Grants Management
Grants.gov Has Systematic Weaknesses That Require Attention Gao ID: GAO-09-589 July 15, 2009In response to the Federal Financial Assistance Management Improvement Act of 1999, the Office of Management and Budget (OMB), among other things, developed Grants.gov as the central grant identification and application portal for federal grant programs. OMB oversees the initiative and named the Department of Health and Human Services (HHS) its managing partner. Grants.gov officials have acknowledged noticeably degraded system performance, and grantees have reported difficulties submitting applications that have in some cases led to late or incomplete submissions and lost opportunities for both grantees and populations served. Through analysis of agency documents, a Web-based survey of federal grant-making officials, and interviews with agency officials and grantee associations, this requested report examines (1) the benefits of Grants.gov and applicant experiences with submitting applications, (2) the governance structure of Grants.gov, and (3) the range of agency policies for processing Grants.gov applications.
Grants.gov has made it easier for applicants to find grant opportunities and grantors to process applications faster, but applicants continue to describe difficulties registering with and using Grants.gov, which sometimes result in late submissions. Grants.gov customer service staff do not always resolve these issues, especially during off-peak hours and peak submission periods. Clear roles and responsibilities for the Grants.gov oversight entities and coordination among them are critical, yet insufficient, and there are no written policies for how these entities are to work with each other. HHS's Chief Information Officer and the Grants Executive Board (GEB) share responsibility for approving major initiatives and funding for Grants.gov, but there is little evidence that GEB-approved funding for Grants.gov is considered in HHS's review of Grants.gov as an IT investment. This created a disconnect between the services Grants.gov is to provide and the funding needed to purchase them. Untimely payment by the 26 agencies that fund Grants.gov also negatively affects system performance. After informing agencies that it was unable to pay its vendors, the Grants.gov Project Management Office (PMO) developed a system shutdown plan and implemented the first step--it eliminated Web site updates and moved all notices to the Grants.gov blog. Grants.gov also lacks performance measures for important aspects of the system. Finally, grantees lack a structured forum for input on the Grants.gov system and standardized governmentwide grant application policies, limiting grantees' ability to affect a system designed, in part, to streamline the grants application process and ease applicant burden. Disparate agency policies on important aspects of processing applications--such as the criteria for granting appeals for late or incomplete applications and for what constitutes a timely application--burden applicants and sometimes puts applications submitted through Grants.gov at a disadvantage compared to applications submitted through other means, such as other electronic systems or the USPS.
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-09-589, Grants Management: Grants.gov Has Systematic Weaknesses That Require Attention
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United States Government Accountability Office:
GAO:
July 2009:
Grants Management:
Grants.gov Has Systemic Weaknesses That Require Attention:
GAO-09-589:
GAO Highlights:
Highlights of GAO-09-589, a report to congressional requesters.
Why GAO Did This Study:
In response to the Federal Financial Assistance Management Improvement
Act of 1999, the Office of Management and Budget (OMB), among other
things, developed Grants.gov as the central grant identification and
application portal for federal grant programs. OMB oversees the
initiative and named the Department of Health and Human Services (HHS)
its managing partner. Grants.gov officials have acknowledged noticeably
degraded system performance, and grantees have reported difficulties
submitting applications that have in some cases led to late or
incomplete submissions and lost opportunities for both grantees and
populations served. Through analysis of agency documents, a Web-based
survey of federal grant-making officials, and interviews with agency
officials and grantee associations, this requested report examines (1)
the benefits of Grants.gov and applicant experiences with submitting
applications, (2) the governance structure of Grants.gov, and (3) the
range of agency policies for processing Grants.gov applications.
What GAO Found:
Grants.gov has made it easier for applicants to find grant
opportunities and grantors to process applications faster, but
applicants continue to describe difficulties registering with and using
Grants.gov, which sometimes result in late submissions. Grants.gov
customer service staff do not always resolve these issues, especially
during off-peak hours and peak submission periods.
Clear roles and responsibilities for the Grants.gov oversight entities
and coordination among them are critical, yet insufficient, and there
are no written policies for how these entities are to work with each
other. HHS‘s Chief Information Officer and the Grants Executive Board
(GEB) share responsibility for approving major initiatives and funding
for Grants.gov, but there is little evidence that GEB-approved funding
for Grants.gov is considered in HHS‘s review of Grants.gov as an IT
investment. This created a disconnect between the services Grants.gov
is to provide and the funding needed to purchase them. Untimely payment
by the 26 agencies that fund Grants.gov also negatively affects system
performance. After informing agencies that it was unable to pay its
vendors, the Grants.gov Project Management Office (PMO) developed a
system shutdown plan and implemented the first step”it eliminated Web
site updates and moved all notices to the Grants.gov blog. Grants.gov
also lacks performance measures for important aspects of the system.
Finally, grantees lack a structured forum for input on the Grants.gov
system and standardized governmentwide grant application policies,
limiting grantees‘ ability to affect a system designed, in part, to
streamline the grants application process and ease applicant burden.
Disparate agency policies on important aspects of processing
applications”such as the criteria for granting appeals for late or
incomplete applications and for what constitutes a timely application”
burden applicants and sometimes puts applications submitted through
Grants.gov at a disadvantage compared to applications submitted through
other means, such as other electronic systems or the USPS.
Figure: Entities Involved in the Federal Grants Pre-Award Stage of the
Grants Life Cycle:
[Refer to PDF for image: illustration]
Grant-making partner agencies: 26:
Grant-making officials from the 26 partner agencies comprise board and
policy committee of the Grants Executive Board.
Managing partner agency (HHS): IT management (Governance body):
Execution team: Grants.gov Program Management Office (PMO): Provides
leadership and resources to Grants Executive Board.
Grants Policy Committee (Governance body):
Execution team: PL 106-107 Pre-award working group: Provides
coordination between Grants Executive Board and OMB.
Source: GAO analysis of OMB data.
[End of figure]
What GAO Recommends:
GAO is making four recommendations to OMB to develop Grants.gov system
performance measures, guidance clarifying the governance structure, a
structured means for applicant input, and uniform policies for
processing grant applications. OMB and HHS generally agreed with our
findings and recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-09-589] or key
components. For more information, contact Stanley J. Czerwinski at
(202) 512-6806 or czerwinskis@gao.gov.
[End of section]
Contents:
Letter:
Background:
Grants.gov Offers Benefits, but Cumbersome Registration Requirements
and Uneven System Performance Burden Applicants and Create Potential
for Late Submissions:
Accountability and Responsibility for Grants.gov Performance among the
Grants.gov Governance Entities Is Unclear:
Disparate Agency Policies for Processing Grant Applications Can Result
in Different Treatment for Applications Submitted through Various
Means:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Detailed Survey Description:
Appendix II: Comments from the Department of Health and Human Services:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Top 10 Grantor Agencies by Grants.gov Submissions, Fiscal Year
2008:
Table 2: Key Steps and Time Frames in the Grants.gov Organization
Registration Process:
Table 3: Top Reasons for Applicants' Late Submissions as Reported by
Grantor Agencies for Fiscal Years 2007 and 2008:
Figures:
Figure 1: Entities Involved in the Federal Grants Pre-Award Stage of
Grants Life Cycle:
Figure 2: Grants.gov Partner Agency Funding Structure, Fiscal Year
2009:
Abbreviations:
AAU: Association of American Universities:
AOR: authorized organization representatives:
CCR: Central Contractor Registration:
CFO: Chief Financial Officers:
COGR: Council on Governmental Relations:
CPIC: Capital Planning and Investment Control:
CSR: customer support representative:
D&B: Dun & Bradstreet:
DUNS: Data Universal Numbering System:
EPA: Environmental Protection Agency:
FACA: Federal Advisory Committee Act:
FDP: Federal Demonstration Project:
GEB: Grants Executive Board:
GSA: General Services Administration:
HHS: Department of Health and Human Services:
HUD: Department of Housing and Urban Development:
IRS: Internal Revenue Service:
MPIN: marketing partner identification number:
NGP: National Grants Partnership:
NIH: National Institutes of Health:
NSF: National Science Foundation:
OCIO: Office of the Chief Information Officer:
OMB: Office of Management and Budget:
PMO: Program Management Office:
POC: Point of Contact:
USPS: U.S. Postal Service:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 15, 2009:
The Honorable George V. Voinovich:
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:
Grants.gov[Footnote 1] serves as the central grant identification and
application portal for more than 1,000 federal grant programs that
fund, for example, training, research, planning, construction, and the
provision of services in areas such as health care, education,
transportation, and homeland security. However, since Grants.gov's
inception, the Grants.gov system administrators have acknowledged the
technical limitations of Grants.gov; more recently, they acknowledged
noticeably degraded performance, and applicants have reported
difficulties in submitting applications through Grants.gov. In some
cases, these issues have led to late or incomplete applications and
lost opportunities for both grantees and the population that may have
benefited from the grantee's programs and services.
In early March 2009, the Office of Management and Budget (OMB)
highlighted the critical nature of Grants.gov by stating that the
implementation of the American Recovery and Reinvestment Act of 2009
(Recovery Act)[Footnote 2] could be hampered by the failure of
Grants.gov, which had already been experiencing noticeably degraded
performance. Noting that Grants.gov was at significant risk of failure
because of the expected increase in application volume from Recovery
Act grants, OMB instructed agencies to identify alternative methods for
accepting grant applications to reduce demand on Grants.gov's limited
resources.[Footnote 3] At least 10 agencies are temporarily accepting
some or all applications through alternative methods[Footnote 4] during
the Recovery Act peak filing period, which is expected to continue
through August 2009. However, the expectation is that agencies and
grantees will return to their reliance on Grants.gov for submitting
applications as fiscal year 2010 approaches.
