Federal Grants Updates and Overview · Grants Officer. Grants Management Office. ... MCSAP Planning Meeting and Grants Training 2017– Federal Grants Updates ... House of Representative

MCSAP Planning Meeting and Grants Training – 2017

MCSAP Planning Meeting and Grants Training March 22-23, 2017

Minneapolis Marriott City Center

Nancy Anne Baugher, CPA, CGFM, RSBOGrants Officer

Grants Management OfficeOffice of the Chief Financial Officer

Federal Grants Updates and Overview


Federal Grants Updates and Overview

Objective: To inform the national FMCSA grants

community about areas of immediate importance as well as those on the horizon

1. Key developments and Federal-wide initiatives in federal grant practice 2. Strategic perspectives on grants: cost concepts, investments and performance


Key developments and Federal-wide initiatives in federal grant

practicePart I

CENTRAL THEMES:Mission-centric, Transparency,

Accountability, Efficiency, Effectiveness, Reduce Costs, Consistency, Results


The Catalog of Federal Domestic Assistance (CFDA) provides a full listing of all Federal programs available to State and local governments (including the District of Columbia); federally-recognized Indian tribal governments; Territories (and possessions) of the United States; domestic public, quasi-public, and private profit and nonprofit organizations and institutions; specialized groups; and individuals.CFDA contains detailed program descriptions for 2,308 Federal assistance programs. The following chart shows the program distribution for the top five issuing agencies

CFDA

Last updated March 16, 2017

Source CFDA website


CFDA – What Programs?

House of Representative John Boehner (R-OH8) released Republican Lawmakers’ Pledge to America, September 23, 2010.


Format of the program description will change:Guidelines will be provided to address programsNew format more user friendly

Procedures for requesting new CFDA numbers will changeThis will affect the Compliance Supplement* OMB and GSA still dealing with logistics

How and when to transition, x-walks, etcMore ideas concerning implementation and timetable for changes still at OMB – no request for annual CFDA updates yet

CFDA

*The OMB A-133 Compliance Supplement is a Federal government guide created by the Office of Management and Budget (OMB) and used in auditing federal assistance and federal grant programs, as well as their respective recipients. It is considered to be the most important tool of an auditor for a Single Audit.


CFDAThe format and structure of CFDA is changing to:

Allow for additional CFDA numbers needed for some agenciesAlign with the Common Government-wide Accounting Classification (CGAC) agency code in the Treasury Account Symbol (TAS) – DATA Act requirement

The numbering system will change from aa.xxx to aaa.xxxxFor DOT, 20.xxx will become 069.xxxx.xxxx will be up to agency, for now

Some discussion about placing conditions placed on sequences (e.g., Reserved sequences for government-wide themes, types of assistance) – nothing concrete here at this time


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CFDA• Motor Carrier Safety Assistance• MCSAP• Number: 20.218 069.xxxx

• Agency: Department of TransportationOffice: Federal Motor Carrier Safety Administration (FMCSA)

• PROGRAM INFORMATION• Authorization (040):• FAST Act, Pub. L. No. § 114-94, §§ 5101(a) and 5101(c) (2015). 49 U.S.C. §§ 31102(a)-(k), 31104 (2016), as amended. See 49 CFR part 350, as

amended. States agree to adopt and enforce 49 CFR parts 390-397 and 107 (subparts F and G only), 171–173, 177, 178 & 180. , Public Law 114-94, 49 U.S.C 390-397 and 107.

• Objectives (050):• The Motor Carrier Safety Assistance Program (MCSAP) is a Federal formula grant program that provides financial assistance to States to reduce

the number and severity of accidents and hazardous materials incidents involving commercial motor vehicles (CMV). The goal of the MCSAP is to reduce CMV-involved accidents, fatalities, and injuries through consistent, uniform, and effective CMV safety programs. Investing grant monies in appropriate safety programs will increase the likelihood that safety defects, driver deficiencies, and unsafe motor carrier practices will be detected and corrected before they become contributing factors to accidents.

• Types of Assistance (060):• FORMULA GRANTS• Uses and Use Restrictions (070):• The primary MCSAP activities eligible for reimbursement include the National Program Elements currently outlined in 49 CFR § 350.109:

1. Driver and Vehicle Inspections;2. Tr . . . . . etc

Reference: https://www.cfda.gov


Federal Funding Accountability and Transparency Act

The Federal Funding Accountability and Transparency Act of 2006 (FFATA), ensures that the public can access information on all entities and organizations receiving Federal funds.

