Recovery Act
Consistent Policies Needed to Ensure Equal Consideration of Grant Applications Gao ID: GAO-09-590R April 29, 2009Grants.gov is the central grant identification and application portal for the more than 1,000 federal grants programs offered by 26 federal grant-making agencies and organizations. The Office of Management and Budget (OMB) created Grants.gov, to streamline administrative grant application requirements and reduce the burden on applicants, among other things. On March 6, 2009, Grants.gov began posting specific grant opportunities provided in the American Recovery and Reinvestment Act of 2009 (Recovery Act). As a result, submissions have escalated to an unprecedented level. During the first week in April, Grants.gov processed almost 11,500 applications, or about three times the weekly average number of submissions in fiscal year 2008. One day that week Grants.gov accepted 3,555 applications--the largest 1-day total to date. On March 9, 2009, OMB notified federal agencies that over the past several months Grants.gov had experienced increased activity beyond what was originally anticipated by the system, which had at times resulted in noticeably degraded performance. OMB further noted that given the expected increase in application volume because of the Recovery Act, the system was at significant risk of failure, thus potentially hampering Recovery Act implementation. To reduce demand on the Grants.gov system and to assist applicants in the short term, OMB instructed federal grant-making agencies to identify alternate methods for accepting grant applications during the peak period of the Recovery Act, with a focus on minimizing any disruption to the grants application processes. OMB and agencies estimate that this peak period will last from April through about August 2009. Alternate methods for applying include agency-specific electronic systems (i.e., non-Grants.gov electronic systems run by a grantor agency), e-mail, fax, and mail. On April 8, 2009, OMB issued another memorandum stating that the existing Grants.gov infrastructure will not be able to handle the influx of applications expected as key Recovery Act deadlines approach. OMB said that the Department of Health and Human Services (HHS), the federal agency that operates and maintains Grants.gov, and the General Services Administration (GSA), which serves as the facilitator of governmentwide solutions, are working together to initiate urgent improvements to the system, and that each grant-making agency is being asked to cover a proportionate share of these improvements. Based on our ongoing work on Grants.gov, Congress asked us to issue two reports: one immediately on our initial observations on improving grant submission policies that could help minimize disruptions to the grants application process during the Recovery Act's peak filing period, and the second in June 2009 addressing in more detail systemic issues with Grants.gov and implications of varying agency policies for processing application submissions.
OMB created Grants.gov (initially known as e-Grants) in response to the Federal Financial Assistance Management Improvement Act of 1999, commonly referred to by the grants community and OMB as Public Law 106-107. Public Law 106-107 sought to improve coordination among federal grantor agencies and their nonfederal partners. It required federal grant-making agencies to streamline and simplify the application, administrative, and reporting procedures for their programs. The act also required OMB to direct, coordinate, and assist agencies in developing and implementing a common application and reporting system that included electronic processes with which a nonfederal entity can apply for multiple grant programs that serve similar purposes but are administered by different federal agencies. OMB has acknowledged the importance of Grants.gov in successfully implementing the Recovery Act. By working with agencies to initiate immediate improvements to Grants.gov and requiring agencies to identify alternate methods for accepting grant applications, OMB has played a critical role in minimizing disruptions to the grants application process. OMB and the Grants.gov staff have worked quickly to mitigate an impending system failure and protect the flow of Recovery Act grant funds to struggling communities around the country. However, applicants lack a centralized source of information on how and when to use these alternatives, rendering them less effective than they otherwise might be in reducing the strain on a system already suffering from seriously degraded performance. Moreover, inconsistent agency policies for grant closing times, what constitutes a timely application, when and whether applicants are notified of the status of their applications, and the basis on which applicants can appeal a late application create confusion and uncertainty for applicants and could result in an application being treated differently depending on how it is submitted--results that are contrary to OMB's stated purposes for recent efforts to improve Grants.gov and to the streamlining goals of Public Law 106-107 in general.