This report responds to your request to examine applicant experiences
submitting grant applications through the Grants.gov Web site. To
accomplish this, we reviewed the 1) benefits of Grants.gov and
applicants' experiences when submitting applications; 2) governance and
accountability structure of Grants.gov, especially with respect to
setting policy and resolving performance issues; and 3) range of agency
policies for processing Grants.gov applications, including late and
incomplete applications. This report follows our April 2009 report on
Grants.gov Recovery Act issues,[Footnote 5] in which we provided our
initial observations on improving grant submission policies to help
minimize disruptions to the grants application process during the
Recovery Act's peak filing period.[Footnote 6]
The information presented in this report is based on our review of
policies and procedures related to grant applications from the
Grants.gov Program Management Office (PMO) and federal grant-making
agencies. We also examined documentation from the Department of Health
and Human Services (HHS), the Grants Executive Board (GEB), the Grants
Policy Committee, and OMB.[Footnote 7] We conducted a Web-based survey
in December 2008 and January 2009 of 80 agency officials representing
the 26 federal grant-making agencies and subcomponents within those
agencies that have distinctive grant application submission and
processing policies. Throughout this report, we call these
organizations grantor agencies.[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 who submit applications through Grants.gov. To
design the questionnaire, we interviewed agency grant officials and
pretested the survey instrument 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. When the survey
closed in late January 2009, we had received responses from 74 grantor
agencies for a response rate of 92.5 percent.[Footnote 9] For more
details on how the survey was constructed, administered and analyzed
for this report, see appendix I. We also conducted interviews with
officials from the Grants.gov PMO, HHS, GEB, the Grants Policy
Committee, and OMB. To obtain more information from the grantee
perspective on using Grants.gov and other application submission
methods, as well as agency submission policies, we reviewed documents
from several associations representing communities of grant applicants
and interviewed staff from these organizations.
We conducted our work from May 2008 to July 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:
Over 1,000 federal grant programs are disbursed and managed by 26
federal agencies and other federal grant-making organizations. Because
of concerns about the burden on grantees of the varying requirements
imposed by these different grant programs, Congress enacted the Federal
Financial Assistance Management Improvement Act of 1999, commonly
referred to by the grants community and OMB as Public Law 106-107.
[Footnote 10] 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.
Our previous reports have reviewed several aspects of Public Law 106-
107's implementation, including 1) what agencies did to implement the
law; 2) the coordination among OMB, the agencies and grantees; and 3)
grantees' views of areas where the goals of the law had not been met.
[Footnote 11]
In response to Public Law 106-107, OMB, among other things, created
Grants.gov (initially known as e-Grants). Grants.gov was included among
the E-Government initiatives designated in OMB's 2002 E-Government
Strategy.[Footnote 12] The Grants.gov Web site was deployed with both
the "Find" and "Apply" tools on October 31, 2003, and was meant, in
part, to improve the announcement and application stages (together
known as the pre-award stage) of the grant-making process for
grantees.[Footnote 13] Almost all federal discretionary grant
opportunities are posted to the Grants.gov Web site; applicants can
search for grant opportunities by agency or across agencies using the
"Find" mechanism.[Footnote 14] Many grant announcements include a link
to application forms and instructions.
In order to log in and submit an application, first-time applicants
must register with Grants.gov--a complex process involving multiple
entities. Once registered, an applicant can log in and upload a
completed application to Grants.gov.[Footnote 15] 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, which includes scanning for viruses and
verifying the applicant's eligibility to apply. 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 16] Once an application is completed by the
grantee and successfully submitted through Grants.gov, it is then
retrieved and reviewed by the grantor agency. The agency then
determines which applicant(s) is awarded the grant. If a grantor agency
determines that an application is late or incomplete, the applicant can
often appeal this determination.
As with all E-Government initiatives, OMB established a management
structure to oversee the initiative and to facilitate a collaborative
working environment for Grants.gov. This management structure included
a managing partner agency--HHS for the Grants.gov initiative--to manage
the system and to coordinate agency involvement in managing and
developing procedures supporting the use of the system. Because
Grants.gov supports "governmentwide common solutions" it is included on
OMB's High Risk List, indicating it is to receive special attention
from oversight authorities.[Footnote 17] The Grants.gov oversight and
management structure includes an OMB portfolio manager, a managing
partner agency, the GEB, and the Grants.gov PMO.
* OMB Portfolio Manager. Categorized as a "government-to-government"
initiative, Grants.gov was assigned to the government-to-government
portfolio manager within OMB's Office of Electronic Government and
Information Technology (Office of E-Government). The portfolio manager
is to provide oversight and guidance to the initiative.[Footnote 18]
* Managing Partner Agency. As managing partner for Grants.gov, HHS is
responsible for managing Grants.gov; HHS is responsible for managing
Grants.gov as an IT investment through the HHS's Office of the Chief
Information Officer (OCIO). OCIO is required to manage Grants.gov
through HHS's capital programming and budget process. The HHS Office of
Grants provides departmental input to Grants.gov and other
governmentwide grant initiatives, and key leadership and oversight on
Grants.gov management and implementation.
* GEB. The GEB was established in 2002 at HHS's request to help
coordinate agency involvement in managing Grants.gov and consists of
grant-making officials from the 26 partner agencies; the OMB government-
to-government portfolio manager is a non-voting member of the board.
The GEB's role is to provide strategic leadership and resources to
Grants.gov, including reviewing implementation and operational
policies, the Grants.gov budget, and the level of financial
contribution of each partner agency. The GEB charter states that it
"will serve as an authoritative voice for the grant-making agencies,
providing a governance body that can vote on proposals and deliverables
as representatives of the grant-making agencies." The chair of the GEB
in fiscal years 2008 and 2009 is a senior grants policy official from
the Environmental Protection Agency (EPA).
Like many E-Government initiatives, Grants.gov is funded by voluntary
contributions from its partner agencies. Memorandums of understanding
between the Grants.gov PMO and the partner agencies lay out the amount
and timing of the contributions to be made and the Grants.gov services
to be provided. The GEB uses a funding algorithm--based primarily on
the total dollar amount of each agency's discretionary grant awards--to
determine the contribution required from each of the 26 grant-making
agencies. In a 2005 report, we reported that most of the 10 E-
Government initiatives that were funded by voluntary agency
contributions experienced shortfalls from their funding plans for
fiscal years 2003 and 2004; in most cases contributions from partner
agencies were made in the third and fourth quarters of those fiscal
years.[Footnote 19]
* Grants.gov PMO. Day-to-day management of the Grants.gov initiative
and its budget is the responsibility of the Grants.gov PMO, which is
located within HHS and is currently staffed by nine employees plus
supporting contractor personnel. The PMO is also responsible for
managing the process to update the standard grant application forms (SF
424 series) approved by OMB for governmentwide use.[Footnote 20]
The Grants Policy Committee, established by the Chief Financial
Officers (CFO) Council,[Footnote 21] has overall responsibility for
implementing Public Law 106-107. One of its goals is to "simplify
federal financial assistance processes to make them more uniform across
agencies and eliminate unnecessary burdens on applicants, grantees, and
federal agencies."[Footnote 22] Specifically, the Grants Policy
Committee is to, among other things, coordinate all federal grants
policy recommendations submitted to OMB, recommend uniform forms and
formats for grant applications and post-award reports, recommend
standard and streamlined federal-to-grantee business processes,
facilitate greater community input and outreach in streamlining federal
financial assistance and collaborate with the GEB on Grants.gov and
other streamlining issues. The committee's pre-award working group is
responsible for developing policy proposals for streamlining and
simplifying the pre-award stage of the grants life cycle. Figure 1
illustrates the various entities involved in the grant pre-award stages
at the federal level.
Figure 1: Entities Involved in the Federal Grants Pre-Award Stage of
Grants Life Cycle:
[Refer to PDF for image: illustration]
Grant-making partner agencies: 26:
Grant-making officials from the 26 partner agencies comprise board and
policy committee of the Grants Executive Board.
Managing partner agency (HHS): IT management (Governance body):
Execution team: Grants.gov Program Management Office (PMO): Provides
leadership and resources to Grants Executive Board.
Grants Policy Committee (Governance body):
Execution team: PL 106-107 Pre-award working group[A]: Provides
coordination between Grants Executive Board and OMB.
Source: GAO analysis of OMB data.
[A] The other Grants Policy Committee working groups are: 1) post-
award, 2) mandatory, 3) audit oversight, 4) training and certification,
and 5) electronic (new as of May 8, 2009).
[End of figure]
The E-Government Act of 2002 and the Clinger-Cohen Act of 1996 are
relevant to Grants.gov as an IT investment.
* E-Government Act of 2002.[Footnote 23] In implementing this act,
OMB's Office of Electronic Government and Information Technology is
responsible for, among other things, providing overall leadership and
direction to the executive branch on electronic government and
oversight of governmentwide implementation of information technology,
including monitoring and consulting on agency technology efforts.
* Clinger-Cohen Act of 1996.[Footnote 24] Among other things, Clinger-
Cohen requires agencies to better link their IT planning and investment
decisions to program missions and goals and to implement and enforce IT
management policies, procedures, standards, and guidelines. The act
also requires that agencies engage in capital planning and performance
and results-based management.[Footnote 25] OMB's responsibilities under
the act include establishing processes to analyze, track, and evaluate
the risks and results of major capital investments in information
systems made by executive agencies. OMB must also report to Congress on
the net program performance benefits achieved as a result of these
investments.[Footnote 26]
In response to the Clinger-Cohen Act and other statutes, OMB developed
a policy and a Capital Programming Guide for the planning, budgeting,
acquisition, and management of federal capital assets that direct
agencies to develop, implement, and use a capital programming process
to build their capital asset portfolios.[Footnote 27] Among other
things, this guidance directs agencies to:
* evaluate and select capital asset investments that will support core
mission functions and demonstrate projected returns on investment that
are clearly equal to or better than alternative uses of available
public resources,
* institute performance measures and management processes that monitor
actual performance and compare it to planned results, and:
* establish oversight mechanisms that require periodic review of
operational capital assets to determine if mission requirements have
changed and whether the assets continue to fulfill those requirements
and deliver their intended benefits.
Grants.gov Offers Benefits, but Cumbersome Registration Requirements
and Uneven System Performance Burden Applicants and Create Potential
for Late Submissions:
Grants.gov offers benefits to grantees and grantor agencies alike.
Grantees and grantor agencies reported the benefits of the "Find"
feature, noting that a single, searchable source for all federal grants
makes it easier to find grant opportunities, especially for similar
activities offered by different agencies. Grantor agencies also
reported that the find feature allows them to reach a larger, more
diverse pool of applicants than before.
The "Apply" feature of Grants.gov allows applicants to avoid some steps
necessary for paper applications, such as making multiple photocopies.