Central to the law was the development of the following FFATA-related websites:

USASpending.gov - Single, searchable website of all Federal grants and contracts containing information required by FFATA.FSRS.gov - The Federal Subaward Reporting System collects data on executive compensation and first-tier subawards.


Funding Awarded By State/Territory FY17https://www.usaspending.gov/transparency/Pages/StateSummaries.aspx

The graph displays the funds awarded by contracts, grants, loans, and other financial assistance for fiscal year .


DATA Act The Digital Accountability and Transparency

Act of 2014 (DATA Act) (P.L. 113-101) requires all Federal agencies to make certain spending

information available to the public in a manner that is accessible, searchable and reliable by establishing data standards and

requirements.


Overview of the DATA Act• The Act applies to funding issued by the Federal government

in the form of grants, cooperative agreements, loans, contracts, insurance, direct appropriations and other similar forms of assistance.

• Establishes government-wide data reporting standards for financial information that is displayed at USASpending.gov.

• Agencies must implement all other requirements established under the Act.


Overview of the DATA Act (cont’d)• Amends the Federal Funding Accountability and Transparency Act of

2006 (FFATA); does not supersede it.• Grantee subaward reporting requirements*under FFATA are still in place:

Report all sub-awards issued for $25,000 or more Report any additional or supplemental funds issued for a subaward

that has already been reported Submit all reportable transactions to the Federal Funding

Accountability and Transparency Act Subaward Reporting System (FSRS)

Submissions must include all required data elements (subaward number, DUNS, place of performance, CFDA, etc.)

See https://www.fsrs.gov/ for more information*These requirements apply to subawards only; there are separate reporting requirements for contracts.

https://www.fsrs.gov/


Impact of the DATA Act on FMCSA Awards

• FMCSA (and all other modes) developed an implementation plan to meet the requirements of the Act.

• Concurrent with the implementation of the DATA Act is a change to the federal award identification number (FAIN) format: all DOT modes will use the same format for all new grants awarded after a certain date (the effective date is TBD, but tentatively scheduled for mid-2018). This applies only to new awards issued on or after the

effective dateAll awards issued prior to the effective date will retain their

original award identification number


Impact of the DATA Act on FMCSA Awards (cont’d)

For purposes of this discussion FAIN has the same meaning as grant number, award number, grant ID, award ID.

FAIN is a reportable data element under FFATA and the DATA Act; and is required component of a Federal award (2 CFR §200.210).

FAINs must be globally unique (i.e., not duplicated anywhere within the Federal government)



Elements of FAIN Field CharacterPositions 1-6: Agency identity for FMCSA; assigned by GSA 69A360Positions 7 & 8: FY in which the award was issued 17

Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA 4

Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions 1234Positions 14 - 17: Program Type established and designated by FMCSA MCG0Positions 18 -19: State of Performance MN

The standard DOT-wide FAIN will be structured as follows:


Impact of the DATA Act on FMCSA’s Awards (cont’d)

The table below shows a side-by-side comparison of the new FAIN and the current award structure:

FAIN Award FormatFAIN

Character Current Award Format Award ComponentPositions 1-6: Agency identity for FMCSA; assigned by GSA 69A360

Positions 1-3: Agency identity with dash FM-

Positions 7 & 8: FY in which the award was issued 17

Positions 4-6: Program type with dash MCG-

Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA 4

Positions 7-11: Sequential award number with dash 9876-

Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions 1234

Positions 12-14: Fiscal year of award with dash 17-

Positions 14 - 17: Program Type established and designated by FMCSA MCG0

Positions 15-17: Budget period with dash 01-

Positions 18 -19: State of Performance MNPositions 18-19: Modification number 00



The final table is a crosswalk of the current and new award structures:

CrosswalkNew FAIN Format Current Award Format

Positions 1-6: Agency identity for FMCSA; assigned by GSA Positions 1-3: Agency identity with dashPositions 7 & 8: FY in which the award was issued Positions 12-14: Fiscal year of award with dashPosition 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA N/APositions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions

Positions 7-11: Sequential award number with dash

Positions 14 - 17: Program Type established and designated by FMCSA Positions 4-6: Program type with dashPositions 18 -19: State of Performance N/A



New FAIN Format Current Award Identification Format69A3601741234MCG0MN FM-MCG-9876-17-01-00

The illustration below shows the new and the current award formats.