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-09-590R, Recovery Act: Consistent Policies Needed to Ensure Equal Consideration of Grant Applications
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United States Government Accountability Office:
Washington, DC 20548:
April 29, 2009:
The Honorable George V. Voinovich:
Acting Ranking Member:
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Edolphus Towns:
Chairman:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Stephen F. Lynch:
Chairman:
Subcommittee on Federal Workforce, Postal Service, and the District of
Columbia:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Danny Davis:
House of Representatives:
Subject: Recovery Act: Consistent Policies Needed to Ensure Equal
Consideration of Grant Applications:
Grants.gov is the central grant identification and application portal
for the more than 1,000 federal grants programs offered by 26 federal
grant-making agencies and organizations.[Footnote 1] The Office of
Management and Budget (OMB) created Grants.gov, to streamline
administrative grant application requirements and reduce the burden on
applicants, among other things. On March 6, 2009, Grants.gov began
posting specific grant opportunities provided in the American
Reinvestment and Recovery Act of 2009 (Recovery Act).[Footnote 2] As a
result, submissions have escalated to an unprecedented level. During
the first week in April, Grants.gov processed almost 11,500
applications, or about three times the weekly average number of
submissions in fiscal year 2008. One day that week Grants.gov accepted
3,555 applications--the largest 1-day total to date.
On March 9, 2009, OMB notified federal agencies that over the past
several months Grants.gov had experienced increased activity beyond
what was originally anticipated by the system, which had at times
resulted in noticeably degraded performance. OMB further noted that
given the expected increase in application volume because of the
Recovery Act, the system was at significant risk of failure, thus
potentially hampering Recovery Act implementation.[Footnote 3] To
reduce demand on the Grants.gov system and to assist applicants in the
short term, OMB instructed federal grant-making agencies to identify
alternate methods for accepting grant applications during the peak
period of the Recovery Act, with a focus on minimizing any disruption
to the grants application processes. OMB and agencies estimate that
this peak period will last from April through about August 2009.
Alternate methods for applying include agency-specific electronic
systems (i.e., non-Grants.gov electronic systems run by a grantor
agency), e-mail, fax, and mail.[Footnote 4]
On April 8, 2009, OMB issued another memorandum stating that the
existing Grants.gov infrastructure will not be able to handle the
influx of applications expected as key Recovery Act deadlines approach.
[Footnote 5] OMB said that the Department of Health and Human Services
(HHS), the federal agency that operates and maintains Grants.gov, and
the General Services Administration (GSA), which serves as the
facilitator of governmentwide solutions, are working together to
initiate urgent improvements to the system, and that each grant-making
agency is being asked to cover a proportionate share of these
improvements.[Footnote 6]
Based on our ongoing work for you on Grants.gov, you asked us to issue
two reports: one immediately on our initial observations on improving
grant submission policies that could help minimize disruptions to the
grants application process during the Recovery Act's peak filing
period, and the second in June 2009 addressing in more detail systemic
issues with Grants.gov and implications of varying agency policies for
processing application submissions.
Our initial observations are based on our review of policies and
procedures related to grant applications submissions from the
Grants.gov Program Management Office (PMO) and federal grant-making
agencies. We also examined documentation from HHS, the Grants Executive
Board (GEB), and OMB.[Footnote 7] As part of the audit work for our
June 2009 report, we also conducted a Web-based survey in December 2008
and January 2009 of 80 agency officials representing the 26 federal
grant-making agencies and organizations within those agencies that have
distinctive grant application submission and processing policies.
Throughout this report, we call these organizations grantor agencies.
We received responses from 74 grantor agencies for a response rate of
92.5 percent.[Footnote 8] Our survey contained questions on agency
policies and practices with respect to competitive grant application
submissions, and questions on agency experiences assisting applicants
that have had problems while using Grants.gov. To construct the
questionnaire, we interviewed agency grant officials and pretested it
with five grantor agencies to ensure that the questions were clear and
unbiased and that the questionnaire could be completed in a reasonable
amount of time. In addition, to encourage them to respond, we sent
three follow-up e-mails. For those that did not respond, we made phone
calls to encourage respondents to complete the questionnaire. We also
conducted interviews with officials from the Grants.gov PMO, HHS, GEB,
and OMB. To obtain more information from the grantee perspective on
using Grants.gov and other application submission methods, we also
reviewed documents from associations representing grant applicants and
conducted interviews with officials from these organizations.