Some grantor agencies report that Grants.gov eliminates the need to
develop an agency-specific electronic system or allows them to process
applications more quickly because they no longer need to manually enter
application data. Use of the Grants.gov "apply" feature has grown
considerably since October 2003. Of the 489,252 total submissions
received between October 2003 and September 2008, more than three
quarters were processed in fiscal years 2007 and 2008.[Footnote 28]
Sixty-four percent (47) of the 74 grantor agencies responding to our
survey--including the National Institutes of Health (NIH), the agency
with the largest number of Grants.gov submissions (see table 1)--said
they require the use of Grants.gov for most to all of their
applications.[Footnote 29]
Table 1: Top 10 Grantor Agencies by Grants.gov Submissions, Fiscal Year
2008:
Grantor agency: National Institutes of Health (HHS);
Number of Grants.gov submissions: 101,000.
Grantor agency: Department of Defense;
Number of Grants.gov submissions: 12,458.
Grantor agency: Department of Education;
Number of Grants.gov submissions: 8,861.
Grantor agency: National Endowment for the Arts;
Number of Grants.gov submissions: 6,544.
Grantor agency: National Endowment for the Humanities;
Number of Grants.gov submissions: 5,481.
Grantor agency: Health Research Services Agency (HHS);
Number of Grants.gov submissions: 5,150.
Grantor agency: Office of Justice Programs (Department of Justice);
Number of Grants.gov submissions: 4,840.
Grantor agency: Cooperative State Research, Education and Extension
Service (U.S. Department of Agriculture);
Number of Grants.gov submissions: 4,818.
Grantor agency: U.S. Department of Housing and Urban Development;
Number of Grants.gov submissions: 4,732.
Grantor agency: Administration for Children and Families (HHS);
Number of Grants.gov submissions: 3,892.
Source: As reported by GAO survey respondents.
Note: We did not verify the accuracy of reported numbers.
[End of table]
Grants.gov Registration Is Complex and a Common Reason for Late
Submissions:
Before submitting an application through Grants.gov, grantees must
first register--a complex and sometimes lengthy process. The GEB
established the registration process to ensure that only authorized
applicants apply on behalf of an organization.[Footnote 30] According
to the Grants.gov PMO, the registration process should take 3 to 5
business days but can take 2 weeks or more for some applicants. We
previously reported applicant issues with the registration process in
July 2006.[Footnote 31] Table 2 highlights key steps and time frames in
the registration process.
Table 2: Key Steps and Time Frames in the Grants.gov Organization
Registration Process:
Steps: 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.
Steps: General Services Administration's (GSA) 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].
Steps: 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.
Steps: 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]
(accessed as of July 6, 2009) 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 who can apply for grants through
Grants.gov on behalf of an organization.
[End of table]
The Grants.gov PMO and grantor agencies widely acknowledge Grants.gov
registration delays and strongly advise applicants to allow 2 to 3
weeks to complete the registration process. In our survey, 37 of the 74
grantor agencies cited difficulties with the overall registration
process as one of the top three reasons that applicants gave for late
applications. Applicants may not realize that, although they can
download and complete an application without registering, in order to
upload the application to Grants.gov--that is, actually submit the
application--they must register. In contrast, applicants who can e-mail
or mail paper applications do not need to register with Grants.gov
before submitting an application.[Footnote 32] Grantee and agency
officials noted that they only use some of the applicant verification
information required for Grants.gov registration, such as the DUNS
number, once an applicant is to receive a grant award. According to HHS
officials, in January 2009 the PMO recommended to the GEB an
alternative process that would defer the applicant verification
activities to the agency level, but the GEB elected to stay with the
existing registration process. In commenting on a draft of this report,
OMB officials said that since 2003, OMB has required all grant
applications, regardless of whether they are submitted through
Grants.gov or some other means, to include a DUNS number. Table 3
describes common reasons for applicants' late submissions.
Table 3: Top Reasons for Applicants' Late Submissions as Reported by
Grantor Agencies for Fiscal Years 2007 and 2008:
Reason for late submission [A,B]:
Applicant had overall difficulty with the registration process;
Total responses: 37.
Reason for late submission [A,B]:
The Grants.gov system was unresponsive, and the application would not
upload;
Total responses: 37.
Reason for late submission [A,B]:
The applicant did not understand error messages generated by
Grants.gov;
Total responses: 20.
Reason for late submission [A,B]:
Technical issues with the applicant's computer prevented him or her
from submitting the application;
Total responses: 19.
Reason for late submission [A,B]:
The applicant was unable to receive timely assistance from the
Grants.gov contact center;
Total responses: 12.
Reason for late submission [A,B]:
The DUNS number provided by the applicant could not be verified by
Grants.gov.; Total responses: 10.
Reason for late submission [A,B]: The applicant was unable to obtain e-
Business POC authorization;
Total responses: 9.
Reason for late submission [A,B]:
The applicant claimed that attachments submitted through Grants.gov
were not transmitted to your organization, resulting in an incomplete
or untimely application;
Total responses: 9.
Reason for late submission [A,B]:
The applicant did not find the assistance provided by the Grants.gov
contact center to be useful;
Total responses: 8.
Reason for late submission [A,B]:
The applicant did not realize his or her application was late;
Total responses: 8.
Reason for late submission [A,B]:
The applicant could not identify the organization's e-Business POC;
Total responses: 4.
Reason for late submission [A,B]:
Personal reasons were given for late applications (e.g., death in the
family);
Total responses: 3.
Reason for late submission [A,B]:
The EIN number provided by the applicant could not be verified;
Total responses: 1.
Reason for late submission [A,B]:
Natural Disaster;
Total responses: 1.
Reason for late submission [A,B]:
Other[C];
Total responses: 22.
Source: As reported by GAO survey respondents.
[A] We asked survey respondents, "From the following list, what are the
3 most common reasons given by applicants for submitting late
applications for the period covering FY07-FY08?" and provided a list of
15 answers (including an "other" category) from which respondents could
choose. Total response is the number of grantor agencies that cited
this as the first, second, or third most common reason for late
submissions, not the number of times these reasons resulted in late
applications. Of the 74 survey respondents, 68 cited a first most
common reason, 66 cited a second most common reason, and 66 cited a
third most common reason. Percentages of respondents answering the
question are not provided because a respondent can answer more than one
category.
[B] Several of the reasons listed are external to the Grants.gov system
and beyond the control of the PMO.
[C] "Other" reasons, cited 22 times by 11 grantor agencies, included:
not applicable (9); no late applications (4); applicant confusion over
grant submission notice (3); no feedback mechanism from users to
grantor organization (3); external factors not listed (1); multiple
factors from list (1); and file too large to submit (1).
[End of table]
Grants.gov System Performance Has Limited Applicants' Ability to Submit
Timely and Complete Applications and Has Increased Applicant Burden:
In our July 2006 report and during the course of this review, we
identified continuing system unresponsiveness and other intermittent
system problems that at times limited applicants' ability to submit
timely, complete applications and that increase applicants' burden. As
shown above in table 3, system unresponsiveness is a top reason that
survey respondents gave for late applications. This problem primarily
arises before the deadline for a large grant or on days with numerous
grant closings, when the number of log-ins increases significantly. As
the system becomes overtaxed, grantees reported that they were
experiencing delays with (1) logging-in, (2) uploading
applications,[Footnote 33] and (3) determining if the upload was
successful. Applicants noted that they sometimes spend hours or days
trying to log-in, submit, and confirm receipt of their submissions. In
an effort to address system slowness, in February 2009 the PMO upgraded
the system to increase the capacity for simultaneous logins from 300 to
2000 users, but applicants continued to report problems with
application submission and logging-in, including after Recovery Act
grants were posted in March 2009. In mid-April 2009, Grants.gov
performed another upgrade that allowed applicants to track the status
of their applications without logging into Grants.gov; this was
intended to improve overall system performance and the ability to meet
the demands of Recovery Act submissions. Afterward, Grants.gov reported
that it successfully received 30,000 applications over an 8-day period
from April 20 to 27; nearly as many applications as it received during
March 2009. Still, on April 27, 2009, the closing date of a large NIH
Recovery Act grant and 28 other grant opportunities,[Footnote 34] the
Grants.gov blog[Footnote 35] reported that the Grants.gov system was
unable to receive applications for about 2 hours.[Footnote 36] Both HHS
and OMB told us that the problem was quickly identified and corrected,
and that no applications were excluded as a result of the system
outage. Further, as a result of the upgrade, the backlog of
applications to be validated rapidly increased, and it took 5 or more
days to validate applications; the problem was reported to be resolved
one week later.
Other reported intermittent system issues include software version
incompatibilities, missing and corrupted applications, and unexplained
error messages. In some cases, such system issues resulted in late or
incomplete applications or confusion about the status of applications.
* Software incompatibility. In late 2007 and 2008, Grants.gov
experienced problems transitioning to a new forms software package.
Applications prepared using an older version of the software were
incompatible with the newer version used by Grants.gov and, when
uploaded, were rejected. For example, in February 2008 a large state
university's application for an approximately $250,000 grant to provide
educational assistance to communities in Africa was rejected for this
reason. The grantee was unable to resubmit the application before the
application deadline and was unable to compete for the grant.
* Missing and corrupted attachments. We also identified instances when
grantees were unaware until after the deadline that attachments to
their applications were corrupted or not received by the grantor
agency, again resulting in missed opportunities to compete for grants.
[Footnote 37] In 2008 two organizations applying for $100,000 to
$250,000 grants to provide health services in rural communities were
denied consideration because attachments were not successfully
transmitted to the grantor agency, and despite evidence that they had
submitted the attachments with their application.
* Unexplained error messages. Between July 2008 and January 2009
applicants received unexplained error messages that left many grantees
unsure if their applications had been received or not. Applicants were
left without a "work around" for up to a week at a time as the
Grants.gov PMO and the IT contractor sought to understand the cause of
the error messages. In commenting on a draft of this report, OMB
officials told us that these problems have not recurred.
Applicants Experiencing Difficulties Described Contact Center
Assistance as Mixed:
The Grants.gov contact center, grantees' primary source of assistance
with the Grants.gov system, is not always able to help grantees,
especially during off-peak hours and peak submission periods. The
contact center can be reached by phone Monday through Friday from 7
a.m. to 9 p.m., eastern time (except federal holidays) or by e-mail;
the Grants.gov Web site generally accepts applications 24 hours a day,
7 days a week. The PMO has encouraged applicants to submit applications
during off-peak times to limit the strain on system resources.
