamlining plans, policies, and systems. In
addition to its general directive to consult and coordinate with
grantees, the act requires the agencies to publish the implementation
plan in the Federal Register for public comment; hold public forums on
the plan; and cooperate with grantees to define goals, objectives, and
performance measures related to the objectives of the act. In prior
work, we have found that collaborative activities include communication
strategies that facilitate two-way communication among the project
team, partners, and other stakeholders, and that outreach programs keep
those affected by the initiative informed of new developments and
provide structured means for feedback and questions.[Footnote 11] By
failing to involve important stakeholders, the initiatives increase the
risk that they will not fully achieve the objectives defined in P.L.
106-107 and the common plan.
In its early work, the groups established by OMB and its lead grant
streamlining agency, HHS, undertook efforts to coordinate and consult
with the grantee communities. The Grants Management Committee created a
Web site that provided information about the work groups' activities in
implementing the act and invited public input. Individual agencies also
sought input through invitations to comment posted on their Web sites.
In the fall of 2000, the Grants Management Committee held a series of
five interagency public consultation meetings with (1) states, (2)
local governments, (3) Native American tribes and tribal organizations,
(4) universities and nonprofit organizations that conduct research, and
(5) other nonprofit organizations. Throughout this process, the teams
built a database of the public comments and used them to develop the
common plan. The plan considers those comments and, in large part, is
based on them. In January 2001, the agencies jointly published the
interim/draft plan in the Federal Register and requested public
comment.
The common plan outlines two processes for maintaining ongoing
communication with grantee groups. First, it envisions the
establishment of an ombudsman, a third party operating apart from the
individual grant-making agencies and OMB that could provide grantees
with an avenue for making their concerns known if agency requirements
appear to exceed the standards adopted. Second, the agencies planned to
establish performance measures[Footnote 12] related to the purposes and
requirements of the act and a process for assessing the extent to which
specified goals and objectives have been achieved. In developing the
performance measures, the agencies were to consider input from
applicants, recipients, and other stakeholders. The agencies planned to
develop multiple measures to assess performance, including progress as
perceived by the public and federal staff as well as objective process
and outcome measures. The agencies expected to use these performance
measures to evaluate their performance in meeting the plan's goals and
objectives and report annually on their progress as required by P.L.
106-107.
As the streamlining reforms have been developed and implemented, the
agencies and work groups have not fulfilled the envisioned processes
for soliciting ongoing input from grantees. By failing to involve
important stakeholders, the initiatives increase the risk that they
will not fully achieve the objectives defined in P.L. 106-107 and the
common plan. The plan envisioned the establishment of an ombudsman that
could provide applicants/recipients an avenue for making their concerns
known if agency requirements appear to deviate from the common systems
or standard processes. The common plan set a target date of March 31,
2002, for finalizing the job description of the ombudsman. The agencies
have not established the ombudsman position and do not currently plan
to establish one due to changing priorities. In addition, the agencies
have neither set specific annual goals and objectives nor used concrete
performance measures in the annual progress reports, as was required by
P.L. 106-107 and envisioned in the common plan. However, the P.L. 106-
107 Program Manager is currently conducting an analysis of progress to
date in meeting the requirements of P.L. 106-107 and an analysis of how
the reforms have addressed the concerns expressed in the public
comments.
Furthermore, only one of the four active cross-agency work groups
consistently uses the public comments during the development of its
initiatives. The Pre-Award Work Group, which addresses the streamlining
of announcements, applications, and award processes, has continued to
use the public comments to inform its work. The other work groups
informally vet their proposals with selected grantee groups. Grantees
are not formally involved in the development of grant-streamlining
proposals. The grant-streamlining teams solicit public comment only
once a proposal is posted in the Federal Register. Representatives from
a group of research grantees told us that this one-way communication is
not sufficient to produce reforms that simplify the grant process for
recipients. For example, they commented that the reform of the cost
principles focused only on reducing the discrepancies in definitions
used by the three different cost principles circulars and actually
increased the administrative burden for the research community. The
work groups have expressed concern that in seeking public input, they
must take care not to violate the Federal Advisory Committee Act of
1972 (FACA), which establishes requirements pertaining to the creation,
operation, duration, and review of covered advisory committees.