We conducted the performance audit for our ongoing work on Grants.gov
from May 2008 to April 2009 in accordance with generally accepted
government auditing standards. Those standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide
a reasonable basis for our findings and conclusions based on our audit
objectives. We believe the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
Background:
OMB created Grants.gov (initially known as e-Grants) in response to the
Federal Financial Assistance Management Improvement Act of 1999,
commonly referred to by the grants community and OMB as Public Law 106-
107.[Footnote 9] Public Law 106-107 sought to improve coordination
among federal grantor agencies and their nonfederal partners. It
required federal grant-making agencies to streamline and simplify the
application, administrative, and reporting procedures for their
programs. The act also required OMB to direct, coordinate, and assist
agencies in developing and implementing a common application and
reporting system that included electronic processes with which a
nonfederal entity can apply for multiple grant programs that serve
similar purposes but are administered by different federal agencies.
[Footnote 10]
In order to log in and submit an application, first-time applicants
must register with Grants.gov--a complex process meant to ensure that
only authorized applicants can apply on behalf of an organization.
[Footnote 11] According to Grants.gov, the registration process for an
organization should take from 3 to 5 business days; however, for some
applicants, this process can take 2 weeks or more.[Footnote 12] Table 1
highlights key steps in the registration process and typical
difficulties that can result in delay. In addition to registration
difficulties, which may or may not be caused by Grants.gov system
issues, applicants commonly encounter technical issues with Grants.gov,
such as system slowness and unresponsiveness, which also delay
applicants' ability to log in and submit applications in a timely
manner.
To submit an application, an applicant logs in and uploads a completed
application to Grants.gov. Grants.gov notifies the applicant by e-mail
that the application was received and provides a tracking number and
submission time stamp. Grants.gov then attempts to "validate" the
application by screening for technical errors, such as computer
viruses. The validation checks are typically completed within 48 hours.
If validation was successful, Grants.gov notifies the applicant by e-
mail. If validation was not successful, Grants.gov notifies the
applicant via e-mail that the application was "rejected due to errors"
and the application must be resubmitted. Grants.gov makes the
successfully validated application available to the grantor agency and
notifies the applicant via e-mail when this occurs.[Footnote 13]
Grantor agencies retrieve the validated applications from Grants.gov
and review them and make determinations about grant awards. If a
grantor agency determines that an application is late, the applicant
can often appeal this determination. There is no standard set of
criteria that agencies use to determine whether they will consider an
appeal.
Table 1: Key Steps and Time Frames in the Grants.gov Organization
Registration Process:
Step: Obtain DUNS number from Dun & Bradstreet (D&B)[A];
Estimated time required and considerations: Typically 1 business day;
* Requires organization information to be submitted to D&B via phone or
Internet.
Step: GSA's Central Contractor Registration (CCR)[B];
Estimated time required and considerations: Typically 1 to 2 business
days. (Can take 2 weeks or more);
* Requires DUNS number;
* Requires an employer identification number (EIN) from the Internal
Revenue Service (IRS). An EIN must be obtained from IRS if the
organization does not already have one. It may take 2 to 5 weeks for a
newly assigned EIN to become active for purposes of registering with
CCR;
* Requires CCR to check the organization information provided against
the IRS data on file; delays could result if there are inconsistencies;
* Establishes organization's E-Business Point of Contact (POC) who
creates a unique identification number for the organization called the
marketing partner identification number (MPIN). Only the E-Business POC
can authorize individuals to submit for the organizations as authorized
organization representatives (AOR)[C].
Step: Obtain username and password;
Estimated time required and considerations: Typically 1 day;
* Requires DUNS number;
* Requires complete and active CCR registration. Requires CCR
registration to be updated annually to be valid;
* Requires AOR to create profile on Grants.gov, which will serve as the
electronic signature when submitting grants.
Step: Register with Grants.gov to establish an AOR;
Estimated time required and considerations: Typically 1 day. (Can vary
because it depends on the E-Business POC);
* E-Business POC receives e-mail from Grants.gov asking him/her to log
in using MPIN and confirm the AOR;
* This takes about 24 hours from when the E-Business POC responds to
the Grants.gov request for authorization. AORs cannot submit an
application until the E-Business POC responds to Grants.gov with a
confirmation of their AOR status;
* Grants.gov advises the AOR to verify that the organization's E-
Business POC has confirmed them as authorized to submit grant
applications for the organization through Grants.gov.