Grants.gov users had mixed views on the quality of the service provided
by the contact center service; some said it was good while others
described it as inconsistent. Specifically, some users commented that:
1) the contact center was unable to solve their problems, 2) the
contact center incorrectly directed callers to the grantor agency, and
3) they had difficulty reaching the contact center during peak
submission periods.
In April 2009, the start of the Recovery Act peak application period,
the contact center was especially strained. Grants.gov officials and
applicants reported very high call volume and long wait times--
sometimes 30 minutes or more--because of the large numbers of
applicants seeking assistance. Although calls may be escalated to PMO
staff or the IT contractor, given the staff size, this is a limited
option on high volume days. Fewer than half of the 74 agencies
responding to our survey have help desks of their own, and those that
do may have more limited hours that the Grants.gov contact center and
are not intended to have in-depth knowledge of Grants.gov system
problems.
Delays in reaching the contact center are especially problematic
because they could hamper an applicant's ability to support a request
for an appeal. When applicants cannot submit timely applications
because of Grants.gov technical problems, grantor agencies may request
the applicant's case number that was given to them by the Grants.gov
contact center; this helps them to obtain details of the case and
confirm the technical problem.[Footnote 38] In February and March 2009,
the overall customer satisfaction rate was 89 percent and 87 percent
respectively (the target level is 90 percent or greater). From January
to April 2009 the contact center failed to meet several of its other
performance goals, such as the percentage of callers responded to
within 30 seconds (i.e., service level) and the percentage of callers
abandoning their attempt to reach the contact center (i.e., abandon
rate).[Footnote 39] In April and May the PMO increased the number of
phone lines and customer support representatives (CSR), and in May the
contact center surpassed its goals for all three measures.[Footnote 40]
Contact center customer satisfaction statistics are not collected on
callers specifically seeking assistance with the registration process
or submitting an application.
Accountability and Responsibility for Grants.gov Performance among the
Grants.gov Governance Entities Is Unclear:
As the day-to-day manager of the Grants.gov Web portal, the Grants.gov
PMO has primary responsibility for ensuring that the website is
operating properly and that its customers--applicants and grantor
agencies--are supported during the submission process. However, we
found that the PMO has been inconsistent in its efforts to meet these
responsibilities. Both grantees and grantor agencies stated that the
PMO is at times slow to identify and address system problems, leaving
grantees frustrated and uncertain of how to proceed when submitting
applications. Identifying problems has been challenging for the PMO
until very recently because system performance has been monitored
anecdotally; that is, through manual checks and customer complaints. In
March 2009, the PMO reported the use of new software to examine user
volume and in early June 2009 installed software to monitor system
performance.
Grantees and grantors also described problems with the adequacy of
system fixes; in some cases the problem was not fully resolved or new
problems arose as a direct result of the fix. For example, on the
Grants.gov blog in February 2009 the PMO noted that applicants were
having difficulty when logging in to the system. Shortly thereafter,
the PMO reported the problem had been resolved; however, several
grantees commented on the blog that they were still receiving the error
messages and could not login. In another case, when Grants.gov
transitioned to a new forms software package to address applicant
issues with the original software, grantees began to experience
rejected application submissions for applications completed using the
new software. The PMO subsequently determined that older versions of
the forms software were incompatible with the new forms. In addition,
end users also reported that the system's slowness increased after the
software change reportedly because the larger file size created when
using the new software meant that more system resources were needed to
transfer applications. Some agencies responded to these problems by
delaying their adoption of the new software or even reverting to forms
constructed using the old software.
Grants.gov lacks performance measures to track important aspects of its
performance. OMB described Grants.gov as a "cannot fail" system and
defined failure as system unavailability, poor performance to the point
of diminished usability, loss of data integrity, or any combination of
the three. Grants.gov's only performance measures that address system
performance are tied to customer satisfaction. Information for these
metrics is collected from a voluntary on-line survey that "pops up"
when grantees use Grants.gov. In May 2009, the customer satisfaction
score for the 3,690 respondents surveyed was 53 out of 100.[Footnote
41] Moreover, customer satisfaction of respondents whose primary reason
for visiting Grants.gov is to submit an application--the area of
Grants.gov in which problems are most likely to occur--is unknown
because the survey does not specifically measure it.
Untimely Agency Contributions Have Adversely Affected Grants.gov
Operations:
The Grants.gov PMO relies on voluntary contributions from the 26 grant-
making agencies to operate (see fig. 2); however, agencies do not
always pay in a timely manner, negatively affecting system performance
and, according to PMO officials, making it more difficult to plan for
the future. For example, in December 2008 Grants.gov had received only
2 percent of agencies' fiscal year 2009 contributions; by the end of
March 2009--halfway through the fiscal year--Grants.gov had only
received 37 percent of their annual contributions. Unable to pay its
vendors, the Grants.gov PMO developed a system shutdown plan and
implemented the first step of the plan--it eliminated Web site updates
and moved all notices to the blog. In February 2009, the PMO said that
unless it received its unpaid contributions by April 2009, it would be
unable to renew software licenses and would shut down Grants.gov.
[Footnote 42] In April 2009, OMB notified agencies that absent
immediate improvements, Grants.gov would be unable to handle the influx
of Recovery Act grant applications and requested agencies to
immediately submit any unpaid fiscal year 2009 contributions and to
provide additional funding to support system improvements.[Footnote 43]
As of June 26, 2009 the PMO received 88 percent of the total 2009
contributions and 72 percent of the total requested additional funding.
According to OMB, reasons for late or nonpayment include internal
agency issues and congressional limitations on agencies' use of funds
for E-Government initiatives.[Footnote 44]
Figure 2: Grants.gov Partner Agency Funding Structure, Fiscal Year
2009:
[Refer to PDF for image: illustration]
Grants Executive Board: Sets contribution rates based on size of agency
(Total: $12,985,569).
OMB: Requested FY 2009 additional contribution for system improvement
(Total: $6,000,000).
Extra large agency (based on discretionary grant dollars):
$1,899,755 per agency (Grants Executive Board);
($872,931) OMB;
Partner Agency: HHS.
Large agency (based on discretionary grant dollars):
$1,067,885 per agency (Grants Executive Board);
($493,131) OMB;
Partner Agencies: DOT, HUD, DoED, USDA.
Medium agency (based on discretionary grant dollars):
$517,763 per agency (Grants Executive Board);
($239,331) OMB;
Partner Agencies: DOL, USAID, DHS, NSF, EPA, DOD, DOJ, DOE, DOC, NASA,
DOI.
Small agency (based on discretionary grant dollars):
$129,299 per agency (Grants Executive Board);
($59,931) OMB;
Partner Agencies: CNCS, VA, IMLS, State, SBA, NEH, NEA.
Extra small agency (based on discretionary grant dollars):
$74,596 per agency (Grants Executive Board);
($34,131) OMB;
Partner Agencies: SSA, NARA, Treasury.
Total agency contributions to support PMO operations: $18,985,569.
Grants.gov Program Management Office (PMO) applies funding to program.
Source: GAO presentation of Grants.gov and OMB data.
Note: The GEB categorizes agencies as extra small, small, medium,
large, and extra large based on the agency's total discretionary grant
award dollars. That is, agencies with larger total discretionary grant
dollars contribute more to Grants.gov, and agencies with smaller total
grant award dollars contribute less to Grants.gov. As the largest grant-
making agency, HHS contributes the most funding. Since fiscal year
2007, the annual Grants.gov budget has been between about $13 to $13.4
million. The 26 agencies in figure 2 are the: Department of Health and
Human Services (HHS), Department of Transportation (DOT), Department of
Housing and Urban Development (HUD), Department of Education (DoED),
United States Department of Agriculture (USDA), National Science
Foundation (NSF), Department of Labor (DoL), Environmental Protection
Agency (EPA), Department of Commerce (DoC), United States Agency for
International Development (USAID), Department of Defense (DoD),
National Aeronautics and Space Administration (NASA), Department of
Homeland Security (DHS), Department of Justice (DoJ), Department of the
Interior (DoI), Department of Energy (DoE), Institute of Museum and
Library Services (IMLS), Corporation for National and Community Service
(CNCS), Department of State (State), National Endowment for the
Humanities (NEH), Department of Veterans Affairs (VA), Small Business
Administration (SBA), National Endowment for the Arts (NEA), Social
Security Administration (SSA), National Archives and Records
Administration (NARA), and Department of the Treasury (Treasury).
[End of figure]
The GEB selected Grants.gov's funding model after considering several
different alternatives. OMB staff said that they monitor the funding
status of all E-Government initiatives and that they ask program
managers to notify them of any funding issues that could potentially
affect performance. OMB staff stated that they recognize the challenges
the PMO faces in compelling agencies to pay on time, but that with
proper management such risks can be greatly mitigated. They added that
other E-Government initiatives face similar challenges but still run
successful systems with higher levels of customer satisfaction, such as
Business Gateway [hyperlink, http://www.business.gov] and GovBenefits
[hyperlink, http://www.govbenefits.gov].
Coordination among Grants.gov Governance Entities Is Inconsistent:
Given the number of entities with management and oversight
responsibilities for Grants.gov, clear roles and responsibilities for
each and coordination among these entities is critical. For example,
the GEB and HHS's OCIO share responsibility for reviewing and approving
major changes to, and funding for, the Grants.gov system, but there is
little evidence that the GEB-approved funding for Grants.gov is
considered in HHS's review of Grants.gov as an IT investment. In
accordance with OMB's guidance on Planning, Budgeting, Acquisition, and
Management of Capital Assets,[Footnote 45] HHS--as the Grants.gov
managing partner--is to manage Grants.gov as an IT investment through
HHS's Capital Planning and Investment Control (CPIC) process, which
includes reviewing and approving Grants.gov's budget and major
initiatives. However, the annual fiscal year 2008 Grants.gov status
report--the documentation provided to us by the OCIO as evidence of
OCIO's CPIC oversight of Grants.gov--discusses neither major operating
changes, such as the GEB-approved July 2008 decision to move to "cloud-
based computing"[Footnote 46] nor concerns about Grants.gov's fiscal
difficulties. As early as 2002, Grants.gov noted that concerns about
lack of timely contributions could hamper Grants.gov's ability to
complete project milestones but the 2008 status report notes this risk
as medium, and the status as managed.