However, because nonfederal participants do not act as full members,
the work groups should not be subject to the FACA requirements.
[Footnote 13] Furthermore, FACA would not limit the work groups'
ability to widely publicize their initiatives and invite public comment
on an ongoing basis.
The Grants.gov initiative has been more active in soliciting grantee
input, but it is unclear if the Line of Business initiative will
include activities to coordinate with grantees. In contrast to the P.L.
106-107 initiative, the Grants.gov initiative has institutionalized
processes to inform the grantee community about its plans and
activities and to gather ongoing input from the grantee community.
Throughout development and implementation of Grants.gov, users'
comments from pilots and actual systems have been used to identify and
address problems. Grants.gov has also conducted three user satisfaction
surveys and maintains a Web portal for user comments. The Web site of
the grant-streamlining teams was recently integrated into the
Grants.gov Web site. The site invites public comment on both the
Grants.gov system and broader grant-streamlining issues and
initiatives. In addition, the Grants.gov Program Management Office
conducted training and outreach to the various applicant constituencies
and to agency staff to increase awareness of the Grants.gov initiative.
Outreach efforts included monthly stakeholder meetings, train-the-
trainer workshops, and grantor workshops. A help desk was established
to address federal staff and applicants' questions and provide
assistance. At this time, it is unclear if the Grants Management Line
of Business initiative will include a process for consultation and
coordination with grantee groups.
Conclusions:
Several initiatives to simplify and streamline the administration of
grants have been proposed in response to P.L. 106-107. Some of these
have been implemented and likely will help grantees to identify and
apply for grants and meet the needs of federal grant-making agencies
when they receive grants. The Grants.gov common portal is clearly used
by many to identify grants and undoubtedly has simplified that process
for grantees. As more agencies allow for electronic application through
Grants.gov and more grantees begin to use the system, it should also
simplify grant management. However, other initiatives that have been
proposed have not yet been completed. Some have languished in the
approval process. Others have not yet been adequately developed to even
reach the approval stage. The lack of clear goals and timelines for the
cross-agency work groups to complete tasks and for agencies to
implement systems undoubtedly has contributed to the lack of progress
in implementing these proposals. Further, agencies need to be held
accountable internally for implementing these programs and should have
performance measures and clear deadlines on which they report. To date,
agencies have not even been held accountable for submitting annual
reports required by P.L. 106-107, which may indicate to agencies that
moving forward quickly on grant administration streamlining is not a
high priority.
In addition, the lack of continuity toward meeting P.L. 106-107's
requirement to develop a common reporting system (including electronic
processes) for similar programs administered by different agencies may
potentially prevent agencies from reaching the act's goals before it
sunsets in November 2007. As overarching committees have evolved and
management of the cross-agency programs have been moved around among
various parties, progress has been slowed. Clearer governance is needed
to ensure that each group sunderstands its roles and coordinates with
the others to prevent overlap and collaborate on common initiatives.
The various initiatives that are implementing P.L. 106-107 have a mixed
record of coordinating with grantees. Grants.gov publicizes its plans
and meeting minutes on its Web site and solicits ongoing grantee input
through its Web site, regular satisfaction surveys, and outreach
meetings with grantees. In planning for the implementation of the act,
the cross-agency work groups also solicited and used grantee input. In
addition, they incorporated several means for soliciting ongoing
grantee input in the plan. However, they did not implement the portions
of the initial plan that would have provided for ongoing coordination
with grantees. Unlike Grants.gov, the work groups have neither made
information about their work public nor solicited ongoing grantee
input, and approaches outlined in the common plan, such as establishing
an ombudsman position, have not been implemented. Without ongoing
grantee input, the reforms are less likely to meet the needs of the
grantees and achieve the purposes of the act.