Recap -

• New FAIN will become effective sometime in 2018 (date to be determined by the CFO for DOT)

• Grants issued prior to the implementation date of the new FAIN structure will retain their current identity

• FMCSA staff and grantees will be provided additional guidance at a later date


Common Grants Forms ReformOMB and HHS (designated lead agency) are convening a work group for the “Common Grants Forms”

Includes SF-424 family, as well as other forms for application, monitoring and reporting of grants informationCoincides with compliance with DATA Act requirements

OMB Working Group for the SF-SAC (Standard Form - Single Audit Collection (Data Collection Form))


Grants Oversight and New Efficiency Act (GONE Act) P.L. 114-117

Enacted by Congress to hold Federal awarding agencies accountable for timely closeout of grant awards. The purpose of the law is to reduce costs associated with maintaining bank accounts of expired grants that contain undisbursed funds or a zero balance.The law requires Federal awarding agencies to submit a report to Congress (Due in 2017) and to the Department of Health and Human Services (HHS) that:· Identifies each Federal grant that has not been closed out two years after the end of the award’s period of performance· Describes the challenges leading to delays in grant closeout· Explains why awards have not been closed outWithin one year of the initial report, Federal awarding agencies are required to provide a follow-up report that specifies which of the identified grant awards have been closed out and those that remain open.


Grants Oversight and New Efficiency Act (GONE Act) P.L. 114-117

Also requires the Director of the Office of Management and Budget (OMB) and the HHS Secretary recommend to Congress legislation to improve the accountability and oversight of grants management.Under the Uniform Guidance, Federal awarding agencies and pass-through entities should complete all closeout activities within one year. 2 CFR 200.343(g) states:The Federal awarding agency or pass-through entity should complete all closeout actions for Federal awards no later than one year after receipt and acceptance of all required final reports.The law currently does not require agencies to complete closeout activities within one year. However, agencies will be required to explain to Congress why closeout has not occurred within the one-year time frame.


GONE Act – and FMCSA

July, 2017, FMCSA will conduct its second annual close-out drill under the GONE Act

Count UDO Balance Year

5 $805,264.44 2009

13 $994,364.74 2010

2 $212,631.59 2011

35 $4,197,983.59 2012

42 $7,782,486.71 2013

58 $10,608,503.07 2014

102 $24,733,100.31 2015

134 $98,999,592.49 2016


System for Award Management (SAM)Beta.SAM.gov Public Display


Federal Awardee Performance & Integrity Information System (FAPIIS)

The Duncan Hunter National Defense Authorization Act of 2009 (Public Law 110-417) was enacted on October 14, 2008. Section 872 of this Act required the development and maintenance of an information system that contains specific information on the integrity and performance of covered Federal agency contractors and grantees. The Federal Awardee Performance and Integrity Information System (FAPIIS), was developed to address these requirements. FAPIIS provides users access to integrity and performance information from the FAPIIS reporting module in the Contractor Performance Assessment Reporting System (CPARS), proceedings information from the Entity Management section of SAM database, and suspension/debarment information from the Performance Information section of SAM.


The Project on Government Oversight

Dear Members of Congress:

We are writing in support of efforts to bring new transparency to federal grants and cooperative agreements. Spread across 1,714 programs and 26 agencies, federal grant outlays reached $538 billion in FY2012. Of that amount, nearly $80 billion was allocated through discretionary grants. While grants and cooperative agreements fulfill a crucial role in our society, too little is known about where the money goes, how it is awarded, and how to apply.

GRANT Act (H.R. 3316)

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On the Horizon – Common Themes


• 2860, the OPM IG Act; H.R. 3316, • the Grant Reform and New Transparency Act of 2013

(GRANT Act); H.R. ___, • the Stop Unworthy Spending Act (SUSPEND Act)

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On the Horizon – Common Themes


Life Cycle of an Award

SAM

CFDA

Data Act

Forms Reform

GONE Act

FAPPIS



SAM

CFDA

Data Act

Forms Reform

GONE Act

FAPPIS



SAM

CFDA

Data Act

Forms Reform

GONE Act

FAPPIS


Part IIStrategic perspectives on grants: cost

concepts, investments and performance

Accountability, Compliance, EffectivenessIn Grant Management

Ensuring Mission Outcomes


More than half of FMCSA budget is spent through Federal financial assistance program activities (grants and

cooperative agreements).

FMCSA responsibility in the stewardship of Federal resources: to ensure that FMCSA funds are expended in

accordance with the law, that programs are effective, and that we achieve the outcomes established by Congress

through these programs

***********Taxpayer investment in our programs

Strategic Investments


Strategic Investments in Grants- Aligning Dollars to Donuts

Planning through budgets Actual expenditures reimbursed to the

recipientdemonstrate taxpayer investments (costs)


>Understanding the general cost elements and principles needed for Federal grant programs (the

legitimacy of costs)(in applications for Federal funding, implementing programs, and through reimbursement of costs).