Officials from the PMO and HHS acknowledged that Grants.gov governance
could be improved; it appears that some progress has been made in this
area. PMO officials told us that since December 2008 they have had more
interaction with the OCIO's office and that in March 2009, a former
OCIO official became the acting Grants.gov program manager. However, an
official in HHS's Office of Grants (the office responsible for
Grants.gov) told us that Grants.gov has matured considerably since its
inception in 2003 and would benefit from a better defined governance
structure. For example, she noted that HHS's role as managing partner
is not well-defined and that while more clarity would benefit
Grants.gov, the managing partner role should be flexible enough to
permit it to evolve over time as circumstances change. Others have also
noted the need to better define the relationship among and
responsibilities of the Grants.gov governance bodies. For example, in
the fall of 2008 the National Grants Partnership (NGP) sent specific
recommendations to the Obama-Biden Transition Team highlighting the
need to better coordinate the activities of Grants.gov with the policy
recommendations of the Grants Policy Committee.[Footnote 47]
There are no written policies or procedures for how the OCIO, the
Grants.gov PMO, and the GEB are to work with each other to ensure
system performance, resulting in confusion about roles,
responsibilities, and accountability; and concerns about duplication of
efforts that could hamper short-term efforts to make urgent
improvements to Grants.gov and longer-term efforts to improve service.
OMB's March and April 2009 memos to executive branch agencies on
improving Grants.gov included steps to prevent an impending Grants.gov
system failure, but these memos did not seek to clarify the roles of
the various governance entities. The memos also noted that GSA--the
governmentwide facilitator of E-Government solutions--would work with
HHS to initiate immediate improvements to the Grants.gov system and
assist with alternatives for select agencies while also identifying
longer-term approaches to improve Grants.gov service delivery; this
resulted in concerns about the future of Grants.gov. In commenting on a
draft of this report, OMB clarified that GSA has taken on a parallel
effort to conduct a pilot system as a "proof of concept" and is not
working with HHS on the Grants.gov system or building an active
alternative system. They further noted that they have clarified GSA's
role with all parties, including HHS and the GEB, in follow-up
discussions.[Footnote 48] Finally, OMB said that it is clear to OMB
that HHS is the entity responsible and accountable for the operation of
Grants.gov, and that the PMO and GEB merely support HHS in managing the
system.
Grantees Continue to Lack Opportunities to Provide Structured Input on
the Grants.gov System:
Grantees lack opportunities to provide upfront, structured input on
Grants.gov, which limits the ability of Grants.gov governance entities
to obtain valuable customer input on a system meant, in part, to ease
applicant burden. GEB bimonthly meetings are closed to the public, and
the HHS OCIO does not have a forum for obtaining external input on
Grants.gov. Instead, the GEB and HHS OCIO rely on the PMO to provide
information on system performance and issues affecting Grants.gov. The
PMO has an Integrated Change Board that considers proposed changes to
Grants.gov, but none of its members are grantees.[Footnote 49] The
Grants.gov blog and Grants.gov quarterly stakeholder Web casts allow
limited two-way communication between the PMO and grantees while the
Grants.gov blog provides daily information on system status, but
neither of these provide for regular, systematic grantee input on
issues such as proposed technical changes, system performance, funding,
and governance.
In our 2006 report on grantees' concerns with efforts to streamline
grants management, we said that some Grants.gov technical issues may
have been resolved more quickly if communication with grantees had been
greater and concluded that Grants.gov has no systematic way to get
grantees' views as it develops and proposes changes.[Footnote 50]
Grantee associations continue to echo those sentiments and are still
seeking opportunities to discuss their concerns about Grants.gov. For
example, in March 2009 the Association of American Universities (AAU)
and the Council on Governmental Relations (COGR) wrote a joint letter
to OMB requesting a meeting to discuss the need for short-and long-term
enhancements to Grants.gov, especially in light of anticipated problems
with Recovery Act applications.[Footnote 51] According to OMB
officials, OMB and COGR have twice been in contact and are in the
process of scheduling this meeting. COGR officials and officials from a
major research university also contacted us and discussed their
concerns.[Footnote 52]
The PMO has taken some steps to get the perspective of the grantee
community. In May 2007, the Grants.gov program manager described plans
to involve end-users (both grantees and grantors) as changes were made
to the Grants.gov system[Footnote 53] and noted that the PMO would
implement these plans once OMB approved the plan and ensured that it
would comply with the Federal Advisory Committee Act (FACA).[Footnote
54] In February 2009, the Grants.gov program manager met with officials
from the Federal Demonstration Project (FDP),[Footnote 55] a grantee
association representing academic research institutions and others, to
obtain informal input on issues that FDP constituents encounter with
Grants.gov as well as how Grants.gov could be improved. After that
meeting the program manager confirmed the PMO's intent to create a user
group that could give systematic, across-the-board input on Grants.gov
issues. He said that this type of input is important because applicant
groups have the most exposure to using the system and are often the
most knowledgeable about what problems exist and how to address them.
However, he noted that it was difficult to reconcile the goals of
Public Law 106-107, which calls for input and advice from the applicant
community, with FACA's requirements for agencies seeking to obtain
advice and recommendations from nonfederal employees. Both agency and
OMB officials have described these requirements as restrictive.
As we have previously reported, federal agencies have a reasonable
amount of discretion with regard to creating committees, drafting their
charters, establishing their scope and objectives, classifying the
committee type, determining what type of advice they are to provide,
and appointing members to serve on committees. Further, we have said
that members appointed to advisory committees as representatives--as
opposed to special government employees--are expected to represent the
views of relevant stakeholders with an interest in the subject of
discussion, such as an industry, a union, an environmental
organization, or other such entity.[Footnote 56] GSA has promulgated
regulations for federal agencies to follow when implementing FACA.
[Footnote 57] These regulations explicitly note that groups assembled
to provide individual advice rather than group consensus (e.g., public
town hall style meetings or meetings of experts where they are not
expected to reach consensus but rather share individual opinions and
advice) are not subject to FACA requirements.
Disparate Agency Policies for Processing Grant Applications Can Result
in Different Treatment for Applications Submitted through Various
Means:
Grantor agencies vary in the closing times they set for their grant
opportunities. While Grants.gov accepts applications until midnight
eastern time on a grant's closing date, about one-third of the
responding grantor agencies we surveyed had grant opportunity closing
times before midnight--often between 4 p.m. and 5 p.m. eastern time.
[Footnote 58] For example, NIH, the largest grantor agency, has a 5:00
p.m. local time closing time 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) when the Grants.gov system
is not experiencing overload issues.[Footnote 59] Some agencies
unofficially provide applicants leeway on meeting the deadline closing
time. For example, two grantor agencies said that though they do not
advertise the fact to applicants, they will accept applications that
arrive by midnight of the deadline date although the official closing
time is earlier.
Different closing times across agencies reportedly caused confusion
among applicants. Several association representatives told us that it
would ease applicant burden if there were a universal deadline across
the federal government. Several suggested that agencies should
coordinate their deadline times with Grants.gov so that it is not
possible for a late application to be accepted by the Grants.gov
system. Despite some discussions about this issue by agency
representatives on the Grants Policy Committee--which has
responsibility for recommending standard and streamlined federal-to-
grantee business processes--it has been unable to come to agreement on
a standard governmentwide closing time. Several of the agency officials
we spoke with stated that there is no technical reason why a standard
closing time could not be set.
Agencies Have Different Policies for Determining the Timeliness and
Completeness of Grants.gov Applications:
Agency policies vary in determining whether applications submitted
through Grants.gov are timely and complete. This sometimes results in
applications' being deemed late or incomplete, even though an applicant
may receive confirmation from Grants.gov that the application was
successfully submitted. These policies may not apply to applications
submitted outside of Grants.gov.
* Timeliness. 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
60] However, validations can take up to 48 hours after an application
is successfully submitted and on some occasions may take longer;
[Footnote 61] this has resulted in late submissions.[Footnote 62] For
example, in 2006 a university whose application failed the validation
process was unable to resubmit the application before the deadline and
lost about $1 million in grant funding. As a result, the university was
unable to continue a program serving over 200 inner-city youth that it
had administered for 12 years. In contrast, applications submitted by e-
mail or mailed in hard copy are not subject to Grants.gov validation.
Instead, agencies use other means to establish the timeliness of these
submissions. For example, the postmark[Footnote 63] or the arrival date
is often used to determine the timeliness of paper applications.
* Completeness. Some agencies require applicants to submit attachments
to the grant application in a particular file format; however, the
Grants.gov system cannot determine whether an application is in the
correct format or as discussed earlier, if attachments are properly
transmitted to the agency. For example, NIH requires applicants to
submit attachments in Pure Edge or Adobe PDF file formats, and cautions
applicants that other file formats are not acceptable, even though
Grants.gov appears to accept these other formats. The National Science
Foundation (NSF) may also reject applications if the attachments are
not in certain file formats. Applicants submitting paper applications
do not have to be concerned about file formats or transmission
problems. Association representatives told us that requiring different
file formats is burdensome for applicants.
Agencies Differ in Notifying Applicants When and Whether Applications
Have Been Successfully Submitted through Grants.gov:
Although the Grants.gov system notifies applicants via e-mail when
their applications have been accepted or rejected, there are no common
requirements for grantor agencies to notify applicants whether they
consider the applications to be timely and complete. More than half of
the agencies responding to our survey (39 respondents) said they notify
an applicant "immediately or almost immediately" when an application is
late and will not be forwarded for content review. Forty agencies said
that when an application had "missing elements," they notified
applicants "immediately or almost immediately." For example, EPA's
grant submission policies state that an applicant must be informed that
their application was rejected because of "a failure to meet the
eligibility threshold" within 15 calendar days of receipt by the
agency. According to EPA officials, 15 days is very early in the grant
processing cycle, thus providing applicants sufficient time to appeal.