Recommendations for Executive Action:
In order to augment the progress toward meeting the goals of P.L. 106-
107 for streamlining grant administration, we recommend that the
Director, OMB, take the following five actions:
* ensure that individual agency and cross-agency initiatives have clear
goals for completion of their initiatives;
* ensure that agency annual progress reports to Congress and OMB on
implementation of P.L. 106-107 are prepared and contain information on
their progress toward goals;
* ensure that efforts to develop common grant-reporting systems are
undertaken on a schedule that will result in significant progress by
the time P.L. 106-107 sunsets in November 2007;
* ensure that OMB's strategy for addressing P.L. 106-107 integrates the
three individual initiatives: HHS's overarching P.L. 106-107 efforts,
the Grants.gov program, and the Grants Management Line of Business
initiative; and:
* solicit grantee input and provide for coordination with grantees on
an ongoing basis.
Agency Comments and Our Evaluation:
We provided a draft of this report to OMB for comment. OMB's formal
comments are reprinted in appendix III. In addition to written
comments, OMB provided us with technical comments verbally, which we
incorporated as appropriate.
In its formal comments, OMB stated that it agreed with many of the
report's recommendations and provided comments on the status of grant
reform efforts. OMB stated it will continue to work aggressively with
agencies to meet their annual reporting responsibilities and is
committed to achieving E-Gov solutions and deploying technical
solutions for streamlining policies and practices. Further, OMB
commented that it will continue to facilitate the integration of the
three grants initiatives related to P.L. 106-107 requirements and will
continue to seek grantee input on an ongoing basis.
We believe that these steps constitute progress toward ensuring that
the goals of P.L. 106-107 are attained, although OMB needs to
aggressively push forward. For example, while it has established a new
grants committee, it needs to ensure that progress does not slow while
this transition occurs. Although the Grants Management Line of Business
initiative is under way, OMB needs to ensure that efforts to address
P.L. 106-107 requirements, such as the development of common electronic
systems to manage and report on the use of funding from similar federal
grant programs administered by different agencies, move forward.
Similarly, while public input was sought heavily during the development
of the common plan and is sought once proposals are developed, the
grantee community's views need to be solicited throughout these
processes and as new initiatives are selected.
We are sending copies of this report to the Director of OMB. In
addition, the report will be available at no charge on the GAO Web site
at [Hyperlink, http://www.gao.gov]. Should you have any questions about
this report, please contact me at (202) 512-6806 or Thomas James,
Assistant Director, at (202) 512-2996. We can also be reached by e-mail
at [Hyperlink, posnerp@gao.gov] and [Hyperlink, jamest@gao.gov],
respectively. Additional key contributors to this report are listed in
appendix IV.
Signed by:
Paul L. Posner:
Managing Director, Federal Budget Analysis and Intergovernmental
Relations Issues, Strategic Issues:
[End of section]
Appendixes:
Appendix I: P.L. 106-107 Annual Reports Submitted to Congress as of
March 1, 2005:
P.L. 106-107 requires each agency to report annually on its progress
implementing the plan, although not all agencies have regularly
submitted these reports. The annual agency progress report summarizes
agency efforts in meeting the goals and objectives of the common plan.
The annual governmentwide progress reports describe the collaborative
efforts of 26 federal agencies to streamline and simplify the award and
administration of federal grants. (See table 3.)
Table 3: P.L. 106-107 Annual Reports Submitted to Congress as of March
1, 2005:
Governmentwide;
2002;
2003;
2004.
Agency for International Development; 2003.
Corporation for National and Community Service; 2003;
2004.
Department of Agriculture;
2004.
Department of Commerce;
2002;
2003;
2004.
Department of Defense;
2002;
2003;
2004.
Department of Education;
2003;
2004.
Department of Energy;
2003;
2004.
Department of Health and Human Services; 2002;
2003;
2004.
Department of Homeland Security/Federal Emergency Management Agency;
2003;
2004.
Department of Housing and Urban Development; 2003;
2004.
Department of the Interior;
2004.
Department of Justice;
2002;
2003;
2004.