Source: GAO presentation of Grants.gov and CCR information.
Notes:
See [hyperlink, http://grants.gov/applicants/get_registered.jsp] for
complete details of the registration process and links to the entities
described here.
[A] The federal government uses DUNS numbers, which identify an
organization to track how federal grant money is allocated.
[B] CCR is operated by GSA.
[C] AORs are the only people in an organization who can apply for
grants on its behalf through Grants.gov.
[End of table]
Applicants Lack a Central Source of Information on Recovery Act
Alternatives to Grants.gov:
Federal agencies must post all discretionary grant opportunities on
Grants.gov; many also require applicants to apply for most or all grant
applications through Grants.gov. Given the growing pressure on
Grants.gov caused by increased volume from the Recovery Act, OMB
required grantor agencies to identify by March 13, 2009, alternate ways
for applicants to submit grant applications during the Recovery Act
peak filing period and submit them to OMB for review and approval.
These alternatives include electronic systems run by a grantor agency,
e-mail, fax, and mail. Recovery.gov, the Web site established to
provide information on the Recovery Act,[Footnote 14] directs people to
use Grants.gov to search for federal grant opportunities but, as of
April 28, 2009, lacked information on the alternate submission methods
agencies have identified. On April 22, 2009, Grants.gov prominently
posted an announcement stating that all opportunities announced on
Grants.gov will include specific application instructions, as
appropriate, for submitting applications.[Footnote 15] The notice
directs applicants to carefully read the instructions for all grant
opportunities--even if they have applied before--to ensure that they
are following proper submission procedures for the programs.
As noted in the April 22 Grants.gov announcement, at least 10 agencies
will accept some or all applications outside of Grants.gov during the
Recovery Act peak filing period. For example, the National Science
Foundation and National Aeronautics and Space Administration are only
accepting applications through their own existing electronic systems
for some grants, and two Department of Justice program offices are
requiring applicants to use an internal electronic system to apply for
grants for the remainder of fiscal year 2009. Many agencies lack
alternate electronic systems and instead plan to rely on alternatives
such as e-mail, fax, or mail.[Footnote 16] For example, as stated in
the Environmental Protection Agency's (EPA) Recovery Act Request for
Applications Under the Clean Diesel Emerging Technologies Program
(released March 19, 2009), EPA will generally provide applicants the
option of submitting application materials by hard copy or through e-
mail.[Footnote 17]
On the other hand, the National Institutes of Health (NIH), which will
be competing at least an additional $400 million of Recovery Act
grants,[Footnote 18] has no viable alternative to Grants.gov. While it
is the largest federal grant-making entity, with over 90 percent of its
applications (101,000 submissions) coming in through Grants.gov in
fiscal year 2008, NIH does not have its own electronic system for
receiving applications. NIH officials told us that given the size and
structure of NIH applications, printing and mailing hard copies or
receiving applications via e-mail is "incredibly impractical" for both
applicants and NIH. These officials said that applicants will continue
to apply through Grants.gov but that NIH will accept late applications
in the event of Grants.gov system problems as it has done in the past.
[Footnote 19] These officials also said that they believe this work-
around will address most issues, but that since Recovery Act grants
have shorter time frames than most other NIH grants, decisions about
grant awards could be adversely affected by a lengthy Grants.gov system
problem or outage.
Disparate Agency Policies for Processing Grant Applications Could
Result in Different Treatment for Applications Submitted Electronically
versus through Other Means:
Agencies have disparate policies on several important aspects of
processing applications, specifically, (1) closing times for submitting
an application, (2) how to determine whether an application was
submitted timely, (3) when and whether to notify applicants that an
application has been successfully submitted, and (4) criteria for
considering an appeal when an application has been deemed late.
* Grants.gov accepts applications after the closing time of some grant
opportunities. Grants.gov accepts applications until midnight eastern
time on a grant's closing date, but about one-third of the responding
grantor agencies we surveyed had application deadlines before midnight-
-sometimes as early as noon eastern time.[Footnote 20] NIH, the largest
grantor agency, has a 5:00 p.m. local time deadline for all its grants.
This presents problems for applicants using Grants.gov for two reasons.