In contrast, 13 respondents said that when an application is late they
either wait until the time that the grant is awarded to notify
applicants or do not notify applicants at all. Fourteen respondents
said that when an application has "missing elements" they either do not
notify applicants about incomplete applications or wait until the
rejection letter goes out.[Footnote 64] Lack of notice, or untimely
notice, can eliminate an applicant's chance to appeal a late or
incomplete determination.
Further, an applicant's ability to determine the timeliness and
completeness of an application varies depending on how the application
was submitted. For example, applicants who mail hard copies of
applications know what they put into the envelope--and what it looks
like--and can choose to track their applications through the U.S.
Postal Service (USPS) or commercial delivery service. Conversely,
applicants who 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. In addition, these applicants may be unable to determine if the
entire contents of their application, including necessary attachments,
were successfully submitted without corruption.
Agencies Have Different Criteria for Considering Appeals, Sometimes Not
Considering the Most Common Reason for Late Submissions:
If a grantor agency determines that an application is late or
incomplete, 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 who provided data about appeals based on registration
difficulties said that appeals on this basis were more likely to be
denied than approved. In one case, an applicant provided evidence that
he worked with the Grants.gov contact center to resolve a registration
problem before the submission deadline, but as he was unable to
register in time, this was not allowable grounds for appeal for a late
application. 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. For applications deemed
incomplete, 50 of the 74 grantor agencies that responded to our survey
said that an applicant can dispute or appeal at least some of the time
if a submission is determined to be incomplete. Some of these agencies
allow applicants to provide the missing information after the deadline,
if that information is required solely for processing the application
and will not affect the substantive content of the application. In
contrast, 16 agencies said that applicants cannot appeal incomplete
applications and that these applications will not be included during
the competitive process.[Footnote 65]
Agencies Vary in the Extent to Which They Assist Applicants Facing
Difficulties when Submitting through Grants.gov:
In response to the recurring difficulties with the Grants.gov system,
some agencies have made efforts to assist Grants.gov applicants by
adjusting their policies on: 1) submission methods, 2) deadline grace
periods, and 3) appeals processes.
* Submission methods. Of the 74 agencies responding to our survey, 47
normally require their grantees to use Grants.gov to apply for most to
all grants. However, more than half of our respondents will accept
applications through agency specific electronic systems, by e-mail, or
mail, under at least some circumstances, such as when Grants.gov is
experiencing system problems.[Footnote 66] One grantor agency began
requiring all applicants to submit a hardcopy of their application in
addition to applying through Grants.gov to avoid system delays and
other problems.
* Deadline grace periods. Some grantor agencies reject applications
with a timestamp that is one second after the announced deadline;
others have instituted a grace period. For example, the U.S. Department
of Housing and Urban Development (HUD) officials told us that for
fiscal year 2009 they implemented a one-day grace period for applicants
who submit on time but fail the Grants.gov validation process; this
allows applicants time to resubmit their applications. NIH has also
instituted policies to accommodate applicants who encounter technical
problems with Grants.gov, even if the process of resolving the
technical issue extends past the due date.
* Appeals processes. Some agencies have also instituted formal appeals
processes to specifically accommodate Grants.gov system issues. HUD
established a "quality assurance review" process, published in the
Federal Register, which states that applications submitted by grantees
who followed all of the application procedures and were unable to apply
successfully through Grants.gov because of unanticipated technical
problems, the forms software package, or Grants.gov error messages will
be considered.[Footnote 67] NIH set up a system to hear and resolve
complaints and appeals well before awards are made.
Grantees Continue to Lack a Means for Structured Input into
Governmentwide Grant Application Policies:
In a July 2006 report, we concluded that action was still needed to
ensure that grantees have adequate input early in developing solutions
on grants streamlining, and recommended that the Grants Policy
Committee and the GEB develop and implement approaches to soliciting
grantee input on an ongoing basis. As of October 2008, the Grants
Policy Committee said they were considering how to involve the grantee
community as policies are being developed. During our current review,
grantee associations continued to express the need for early input into
policies that could help streamline and standardize grants policies
governmentwide, such as those mentioned in this report, in order to
improve the grant application experience for applicants and reduce
applicant burden.
Conclusions:
The Recovery Act has highlighted the importance of Grants.gov in
ensuring the flow of grant funds to struggling communities and
organizations around the country. Over the past several months, OMB and
the Grants.gov staff worked quickly to mitigate an impending system
failure in the short-term. As the Grants.gov governance entities begin
to consider longer-term improvements to Grants.gov, now is the time to
reconsider whether Grants.gov's performance measurement efforts, its
management structure, the current ad-hoc methods for obtaining
stakeholder input, and disparate agency policies for processing grant
applications will help or hinder Public Law 106-107's goals of
simplifying and streamlining grant administration.
Grants.gov's performance measures do not provide a clear picture of
system performance or how well applicants are being served. Absent
measures that track the health of the system against OMB's definition
of system failure, gaps in performance information will persist.
However, collecting performance information is not enough; unless this
information is used to inform decision making, the Grants.gov
governance bodies will lack a valuable management tool for developing
strategies to better achieve results.
GEB provides strategic direction and oversight, while HHS, as managing
partner, is expected to take the necessary steps to resolve concerns
and issues raised at GEB meetings. However, inconsistent coordination,
unclear lines of authority, and confusion over roles and
responsibilities have contributed to system unreliability at critical
points in the application submission process and, if not addressed,
could threaten distribution of Recovery Act grants in the short-term
and risk the system's long-term performance. Finally, until HHS better
links its review of Grants.gov as an IT investment with the GEB's
review and approval of Grants.gov's budget and funding mechanism, HHS
will have difficulty weighing the relative costs and benefits of
Grants.gov and lack assurances that adequate funding is in place to
support the level of capital investment desired.
As managing partner for Grants.gov, HHS continues to lack a systematic
way to obtain grantees' views on proposed changes to the Grants.gov
system; the Grants Policy Committee continues to lack such a mechanism
as it implements policies to streamline federal-to-grantee business
processes. If grantees remain isolated from the development of systems
and policies that directly affect them, the systems and policies will
be less effective, and opportunities to better streamline the
application process will be missed.
Finally, inconsistent agency policies relating to, for example,
application deadlines and notifications both increase applicant burden
and, in some cases, disadvantage applicants who submit applications
through Grants.gov as compared to applicants who submit applications
using other electronic systems, e-mail, the USPS, or a commercial
delivery service. Further, some agencies do not recognize Grants.gov
registration issues and technical issues such as system
unresponsiveness--problems identified by our survey respondents as
among the most common causes of late applications--as a valid basis for
appeal. On the other hand, some agencies have successfully modified
their policies to reflect these types of applicant challenges; these
efforts could be a starting point for considering consistent,
governmentwide policies in these areas and could assist the Grants
Policy Committee in its efforts to develop policy proposals for
streamlining and simplifying the pre-award stage of the grants life
cycle.
Recommendations for Executive Action:
We are making the following four recommendations to the Director of OMB
to increase the effectiveness and long-term viability of Grants.gov:
* OMB should (1) work with HHS to develop performance measures related
to system availability, usability, and data integrity and (2) direct
HHS and the Grants.gov PMO to review performance results on a regular
and recurring basis and communicate decisions based on performance
information to show that performance information is reviewed and acted
upon.
* OMB should work with HHS to develop guidance that:
- ensures that the Grants.gov budget and funding model adopted by the
GEB adequately supports the package of Grants.gov IT services approved
through the HHS CPIC process;
- clearly defines the roles and responsibilities of the GEB, HHS OCIO,
and Grants.gov PMO with respect to Grants.gov, including how these
entities are to coordinate with each other to resolve Grants.gov system
issues; and:
- addresses GSA's role and specific responsibilities in developing
approaches for longer-term Grants.gov solutions.
* OMB should work with HHS and other stakeholders as appropriate to
identify and implement a Grants.gov "applicant user group" or other
systematic, periodic approaches for obtaining grantees' input on
changes and improvements to Grants.gov system.
* OMB should work with HHS, the Grants Policy Committee, and other
stakeholders as appropriate to identify and implement, to the extent
permissible by law, governmentwide policies for processing grant
applications, with the goals of minimizing applicant confusion and
burden and creating a level playing field for all application
submissions, no matter the submission method. These policies could
address:
- criteria for what constitutes a timely and complete application;
- notifications grantor agencies provide applicants when an application
has been received or been deemed late or incomplete;
- criteria for granting appeals for applications deemed late or
incomplete; and:
- the Grants.gov registration process.
In doing so, OMB should also ensure that grantees have a structured,
ongoing means to provide input on the development and implementation of
governmentwide grant application policies and procedures such as those
mentioned above.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Director of the Office of
Management and Budget and the Secretary of the Department of Health and
Human Services. OMB staff provided us oral comments and generally
agreed with our overall findings and recommendations. OMB staff stated
that it is the responsibility of HHS as the managing partner agency to
manage system requirements and development for Grants.gov, and that the
PMO, GEB, and Grants Policy Committee are merely resources that HHS
uses to assist it with its management responsibility. Given where
Grants.gov is in its useful life cycle, OMB staff said that they do not
foresee any system changes beyond those needed to keep the system
stable and operational, and that Grants.gov should be in an operations
and maintenance mode until requirements for a new system are developed.
OMB staff also provided technical comments that were incorporated as
appropriate.
In written comments, the HHS Acting Assistant Secretary for Legislation
concurred with our overall findings and recommendations and suggested
additions to our recommendation on governmentwide grant policies; we
agree with HHS and clarified our fourth recommendation. HHS's written
comments are reprinted in appendix II. Key comments include that
"systemic issues remain regarding standardization of grants application
policies and procedures across the federal government and the
Grants.gov governance and funding model" and "the Grants.gov system
funding model is institutionally biased against investing adequate
resources in system improvements and could benefit from review." In
addition, HHS provided an update on Grants.gov activities since April
2009 and said that operations have been essentially normal since that
time, with NIH receiving more applications per hour than ever before
through Grants.gov. Technical comments and suggested edits were
incorporated where appropriate.
We are sending copies of this report to the Director of the Office of
Management and Budget, 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].
If you or your staff have any questions regarding this report, please
contact me at (202) 512-6806 or by e-mail at 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 are listed in Appendix III.