Department of Labor;
2002;
2003;
2004.
Department of State;
2002;
2003;
2004.
Department of Transportation;
None.
Department of the Treasury;
2003;
2004.
Department of Veterans Affairs;
2003.
Environmental Protection Agency;
2002;
2003;
2004.
Institute of Museum and Library Services; 2003;
2004.
National Aeronautics and Space Administration; 2003;
2004.
National Archives and Records Administration; 2003;
2004.
National Endowment for the Arts;
2002;
2003;
2004.
National Endowment for the Humanities; 2002;
2003;
2004.
National Science Foundation;
2003;
2004.
Small Business Administration;
None.
Social Security Administration;
2003;
2004.
Source: HHS.
[End of table]
[End of section]
Appendix II: Detailed Information on Grants.gov:
As cross-agency teams identified the need for streamlining, agency
representatives and the Office of Management and Budget (OMB)
recognized that potential grantees needed a simpler and more consistent
way to identify and apply for federal grant opportunities. The process
in place for identifying grant opportunities resulted in applicants
searching for applications from many different agencies and then having
to apply to the various agencies using different application forms and
processes. Public comments from the grantee community identified the
lack of a central source for obtaining information about all federal
agencies' current funding opportunities and the variation in the way
agencies' grant announcements were organized. P.L. 106-107 required
that OMB coordinate grant-making agencies in establishing an
interagency process to streamline and simplify these procedures for
nonfederal entities. Further, it required that the agencies allow
applicants to electronically apply and report on the use of funds from
grant programs they administer. The E-grant initiative, along with
other E-government approaches, was undertaken to meet these needs. It
was implemented initially by the E-Grants Program Management Office
based in the Department of Health and Human Services, which was the
lead agency for P.L. 106-107 implementation. More recently, it has been
referred to as Grants.gov, the Internet portal through which it is
accessed.
The first service that Grants.gov implemented was the "find"
capability, which established a single Web site to provide information
on federal grant-funding opportunities. This enabled applicants to
search these opportunities by several components, such as the type of
activity funded (e.g., the arts and humanities, education, and the
environment) and the agency providing funds. Further, it provided the
capability of notifying potential fund recipients by e-mail of new
opportunities that met parameters they identified. In addition,
descriptions of funding opportunities were organized uniformly to
simplify finding key information. Agencies began posting summaries in
February 2003. A key aspect of its full implementation was OMB's
requirement that by November 7, 2003, all federal agencies were to
electronically post information on funding opportunities that award
discretionary grants and cooperative agreements at the Grant.gov Web
site, using a standard set of data elements. Grants.gov's program
management office reports that since October 2003, all 26 grant-making
agencies have listed grant opportunities in the "find" activity of
Grants.gov. The public's use of the portal has grown significantly;
according to the Program Management Office, the "find" activity on
Grants.gov received about 2.2 million page requests in November 2004
and applicant e-mail notifications have averaged 600,000 to 700,000
weekly.
More recently, Grants.gov has provided the capability to apply for
grants electronically through the portal. The "apply" activity allows
an applicant to download an application package from Grants.gov and
complete the application off-line. After an applicant completes the
required forms, they can be submitted electronically to Grants.gov,
which transmits the application to the funding agency. Grant-making
agencies must take several steps to provide the capability to apply
electronically. They work with Grants.gov Program Management Office
staff to identify the forms needed and make them accessible. Previous
forms that grant-making agencies have used for similar application
packages are readily available as are forms that other agencies have
used that might be appropriate, thus simplifying the process of adding
new applications. The agencies identify how long they would like the
application packages to be retained on the site after they close; after
that, they are archived on the site. While some agencies have enabled
applicants to apply electronically directly on Grants.gov, some
announcements link to a grant announcement in the Federal Register or
link to more detail on the "find" site, which the applicant completes
in hard copy. To apply for grants electronically, the applicant must
download specific free software--Pure Edge Viewer. After an application
is submitted, the Grants.gov system checks the application to ensure
all the required forms are included and sends the applicant an e-mail
saying that it has been accepted, or rejected if a problem has been
identified. If accepted, the application is then forwarded from
Grants.gov to the grantor agency; when that agency downloads the data,
it informs the Grants.gov system and the applicant is informed by
Grants.gov that data have been downloaded to the agency. In some cases,
agencies can download data directly to their own grant management
systems, thus eliminating the need for staff time to input data.