First, applicants could receive confirmation that an application was
successfully submitted to Grants.gov, but the application can still be
deemed late by the grantor agency. Second, Grants.gov officials have
told applicants to submit applications during off-peak hours, (i.e.,
before 11:00 a.m. and after 8:00 p.m. eastern time) to help resolve
ongoing Grants.gov system overload issues.[Footnote 21]
* Agencies have different policies for determining the timeliness of
Grants.gov applications as well as for submissions through other
methods. Of the 74 grantor agencies responding to our survey, more than
60 percent (47) said that they determine whether an application is
timely based on the time the application was submitted to Grants.gov;
16 percent (12) said they determine whether an application is timely
based on the time the application was validated by Grants.gov.[Footnote
22] However, validation can take up to 48 hours after a grant is
successfully submitted; this has resulted in late submissions.[Footnote
23] In contrast, applications submitted by e-mail or mailed in hard
copy--two of the options agencies have made available as alternate
means of submitting applications during the Recovery Act peak filing
period--are not subject to Grants.gov validation. Instead, agencies use
other means to establish the timeliness of these submissions. For
example, the postmark[Footnote 24] or the arrival date is often used to
determine the timeliness of paper applications.
* Agencies differ in notifying applicants when and whether applications
have been successfully submitted. There are no common requirements for
notifying applicants of the status of their applications; as such,
these policies vary across grant-making agencies. More than half of the
agencies responding to our survey (39 respondents) said that they
notify an applicant "immediately or almost immediately" when an
application is late and will not be forwarded for content review. In
contrast, 13 respondents said that they either wait until the time that
the grant is awarded to notify applicants or do not notify applicants
at all.[Footnote 25] Further, an applicant's ability to determine the
status of an application varies depending on how the application was
submitted. For example, applicants that mail hard copies of
applications can choose to track their applications through the U.S.
Postal Service or commercial delivery service; applicants that submit
their applications via e-mail or an electronic system have no way of
knowing if their applications were successfully submitted unless the
grantor agencies or electronic systems notify them. Lack of notice, or
untimely notice, can eliminate an applicant's chance to appeal a late
determination.
* Agencies have different criteria for considering appeals when an
application is late and do not always consider the most common reasons
for late submissions. If a grantor agency determines that an
application is late, applicants can often appeal this determination;
however, the criteria agencies use to determine whether they will
consider an appeal vary. Our survey results and interviews indicate
that being unable to register with Grants.gov is one of the most common
problems experienced by applicants. However, more than half of the 23
survey respondents that provided data about appeals based on
registration difficulties said that appeals on this basis were more
likely to be denied than approved. Registering with Grants.gov in a
timely manner--which should take from 3 to 5 business days but can take
2 weeks or more if applicants encounter problems--may be even more
difficult during the Recovery Act period given the number of applicants
trying to register. On the other hand, most of the 27 survey
respondents who provided data on appeals based on technical issues with
Grants.gov, such as system slowness or unresponsiveness, said that
these appeals were approved most to all of the time. To provide
evidence of technical issues, agencies may ask applicants to provide
case numbers from the Grants.gov contact center so the agencies can
obtain the details of the cases and confirm the technical problems.
[Footnote 26] However, applicants report that obtaining a case number
from the contact center in a timely fashion has become more challenging
in recent months. Grants.gov officials and applicants have reported
long wait times--sometimes 30 minutes or more--when calling the contact
center, because of the large numbers of applicants seeking assistance.
These delays could hamper an applicant's ability to obtain the
necessary data to support a request for an appeal.
Conclusions:
OMB has acknowledged the importance of Grants.gov in successfully
implementing the Recovery Act. By working with agencies to initiate
immediate improvements to Grants.gov and requiring agencies to identify
alternate methods for accepting grant applications, OMB has played a
critical role in minimizing disruptions to the grants application
process. OMB and the Grants.gov staff have worked quickly to mitigate
an impending system failure and protect the flow of Recovery Act grant
funds to struggling communities around the country.