Signed by:
Stanley J. Czerwinski:
Director:
Strategic Issues:
[End of section]
Appendix I: Detailed Survey Description:
We conducted a Web-based survey of federal grant-making agency
officials to obtain information on 1) agency policies and practices
with respect to competitive grant application submissions, and 2)
agency experiences assisting grant applicants who have had problems
while using Grants.gov. Our background research indicated that agency
officials are knowledgeable about agency grant application policies and
have experience assisting grantees who are trying to submit
applications through Grants.gov. We did not survey grantees because of
the difficulty and resources needed to identify and sample the
thousands of grantees who have submitted or attempted to submit
applications using Grants.gov.
To design the survey, we reviewed documentation from the Grants.gov PMO
and grant-making agencies and interviewed agency grant officials to
gain an understanding of 1) agency grant application policies and
procedures and 2) their knowledge of applicant experiences using
Grants.gov. We worked with a social science survey specialist to design
a draft survey instrument and then pre-tested the instrument with five
grant-officials from five different agencies to ensure that the
questions were clear and unbiased and that the survey could be
completed in a reasonable amount of time. We made revisions to the
survey instrument in response to each of the pre-tests and presented a
final draft to the Grants Executive Board (GEB) members for expert
review; they suggested minor changes that were incorporated.
To identify the population of federal "grantor agencies" to survey, we
asked the 26 members of the GEB to identify all organizations within
their agency that have established distinct grant application policies
for competitive, discretionary grants and to provide us a contact
person within the grantor agency who would be responsible for
responding to the survey. This was necessary because policies for
processing grant applications can be centralized at the agency level or
can differ within an agency by subagency or program office. With
knowledge of a particular agency, the 26 GEB members (or their
designees) provided us contact information for officials from 86
grantor agencies, and the survey was provided to those individuals
during the first week of December 2008. During December 2008 and
January 2009, we sent three e-mail reminders to and in some cases
telephoned nonrespondents, asking them to complete the survey. We
eliminated six of the respondents from the population after discussions
led us to determine that 1) their grantor agency does not offer
competitive, discretionary grants or 2) we had received contact
information for multiple respondents from the same grantor agency. The
final population of 80 respondents represents the universe of grantor
agencies with distinct grant application policies. When the survey
closed on January 29, 2009, we had received responses from 74 of the 80
grantor agencies that offer competitive grants for a response rate of
92.5 percent.
Data analysis of the survey was conducted by a GAO data analyst working
directly with the GAO staff with subject matter expertise. Since this
was a Web-based survey, respondents entered their answers directly into
the electronic questionnaire, eliminating the need to key data into a
database, minimizing error. When the data were analyzed, a second
independent data analyst checked all computer programs for accuracy.
Because this was not a sample survey, it has no sampling errors.
However, the practical difficulties of conducting any survey may
introduce errors, commonly referred to as nonsampling errors. For
example, difficulties in interpreting a particular question, sources of
information available to respondents, or entering data into a database
or analyzing them can introduce unwanted variability into the survey
results. We took steps in developing the questionnaire, collecting the
data, and analyzing them to minimize such nonsampling errors. It should
be noted that some grantor agencies' policies on the allowable methods
for submitting applications currently differ from their original survey
responses because of OMB's memo of March 9, 2009, instructing agencies
to identify alternatives to Grants.gov for accepting grant applications
during the Recovery Act's peak filing period, estimated by OMB to be
April through August 2009.
[End of section]
Appendix II: Comments from the Department of Health and Human Services:
Department Of Health and Human Services:
Office Of The Secretary:
Assistant Secretary for Legislation:
Washington, DC 20201:
June 16, 2009:
Stanley J. Czerwinski:
Director, Strategic Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear. Mr. Czerwinski:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's draft report entitled, "Grants Management:
Grants.gov Has Systemic Weaknesses That Require Attention" (GAO-09-
589).
The Department appreciates the opportunity to comment on this draft
report before its publication.
Sincerely,
Signed by:
Barbara Pisaro Clark:
Acting Assistant Secretary for Legislation:
Enclosure:
[End of letter]
Comments Of The U.S. Department Of Health And Human Services To The
Government Accountability Office's (GAO) Draft Report Entitled. "Grants
Management: Grants.Gov Has Systemic Weaknesses That Require Attention"
(GAO-09-589):
HHS concurs with the overall findings and recommendations of the draft
GAO Report.
Update on Grants.gov Activities since April 2009:
While the Report accurately reflects many of the performance problems
faced by users of Grants.gov through early 2009, HHS has devoted
tireless attention to the systemic weaknesses highlighted in the report
to dramatic effect. Interim improvements to enhance system performance
enabled Grants.gov to successfully handle the largest grant opportunity
related to ARRA, NIH's Challenge Grant; receiving over 30,000
applications in an 8-day period in April; including 8,400 applications
on April 27-alone. Although the GAO report accurately notes there was a
short two hour period at the end of the day in which applications could
not be received by the Grants.gov system, the problem was quickly
identified and corrected, and no grantee applications were excluded due
to the system outage. Operations have been essentially normal since
that time. HHS is currently beginning implementation of a 60-day
"boost" initiative that will further stabilize the Grants.gov system
and increase its reliability and ability to sustain expected grant
activity into the future.
Summary of Key Comments:
Page 24 and Page 31, Item 1: HHS believes that systemic issues remain
regarding standardization of grants application policy and procedures
across the Federal government and the Grants.gov governance and funding
model. HHS concurs with GAO that it is important to develop a standard
protocol for Federal grantors "accepting" grantee applications, and
recommends establishing a standard process and approach for submitting
grant applications which takes advantage of current technology and
minimizes the number of different forms required. The multiplicity of
application forms contributes to difficulty in defining system
requirements, optimizing the capacity of the system, and running an
efficient operations and maintenance program.
Page 32, Item 2a: Additionally, HHS observes that the Grants.gov system
funding model, which requires devoting considerable resources
throughout the entire fiscal year to collect annual funding
contributions from 26 agencies, is institutionally biased against
investing adequate resources in system improvements and could benefit
from a review. One alternative could be a more established source of
funding such as an annual appropriation in order to avoid the perpetual
financial challenges associated with maintaining and upgrading this
vital government-wide system.
HHS offers the following specific comments and edits for your
consideration:
Grants.gov Registration is Complex and a Common Reason for Late
Submissions:
Page 11, Table 2: Registration delays are acknowledged and are due to
the current mandate from the Grants Executive Board (GEB) to have the
Grants.gov system verify the responsibility and authority of the
applicant to submit an application at the time an application is
submitted rather than later in the process (the pre-award stage). In
January 2009, the Grants.gov Program Management Office (PMO)
recommended to the GEB an alternative process that would defer the
applicant verification activities to the agency level versus the
Grant.gov system level. The GEB elected to stay with the existing
registration process.
Reason for Late Submission:
Page 12, Table 3: HHS recommends that GAO clarify that the reasons
listed in Rows 4, 7, 10, 11, 12 and 14 on why prospective grantees
submit late applications, are external to the PMO and the Grants.gov
system and outside the scope of its control.
Accountability and Responsibility for Grants.gov Performance among the
Grants.gov Governance Entities is Unclear:
Page 17, 2nd paragraph: HHS recommends that GAO update its text to
indicate that following a year long transition, in March 2009, the
Grants.gov PMO decommissioned the system/servers using the original
forms software, "PureEdge," therefore future issues of this nature are
unlikely.
Section on "Coordination among Grants.gov Governance Entities"
Page 20: While HHS believes that its current Capital Planning and
Investment Control (CPIC) process is designed to ensure that Grants.gov
is required to meet the same accountability and reporting requirements
as enterprise HHS IT investments, HHS would agree that it is important
to continue to enhance internal coordination within the Department.
Recommendations for Executive Action:
Page 31, Item 1: One additional suggestion would be that the Executive
Branch should work with Grants.gov governance entities and policy
makers to streamline/standardize grant application processes, reduce
the number of electronic forms used by prospective grantees, and
identify concrete, functional system requirements that reflect user
needs and take advantage of current technological advances.
Technical Comments Page 12, line 7:
..."complete the application process" should be changed to "actually
submit the application". For NIH, submission to Grants.gov does not
complete the application process.
Page 14, end of first paragraph:
It is worth mentioning that the Grants.gov built the weekend after the
April 27 deadline took care of the problem with slow application
processing. NIH is receiving more applications per hour than ever
before from Grants.gov.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Stanley J. Czerwinski (202) 512-6806 or czerwinskis@gao.gov:
Acknowledgments:
In addition to the contact named above, Thomas James, Assistant
Director; Jacqueline M. Nowicki, Assistant Director; and Jennifer
Ashford managed this assignment. Carolyn Boyce, James J. Burns, David
Fox, Carol Patey, and James R. Sweetman, Jr., made major contributions.
Cynthia Grant and Luann Moy provided methodological assistance; Shirley
Jones provided legal assistance; and Donna Miller developed the
report's graphics.
[End of section]
Footnotes:
[1] [hyperlink, http://www.grants.gov/].
[2] Pub. L. No. 111-5 (Feb. 17, 2009). Recovery Act funds are being
distributed to states, localities, other entities, and individuals
through a combination of formula and competitive grants and direct
assistance. Nearly half of the approximately $580 billion associated
with Recovery Act spending programs will flow to states and localities
affecting about 50 state formula and discretionary grants as well as
about 15 entitlement and other countercyclical programs. For Recovery
Act grant opportunity postings, see [hyperlink,
http://www.grants.gov/applicants/recovery.jsp] (accessed as of July 6,
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). For other OMB guidance related to Grants.gov, see
Office of Management and Budget, Improving Grants.gov, M-09-17
(Washington, D.C.: Apr. 8, 2009).
[4] Alternative 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.
[5] GAO, Recovery Act: Consistent Policies Needed to Ensure Equal
Consideration of Grant Applications, [hyperlink,
http://www.gao.gov/products/GAO-09-590R] (Washington, D.C.: Apr. 29,
2009).
[6] OMB estimated the peak filing period to be April to August 2009.
[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. The Grants Policy
Committee coordinates all federal grants policy recommendations to OMB.
OMB provides oversight and guidance to Grants.gov and the other 23 E-
Government initiatives.
[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
among and within the 26 grant-making agencies. We identified 80
"grantor agencies" that have distinctive grant application policies.
[9] The 74 responses we received were from all of the 26 grant-making
agencies.
[10] 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.