Usage of the electronic "apply" component has been slower to grow than
the use of the "find" component for a number of reasons. As shown in
table 4, as of April 6, 2005, 20 of the 26 key federal grant-making
agencies have posted "apply" packages, 723 electronic application
packages were available, and 2,621 electronic applications have been
received. For agencies, forms must be uploaded to the system. Further,
some are struggling with setting up their systems to handle the data
from Grants.gov. For grantees, some necessary registration steps
require lead time--an estimated 6 days that must be allowed for the
entire registration process the first time. This verifies that the
grantee point of contact is the appropriate person to submit an
application. Grant.gov's surveys to determine users' satisfaction with
the system have also identified dissatisfaction on other aspects, such
as the adequacy of the status page and the ease of submitting the
applications.
Table 4: Status of Agency Participation in Grants.gov "Apply" Component
(as of April 6, 2005):
Agency: Agency for International Development; Number of apply packages
posted: 1; Number of electronic applications received: 3.
Agency: Corporation for National and Community Service; Number of apply
packages posted: 0; Number of electronic applications received: 0.
Agency: Department of Defense;
Number of apply packages posted: 0; Number of electronic applications
received: 0.
Agency: Department of Agriculture; Number of apply packages posted: 38;
Number of electronic applications received: 188.
Agency: Department of Commerce;
Number of apply packages posted: 178; Number of electronic applications
received: 532.
Agency: Department of Education;
Number of apply packages posted: 26; Number of electronic applications
received: 196.
Agency: Department of Energy;
Number of apply packages posted: 28; Number of electronic applications
received: 120.
Agency: Department of Health and Human Services; Number of apply
packages posted: 325; Number of electronic applications received: 860.
Agency: Department of Homeland Security; Number of apply packages
posted: 1; Number of electronic applications received: 2.
Agency: Department of Housing and Urban Development; Number of apply
packages posted: 44; Number of electronic applications received: 41.
Agency: Department of Justice;
Number of apply packages posted: 5; Number of electronic applications
received: 84.
Agency: Department of Labor;
Number of apply packages posted: 6; Number of electronic applications
received: 54.
Agency: Department of the Interior; Number of apply packages posted:
11; Number of electronic applications received: 175.
Agency: Department of State;
Number of apply packages posted: 4; Number of electronic applications
received: 2.
Agency: Department of the Treasury; Number of apply packages posted: 2;
Number of electronic applications received: 7.
Agency: Department of Transportation; Number of apply packages posted:
17; Number of electronic applications received: 4.
Agency: Department of Veterans Affairs; Number of apply packages
posted: 1; Number of electronic applications received: 1.
Agency: Environmental Protection Agency; Number of apply packages
posted: 10; Number of electronic applications received: 58.
Agency: Institute of Museum and Library Services; Number of apply
packages posted: 0; Number of electronic applications received: 0.
Agency: National Aeronautics and Space Administration; Number of apply
packages posted: 0; Number of electronic applications received: 0.
Agency: National Archives and Records Administration; Number of apply
packages posted: 0; Number of electronic applications received: 0.
Agency: National Endowment for the Arts; Number of apply packages
posted: 5; Number of electronic applications received: 23.
Agency: National Endowment for the Humanities; Number of apply packages
posted: 13; Number of electronic applications received: 38.
Agency: National Science Foundation; Number of apply packages posted:
0; Number of electronic applications received: 0.
Agency: Small Business Administration; Number of apply packages posted:
2; Number of electronic applications received: 7.
Agency: Social Security Administration; Number of apply packages
posted: 6; Number of electronic applications received: 226.