However, applicants lack a centralized source of information on how and
when to use these alternatives, rendering them less effective than they
otherwise might be in reducing the strain on a system already suffering
from seriously degraded performance. Moreover, inconsistent agency
policies for grant closing times, what constitutes a timely
application, when and whether applicants are notified of the status of
their applications, and the basis on which applicants can appeal a late
application create confusion and uncertainty for applicants and could
result in an application being treated differently depending on how it
is submitted--results that are contrary to OMB's stated purposes for
recent efforts to improve Grants.gov and to the streamlining goals of
Public Law 106-107 in general.
Recommendations for Executive Action:
We are making the following two recommendations to the Director of OMB
to increase the likelihood that applicants can successfully apply for
grants during the Recovery Act's peak application filing period.
We recommend that the Director of OMB ensure that an announcement
discussing agency alternate submission methods similar to that recently
posted on Grants.gov is posted in a prominent location on Recovery.gov
and on all federal Web sites or in all documents where instructions for
applying to Recovery Act grants are presented. Such announcements,
including the one on Grants.gov, should also include guidance for
applicants that try to submit through Grants.gov but cannot
successfully register and are therefore unable to submit timely
applications.
We recommend that the Director of OMB implement and prominently post
the following governmentwide policies, effective immediately, for all
grant applications submitted during the peak filing period for Recovery
Act grants:
* To the extent permissible by law, applications received at any point
on the stated grant opportunity closing date should be considered
timely.
* Agencies must notify an applicant when an application submission has
been received and if the application has been deemed late. An applicant
that submits electronically (including by e-mail or fax) should receive
automatic confirmation, including a date and time stamp.
* Applicants whose applications have been deemed late should be given
an opportunity to provide supporting documentation to demonstrate that
they attempted to submit an application on time. Proof of timely
submission could include (1) e-mail confirmation of receipt from the
electronic system used to submit the application, (2) system time
stamps from the electronic system used to submit the application, or
(3) a dated postmark or receipt from the U.S. Postal Service or a
commercial delivery service.
Agency Comments:
In commenting on a draft of this report, OMB concurred with our
findings and the overall objectives of our recommendations. OMB staff
also provided technical comments, which we have incorporated as
appropriate. OMB said that it plans to work with the Grants Policy
Committee and with other stakeholders as appropriate to define the best
path forward in addressing our recommendations. HHS provided technical
comments which have been incorporated as appropriate.
We are sending copies of this report to the Director of OMB, the
Secretary of Health and Human Services, and other interested parties.
The report also is available at no charge on the GAO Web site at
[hyperlink, http://www.gao.gov].
Should you wish to discuss these matters, please contact me at (202)
512-6806 or czerwinskis@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. Major contributors to this report were Thomas
James, Assistant Director; Jacqueline M. Nowicki, Assistant Director;
Jennifer Ashford; Carolyn Boyce; James J. Burns; David Fox; and James
R. Sweetman, Jr. Cynthia Grant, Chelsa Gurkin, Luann Moy, and Carol
Patey also made key contributions.
Sincerely Yours,
Signed by:
Stanley J. Czerwinski:
Director:
Strategic Issues:
[End of section]
Footnotes:
[1] All federal discretionary grant opportunities are required to be
posted on the site, and many "grantor agencies" require applicants to
submit most or all grant applications using the Grants.gov "apply"
mechanism. We use the term grantor agencies throughout this report to
mean the 26 grant-making agencies and their subcomponents that have
distinctive application policies. For example, the Department of Health
and Human Services is made up of agencies, each of which has its own
policies on grant applications. We consider each operating division a
grantor agency. In a survey we conducted of 80 grantor agencies, we
found that 64 percent (47) of the 74 respondents required the use of
Grants.gov for most to all of their grants.
[2] Pub. L. No. 111-5 (Feb. 17, 2009). For grant opportunity postings,
see [hyperlink, http://www.grants.gov/applicants/recovery.jsp] (as of
Apr. 28, 2009).
[3] Office of Management and Budget, Recovery Act Implementation--
Improving Grants.gov and Other Critical Systems, M-09-14 (Washington,
D.C.: Mar. 9, 2009).
[4] OMB instructed agencies that applicants be provided an electronic
alternative to Grants.gov; a paper-only alternative was not an approved
option.
[5] Office of Management and Budget, Improving Grants.gov, M-09-17
(Washington, D.C.: Apr. 8, 2009).