>Understanding the relationship to GAAP

Legitimate Investments


Under 2 CFR, for any costs to be charged directly to a federal award the expense must be:

Allowable (includes provisions for eligibility)Allocable

ReasonableCharged consistently

**********These factors address directly the legitimacy of a cost

charged against specific federal awards.


For any costs to be charged directly to a federal award under 2 CFR the expense must be:

Allowable under both the provisions of federal guidance AND the terms of a specific award (includes provisions for eligibility)Allocable: associated to a project with a high degree of accuracyReasonable: the cost reflects what a “prudent person” would pay in a similar circumstanceCharged consistently as direct expense (versus an indirect cost), and as Federal and non-Federal cost objectives.


Recipient Compliance to Support Outcomes

Terms & Conditions of AwardBy accepting a Federal award a grantee is

responsible for fulfilling/upholding all compliance requirements defined in the terms and conditions of

award.The recipient/grantee entity is responsible for

ensuring that costs charged to grants and cooperative agreements are allowable, reasonable, necessary and consistently applied . . . . . . . . . Each

financial transaction charged against a Federal award is evaluated against these concepts

(legitimacy).


Stewardship of Federal resources: responsibility to ensure that FMCSA funds are expended in accordance with the law,

that programs are effective, and that we achieve the outcomes established by Congress through these programs

***********Taxpayer investment in our programs

The recipient/grantee entity is responsible for ensuring that costs charged to grants and cooperative agreements are

allowable, reasonable, necessary and consistently applied . . .. . . .Each financial transaction charged against a Federal award

is evaluated against these concepts.

Compliance to Support Outcomes


Generally Accepted Accounting Principles (GAAP)

The Federal government operates under the principles of GAAP. Today, all 50 state governments prepare their financial reports according to GAAP. While a little less than half of U.S. states officially require local governments to adhere to GAAP,

the Governmental Accounting Standards Board (GASB) estimates that approximately 70% of county and local

financial offices do anyway.(http://www.accounting.com/resources/gaap/)

Consistency

http://www.gasb.org/

http://www.accounting.com/resources/gaap/


Generally Accepted Accounting Principles (GAAP)

Three important sets of rules: (1) the basic accounting principles and guidelines, (2) the detailed rules and standards issued by FASB, and predecessor the

Accounting Principles Board (APB), and (3) the generally accepted industry practices, to standardize and regulate

accounting definitions, assumptions, and methods. Provides foundation for consistency from year to year in the methods used to prepare an entity’s financial statements.

OMB regulations are also founded on basic accounting and financial premises.Recognizing those points central to fundamental accounting principles and guidelines helps ensure outcomes.


GAAP - 10 general principlesThese 10 general principles on the concepts of GAAP:

Principle of Regularity Adhering to standards, such as those represented through GAAP.Principle of Consistency Applying the same standards throughout the reporting process to prevent errors or discrepancies. As well as to fully disclose and explain the reasons behind any changed or updated standards.Principle of Sincerity Striving to provide an accurate depiction of the financial status or situation.Principle of Permanence of Methods The procedures used in financial reporting are consistent and repeatable.Principle of Non-Compensation Both negatives and positives are fully reported with transparency and without the expectation of debt compensation. (insider obligations)


GAAP - 10 general principles (cont)

Principle of Prudence Fact-based financial data and information is represented not clouded by speculation.Principle of Continuity Valuation of assets, investment of resources and commitments assumes entity will continue to operate as proposed.Principle of Periodicity Entries should be distributed across the appropriate periods of time. Principle of Materiality / Good Faith Striving for full disclosure in reporting, including reporting status and updates.Principle of Utmost Good Faith Derived from the Latin phrase “uberrimae fidei” used within the insurance industry. It presupposes that parties remain honest in transactions.


Monitoring & Oversight(Grant Management)



SAM

CFDA

Data Act

Forms Reform

GONE Act

FAPPIS

What is Post-award?The timely investment of tax payer funds, intended to fulfill a social or societal goal or mission.


• Financial Assistance Guidance Manual (FAGM) (GMM)• FATE (Financial Assistance Team of Executives)

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Post-scriptINSIDE DOT

Documents

Federal Grants Updates and Overview · Grants Officer. Grants Management Office. ... MCSAP Planning Meeting and Grants Training 2017– Federal Grants Updates ... House of Representative