Total;
Number of apply packages posted: 723 packages (20 agencies); Number of
electronic applications received: 2,621.
Source: Grants.gov Program Management Office.
[End of table]
Grants.gov staff members have reached out to both agencies and the
grantee community, sometimes through the use of a contractor, to
solicit input and to increase its usage. They have provided training
and workshops to grant-making agencies and have hosted monthly
stakeholder meetings to update users on changes. The Grants.gov Program
Manager meets monthly with the Grants.gov Executive Board, comprising
senior executives of partner agencies, to update them on activities and
get guidance on strategic issues. As outreach to the grantee community,
staff members have given presentations and provide resources to
agencies to inform their grantee communities. Also, a "contact center"
is available for grant applicants to assist with the electronic
applications.
With the growth of its services, the operations of the Grants.gov
office Program Management Office have evolved. As of December 2004, the
Program Management Office has several full-time employees, including a
Program Manager and a Deputy Program Manager, and additional detailees
from grantor agencies. It has not received direct appropriations but
was funded during the period from 2002 to 2004 by contributions from 13
grant-making agencies, the Chief Financial Officers Council, and the
General Services Administration (for maintenance of the Grants.gov
"find" mechanism). Funding for those 3 years totaled about $29.4
million. Beginning with fiscal year 2005, Grants.gov has moved to a fee-
for-service model. Funding will be from 26 grant-making agencies, with
payments based on an agency's total grant dollars awarded. Based on
natural break points in data on funds that the agencies award, the
grant-making agencies were divided into three categories. For 2005 and
2006, the 6 large agencies will be assessed $754,467, the 10 medium
agencies will be assessed $452,680, and the 10 small agencies will be
assessed $226,340, for a total of about $11,300,000 each year.
[End of section]
Appendix III: Comments from the Office of Management and Budget:
EXECUTIVE OFFICE OF THE PRESIDENT: OFFICE OF MANAGEMENT AND BUDGET:
WASHINGTON, D.C. 20503:
DEPUTY DIRECTOR FOR MANAGEMENT:
MAR 30 2005:
Mr. Paul Posner:
Managing Director:
Federal Budget and Intergovernmental Relations: Government
Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Posner:
I am writing with regard to the Government Accountability Office (GAO)
draft report entitled, "Grants Management: Additional Actions Needed to
Streamline and Simplify Processes" (GAO-05-335). Thank you for the
opportunity to provide written comments on this draft report, as well
as the many technical edits we suggested during a teleconference call
on March 24, 2005.
We appreciate GAO's extensive review of the interagency activities-both
completed and underway-to implement the requirements of the Federal
Financial Assistance Management Improvement Act (P.L. 106-107). We are
pleased the draft report recognizes the progress made in many areas,
such as the government-wide standard announcement format and the
electronic option available to the public for finding and applying for
Federal grants. We agree with many of the report's recommendations, and
offer the following comments:
* The Office of Management and Budget (OMB) continues to actively work
with the groups involved with streamlining grants administration to
better ensure there are clear goals for individual agencies, as well as
for the three grants-related initiatives. OMB uses a number of
mechanisms, including budget and other policy guidance, to establish
clear performance goals for the initiatives and agencies'
implementation of them. OMB monitors progress towards these goals with
the President's Management Agenda Scorecard.
* OMB will continue to aggressively work with the agencies to meet
their annual reporting responsibilities under Section 5(b) of P.L. 106-
107. Each year, OMB assists the interagency groups to develop cross-
agency accomplishments, as well as a template that agencies may use to
report on agency-specific accomplishments. OMB reminds the agencies of
the deadline (established as August 31 each year) and promptly reviews
each agency's draft report prior to submission to Congress.
OMB is committed to achieving citizen-centered E-Gov solutions and
better ensuring proper deployment of technical solutions to support
streamlining policies and practices. The Grants Management Line of
Business initiative is underway to develop a common solution for grant
reporting, and OMB continues to take the necessary steps to better
ensure efforts remain on track.