[6] Like many e-Government initiatives, Grants.gov is funded by
voluntary agency contributions. OMB instructed the 26 grant-making
agencies that together finance Grants.gov to immediately submit any
fiscal year 2009 unpaid contributions to HHS and to provide the
additional funding requested for Recovery Act-related improvements to
Grants.gov. See Office of Management and Budget, Improving Grants.gov.
[7] The Grants.gov PMO is in charge of the day-to-day management of
Grants.gov. HHS is the designated managing partner of Grants.gov and
has lead responsibility for the initiative. The GEB consists of
representatives from the 26 grant-making agencies and provides
strategic leadership and resources to Grants.gov. OMB provides
oversight and guidance to the 24 e-Government initiatives of which
Grants.gov is one.
[8] We worked with officials from the 26 grant-making agencies to
determine if policies on submitting and reviewing grant applications
are centralized at the agency level or if they differ within an agency
by subagency or program office. We then administered the survey at the
level where policies are established in order to capture differences
between and within the 26 grant-making agencies. We identified 80
grantor agencies that have distinctive grant application policies. The
74 responses we received were from all of the 26 grant-making agencies.
[9] Pub. L. No. 106-107 (Nov. 20, 1999). Although we focus on grants
and cooperative agreements in this report, the law covers all types of
federal financial assistance.
[10] OMB requires agencies to announce all discretionary grants
opportunities on Grants.gov; it does not require agencies to accept
applications through Grants.gov.
[11] Applicants applying as individuals (not as part of an
organization) must also register with Grants.gov before applying for
grants; however, individuals are only able to apply for grant
opportunities that are open to individuals. In our survey, only 32
percent (24) of the 74 respondents stated that they offer grants to
individuals.
[12] As shown in table 1, obtaining an employer identification number
from the Internal Revenue Service may take 2 weeks or more.
[13] The Grants.gov validation process is not designed to verify any
agency-specific or grant-specific requirements; as such, an application
that was validated by Grants.gov could be forwarded to the agency and
still fail to meet criteria specified in a grant's application
instructions.
[14] Pub. L. No. 111-5, div. A, title XV, § 1526.
[15] See [hyperlink, http://www.grants.gov/applicants/bulletin.jsp] (as
of Apr. 28, 2009).
[16] In some cases, agencies already allowed applicants to submit using
these alternative methods.
[17] The other 6 agencies are: Corporation for National and Community
Service, and the Departments of Defense, Education, Energy, Housing and
Urban Development, and Transportation.
[18] NIH plans to compete approximately $9.9 billion in Recovery Act
grants and Recovery Act contracts. At the time of our review, NIH
officials estimated that of the $9.9 billion, a minimum of $400 million
would be awarded through grants. The Web portal for all federal
government contracting opportunities is [hyperlink,
http://www.FedBizOpps.gov].
[19] Even before the Recovery Act became law, some agencies recognized
the need to amend their application submission policies to better meet
applicants' needs. For example, NIH reported that it has changed its
policies to accommodate applicants that encounter technical problems
with Grants.gov or NIH systems, and that it works with applicants in
need of assistance even if it means granting an extension beyond the
grant closing date.
[20] Grants.gov officials told us that in rare cases application
deadline times are written into a grant's authorizing legislation.
[21] For example, on April 6, 2009, the day Grants.gov received its
largest numbers of submissions to date, almost one-third of the 3,555
applications received were submitted from 3:00 p.m. through 6:00 p.m.
eastern time.
[22] Six respondents said that they used another indicator to determine
timeliness, and nine did not answer the question.
[23] Although it was beyond the scope of our work to fully examine
other agency-specific electronic systems, we found evidence that some
of those systems have a registration process similar to the Grants.gov
registration process; we could not determine if any had a similar
validation process.
[24] Agencies may specify the requirement of a U.S. Postal Service
postmark or a dated receipt from a commercial carrier in their
application instructions.
[25] Of the remaining responses, 12 answered "other," and 10 did not
respond or answered "no response."
[26] The Grants.gov contact center is a help desk that applicants can
call or e-mail when they need assistance. The contact center assigns
case numbers and attempts to resolve callers' issues. The grantor
agency can contact the call center and use the case number to obtain
the case notes. Grantor agencies may also allow the applicants to
provide additional evidence.
[End of section]
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