Late last month, the White House Office of Management and Budget (OMB) and Office of Science and Technology Policy (OSTP) issued an Advance Notice of Proposed Guidance, seeking public comment on proposed changes to single audit, cost principles, and administrative requirements for Federal grants and cooperative agreements. According to OSTP, “In many instances (e.g., indirect-costs-setting policy), multiple options are outlined [in the advance notice], reflecting a range of approaches likely to be attractive to different sectors of the grants community.”
In particular, the Advance Notice specifies the reform ideas outlined below:
- Reforms to Audit Requirements: Changes to Circulars A-133 and A-50, including changes to the Single Audit threshold, streamlining the A-133 Compliance Supplement, and strengthening guidance on audit follow-up and resolution.
- Reforms to Cost Principles: Changes to Circulars A-21, A-87, and A-133, including implementing a flat rate for indirect costs, exploring alternatives to time-and-effort reporting, expanding application of the utility cost adjustment, clarifying allocable administrative support as a direct cost, addressing allowable direct cost of computing devices, clarifying the threshold for allowable residual inventory, eliminating compliance requirements with no added value, and allowing for the budgeting of contingency funds.
- Reforms to Administrative Requirements: Changes to Circular A-102, A-110, and A-89, including requiring pre-award consideration of each proposal’s merit and applicant’s financial risk, requiring agencies to provide 90-day notice of funding opportunities, and providing a standard format for announcements of funding opportunities.
Key overarching questions on which OMB and OSTP are seeking public input include:
- Which of these reform ideas would result in reduced or increased administrative burden to you or your organization?
- Which of these reform ideas would be the most or least valuable to you or your organization?
- Are there any of these reform ideas that you would prefer that OMB not implement?
- Are there any reform ideas, beyond those included in this notice, that OMB should consider as a way to relieve administrative burden?
Comments must be received by OMB — electronically or via mail — by 5pm ET on March 29th.
To learn more, check out the Advance Notice of Proposed Guidance in the Federal Register.
(Contributed by Erwin Gianchandani, CCC Director)