* OMB will continue to facilitate the integration of the three grants-
related initiatives to collectively implement the requirements of P.L.
106-107. In addition, a new grants committee has been established under
the Chief Financial Officers Council to ensure consistent policies
among the initiatives.
* OMB will continue to seek grantee input on an on-going basis for the
grants streamlining work. For example, all new proposed policies, as
well as related government-wide datasets, are published in the Federal
Register for public comment. We have made considerable outreach efforts
with various grantee groups to make in-progress information available
to the public. OMB has also accompanied the working groups at several
informal meetings conducted for the purpose of soliciting grantee
input. We will work with the cross-agency work groups to establish
additional performance measures beyond those already established for
the electronic deployment aspects of grants streamlining.
OMB will continue to work with. Federal agencies and grantees in their
efforts to streamline the grants administration policies and processes.
Thank you for the opportunity to review and comment on your draft
report on this important issue.
Sincerely,
Signed by:
Clay Johnson III:
[End of section]
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Paul L. Posner, (202) 512-6806;
Thomas James, (202) 512-2996:
Acknowledgments:
In addition to the above contacts, Jack Burriesci, Martin De Alteriis,
Patricia Dalton, Susan Etzel, Ronald La Due Lake, Hannah Laufe, Donna
Miller, Melissa Mink, and Carol Patey also made key contributions.
(450316):
FOOTNOTES
[1] As defined in the act, "federal financial assistance" includes
grants, cooperative agreements, loans, loan guarantees, insurance,
interest subsidies, and other forms of assistance. Pub. L. No. 106-107,
§4. The current streamlining efforts have focused on grants and
cooperative agreements. In our evaluation we have also limited our
assessment to grants and cooperative agreements and, for simplicity,
refer to them as grants.
[2] GAO, Federal Assistance: Grant System Continues to Be Highly
Fragmented, GAO-03-718T (Washington, D.C.: Apr. 29, 2003).
[3] Pub. L. No. 95-224, §9.
[4] Single audits, required by the Single Audit Act of 1984 (Pub. L.
No. 98-502) as amended by the Single Audit Act Amendments of 1996 (Pub.
L. No. 104-156), streamline and improve the effectiveness of audits of
federal awards and reduce the audit burden on states, local
governments, and nonprofit entities receiving federal awards by
replacing multiple grant audits with one audit of a recipient as a
whole.
[5] Formerly, Grants.gov was referred to as E-Grants. It is one of the
"E-gov" initiatives and supports the President's Management Agenda goal
of expanding electronic government.
[6] Although located in the Code of Federal Regulations, the OMB
circulars and policy documents will still be guidance to federal
agencies, not regulations.
[7] The other groups address financial management, human resources
management, federal health architecture, and case management.
[8] End-to-end activities would address steps in the entire grant life
cycle from informing potential grantees of a funding opportunity to
closing out and auditing grants.
[9] GAO, Electronic Government: Potential Exists for Enhancing
Collaboration on Four Initiatives, GAO-04-6 (Washington, D.C.: Oct. 10,
2003).
[10] Two other key coordination practices identified in the report,
contributing resources equitably and adopting a common set of
standards, are more relevant for formal collaboration agreements and
less relevant to the varying levels of coordination needed in the grant-
streamlining work.
[11] GAO-04-6.
[12] The agencies planned to use a "balanced scorecard" approach to
measure success in implementing the act.
[13] FACA does not apply to committees or work groups that are composed
wholly of full-time or permanent part-time officials or employees of
the federal government. See Federal Advisory Committee Act, Pub. L. No.
92-463, §3(2) (codified as amended at 5 U.S.C. App. 2). However, if
nonfederal participants regularly attend and fully participate in the
work group meetings as members, the issue may arise as to whether the
nonfederal participants could be construed as full members of the work
group. See in Association of American Physicians and Surgeons, Inc. v.
Clinton, 997 F.2d 898, 302 (D.C. Cir. 1993), for a discussion of when a
working group composed of federal employees may constitute a FACA
advisory committee.
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