[11] GAO, Grants Management: Additional Actions Needed to Streamline
and Simplify Processes, [hyperlink,
http://www.gao.gov/products/GAO-05-335] (Washington, D.C.: Apr. 18,
2005) and GAO, Grants Management: Grantees' Concerns with Efforts to
Streamline and Simplify Processes, [hyperlink,
http://www.gao.gov/products/GAO-06-566] (Washington, D.C.: July 28,
2006).
[12] Office of Management and Budget, E-Government Strategy
(Washington, D.C.: Feb. 27, 2002).
[13] The five stages of the grant life cycle are: 1) announcement (pre-
award), 2) application (pre-award), 3) award, 4) postaward, and 5)
closeout.
[14] OMB requires agencies to announce all discretionary grants
opportunities on Grants.gov; although agencies may apply for waivers
from OMB. OMB does not require agencies to accept applications through
Grants.gov.
[15] Applications must be downloaded to the applicant's computer,
completed, and uploaded to the Grants.gov system. Applicants are not
required to be connected to the Internet when completing applications.
[16] 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.
[17] Projects on OMB's IT High Risk List are not necessarily at risk of
failure; rather, because they meet certain criteria specified by OMB,
they are to receive special attention from oversight authorities and
the highest levels of agency management. "Program or program management
office activities supporting governmentwide common solutions" is one
criterion, as is "major systems formally designated as an E-Government
or Line of Business shared service provider."
[18] In addition, four other portfolios were designated: government-to-
citizen, government-to-business, internal efficiency and effectiveness,
and cross-cutting. Each portfolio had a manager and each of the
initiatives was included under one of the five portfolios.
[19] GAO, Electronic Government: Funding of the Office of Management
and Budget's Initiatives, GAO-05-420 (Washington, D.C.: Apr. 25, 2005).
[20] Some agencies use agency-specific grant application forms; the PMO
is not responsible for managing the process to update these forms.
[21] The CFO Council--the CFOs and Deputy CFOs (DCFO) of the largest
federal agencies and senior officials of the Office of Management and
Budget and the Department of the Treasury--work collaboratively to
improve financial management in the U.S. Government.
[22] See [hyperlink,
http://www.cfoc.gov/index.cfm?function=grant_governance] (accessed July
6, 2009).
[23] Pub. L. No. 107-347, Dec. 17, 2002, codified at 44 U.S.C. §§
3602(a)-(g).
[24] Pub. L. No. 104-106, Division E, Feb. 10, 1996, codified at 40
U.S.C. §§ 11101-11704.
[25] 40 U.S.C. §§ 11312 - 11313.
[26] 40 U.S.C. §§ 11302 - 11303.
[27] This policy is set forth in OMB Circular A-11 (section 300) and in
OMB's Capital Programming Guide (supplement to Part 7 of Circular A-
11).
[28] Grants.gov processed 180,861 submissions in fiscal year 2007 and
202,366 submissions in fiscal year 2008.
[29] On March 9, 2009, OMB instructed federal grant-making agencies to
identify alternate methods for accepting grant applications during the
Recovery Act peak filing period, which is estimated to last from April
through August 2009.
[30] Applicants applying as individuals (not as part of an
organization) must also register with Grants.gov before applying for
grants but follow different procedures to register and then can only
apply for grants open to individuals. In our survey, 32 percent (24) of
the 74 respondents stated that they offer grants to individuals.
[31] See [hyperlink, http://www.gao.gov/products/GAO-06-566], p. 19-21.
This report discusses grantee difficulties with multiple Data Universal
Numbering System (DUNS) numbers, the Central Contractor Registration
process, and the time it takes to complete the registration process.
[32] In our survey, 20 of 74 grantor agencies (27 percent) reported
that they always allow paper applications and 32 of 74 grantor agencies
(43 percent) have accepted e-mailed applications.
[33] The Grants.gov submission process differs from web-based
applications, which are completed and saved while the applicant is
connected to the Internet and do not have to be uploaded.
[34] Grants.gov reports that on April 27th it processed 8,392
applications. At that time, this was the largest one day submission
total for the system, surpassing the April 24th record high of 5,973.
[35] The Grants.gov PMO runs a blog that reports at least daily on
system performance. See [hyperlink, http://grants-gov.blogspot.com]
(accessed as of July 6, 2009.)
[36] On April 27, 2009, at 10:55 p.m. on the Grants.gov blog, the PMO
reported, "at approximately 7:45pm, April 27th, the portion of the
Grants.Gov system that manages the intake of new applications suffered
technical difficulties due to the unprecedented number of new
applications received today. The immediate result was that users could
not submit grant applications through Grants.gov for about a two-hour
period from 7:45 pm to 9:45 pm EST (Eastern Standard Time). Grant
opportunity search capability, and processing of applications that had
already been submitted before the failure, continued to function
normally."
[37] Although Grants.gov sends e-mail communications to applicants
notifying them when their application is "validated" and transmitted to
the grantor agency, applicants have no way of knowing the contents or
condition of the documents received by the agency.
[38] When an applicant calls the contact center, the customer service
representative assigns a case number and attempts to resolve callers'
issues. A grantor agency can use the case number to obtain the case
notes from the PMO.
[39] During that time frame, the contact center's service level ranged
between 26 and 72 percent (the target level is 85 percent or higher).
The abandon rate ranged between 6 and 29 percent (the target level is
less than 5 percent).
[40] The overall satisfaction rate in May 2009 was 92 percent, the
service level was 88 percent, and the abandon rate was 2 percent.
[41] The customer satisfaction score averaged around 55 out of 100 from
April 2008 to January 2009, but has been between 50 and 53 since then.
The score does not represent the percentage of Web site visitors who
were satisfied; rather, it is an index that is derived from multi-item
satisfaction questions and weightings that are designed to maximize
causation between the drivers of satisfaction and satisfaction
outcomes.
[42] By April, the PMO received a sufficient amount of agency
contributions to renew the licenses.
[43] Office of Management and Budget, Improving Grants.gov. M-09-17
(Apr. 8, 2009).
[44] For example, since Fiscal Year 2006 agencies may not make funds
available for OMB's E-Government initiatives until 15 days after OMB
submits an E-Government funding report to the House and Senate
appropriations committees and until the committees approve the
availability of these funds. OMB officials told us that they generally
submit this report to Congress after the first quarter of each fiscal
year. Also, at least one agency has, in some years, not paid its
Grants.gov contributions because its appropriations subcommittee
directed it not to.
[45] OMB Circular A-11, Part 7.
[46] "Cloud computing" refers to an arrangement in which an
organization pays a service provider to deliver IT applications,
computing power, and storage via the Internet. For Grants.gov, a change
to "cloud computing" means outsourcing its IT system, including
hardware and related software, and having its IT services managed and
delivered from a Web-based platform rather than owning them and having
them managed by an in-house contractor as it currently does. Cloud
computing would still require the Grants.gov PMO to manage the system
through a contractor and applicants would still upload submissions to
the Grants.gov system.
[47] See National Grants Partnership, Presidential Transition Report
(Washington, D.C.: November 2008). The NGP was established in 2004 to
bring together government and non-government individuals with an
interest in improving the grants process in the United States.
[48] OMB also noted that GSA, through the Integrated Acquisition
Environment has been working steadily with the Grants.gov PMO to ensure
that the system includes the current and correct information from the
Catalog of Federal Domestic Assistance. GSA manages this catalog for
OMB.
[49] In a comment on the blog one user suggested the use of a change
control board composed of key stakeholders in agencies and grantee
organizations as a structured way to provide input to Grants.gov.
[50] [hyperlink, http://www.gao.gov/products/GAO-06-566].
[51] See [hyperlink,
http://www.aau.edu/search/default.aspx?searchtext=Grants.gov] (accessed
July 6, 2009). AAU is a nonprofit organization of 62 leading public and
private research universities in the U.S. and Canada; COGR is an
association of more than 175 U.S. research universities and their
affiliated academic medical centers and research institutes.
[52] The NGP also noted the lack of non-federal representation on the
Policy Committee. See NGP, Presidential Transition Report.
[53] The Grants.gov program manager at the time told us that there were
plans in the works to create a team consisting of 10 representatives
reflective of the end user community, including states, not-for-
profits, research entities, housing entities, tribal organizations,
educational entities, local government, and large, medium, and small
federal agencies. The group was meant to address the issues we raised
in our 2006 report on grants streamlining, specifically, to solicit the
assistance of the grant community and to build in end user acceptance
of Grants.gov system changes.
[54] FACA, 5 U.S.C. Appx §§ 1-15, imposes a number of requirements on
committees or similar groups of nonfederal employees that are
established or utilized by the President or federal agencies in the
interest of obtaining advice or recommendations, such as: filing a
charter, advance notice of public meetings, keeping meeting minutes,
and public availability of records.
[55] FDP is an association of federal agencies, academic research
institutions with administrative, faculty and technical representation,
and research policy organizations that work to streamline the
administration of federally sponsored research.
[56] GAO, Federal Advisory Committee Act: Issues Related to the
Independence and Balance of Advisory Committees, [hyperlink,
http://www.gao.gov/products/GAO-08-611T] (Washington, D.C.: Apr. 2,
2008).
[57] 41 C.F.R. §102-3.40.
[58] Grants.gov officials told us that in rare cases application
deadline times are written into a grant's authorizing legislation.
[59] For example, on April 6, 2009, a day on which Grants.gov received
an exceptionally large number of submissions, almost one-third of the
3,555 applications received were submitted between 3:00 p.m. and 6:00
p.m. eastern time.
[60] Six respondents said that they used another indicator to determine
timeliness, and nine did not answer the question.
[61] For example, before a large closing day in late April 2009
validations were taking up to 5 days.
[62] 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.
[63] Agencies may specify the requirement of a U.S. Postal Service
postmark or a dated receipt from a commercial carrier in their
application instructions.
[64] The remaining responses for these questions were "other" or "no
response."
[65] In other cases, the grantor agency would accept the application
but it would receive a lower overall score during the review process.
[66] On March 9, 2009, OMB required agencies to provide applicants an
alternative to Grants.gov for submitting applications during the
Recovery Act peak filing period, which is estimated to last from April
through August 2009.
[67] However, applicants who did not complete the registration process
will not be considered.
[End of section]
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