Federal Grants Updates and Overview Thomas Martin Grants Officer - - PowerPoint PPT Presentation

MCSAP Conference – 2018

MCSAP Planning Meeting and Grants Training April 24-27, 2018 Orlando, FL

Thomas Martin Grants Officer Grants Management Office Office of the Chief Financial Officer

Federal Grants Updates and Overview

MCSAP Conference – 2018

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

MCSAP Conference – 2018

Key developments and Federal- wide initiatives in federal grant practice

CENTRAL THEMES: Mission-centric, Transparency, Accountability, Efficiency, Effectiveness, Reduce Costs, Consistency, Results

MCSAP Conference – 2018

Key developments and Federal- wide initiatives in federal grant practice

SPECIFIC TOPICS: High Risk, FAIN, Closeout, GrantSolutions, Technical Review Panels

MCSAP Conference – 2018

• The grants community is under increasing scrutiny and

pressure to protect Federal funds from waste, fraud, and abuse.

• 2 CFR 200 (Uniform Guidance) establishes protections at

each part of the grants lifecycle to protect Federal funds from risk.

• The Uniform Guidance also defines the responsibilities

for Federal awarding agencies, pass-through entities, grant recipients, and auditors to guarantee grant funding is used for its intended purposes.

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Risk Assessment

MCSAP Conference – 2018

• 2 CFR 200.205 requires Federal awarding agencies to develop and

implement a risk assessment framework.

• Federal awarding agencies are required to evaluate the risk posed

by applicants before making an award.

• Provides agencies with the flexibility to develop an agency-based

risk assessment framework; however, agencies are required to verify applicant eligibility through the SAM Exclusions Extract and evaluate applicant qualifications through the Federal Awardee Performance and Integrity Information System (FAPIIS).

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Federal Awarding Agency Review of Risk Posed by Applicants

MCSAP Conference – 2018

• Financial stability
• Quality of management systems
• History of performance
• Audit reports
• Ability to comply with program requirements

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In addition, agencies may evaluate an applicant’s:

MCSAP Conference – 2018

• 2 CFR 200.205 requires Federal awarding agencies to

describe the risk assessment framework in the Notice of Funding Opportunity (NOFO).

• Prior to award, each selected applicant will be subject to a

risk assessment. Depending on the level and severity of the findings, FMCSA may determine that the applicant is not qualified to receive the award and use that determination as a basis for making an award to another applicant.

• FMCSA may also impose additional grant award terms and

conditions above its customary general terms and conditions.

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FMCSA High Priority NOFO Sect. E.3

MCSAP Conference – 2018

• A debarment and suspension review that included a review
• f the applicant’s administrative capability self-certification

form and a check against the records in SAM (currently the Federal Awardee Performance and Integrity Information System.

• An applicant, at its option, may review information in the

designated integrity and performance systems accessible through SAM and comment on any information about itself that a Federal awarding agency previously entered and is currently in the designated integrity and performance system accessible through SAM;

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FMCSA Risk Assessment Process

MCSAP Conference – 2018

• FMCSA will consider any comments by the applicant, in

addition to the other information in the designated integrity and performance system, in making a judgment about the applicant's integrity, business ethics, and record of performance under Federal awards when completing the review of risk posed by applicants; and

• An evaluation of the applicant’s Single Audit in accordance

with the Single Audit Act. The FMCSA may, at its discretion, request further information and/or conduct an audit to confirm compliance as indicated on the SF-LLL – Disclosure of Lobbying Activities form.

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FMCSA Risk Assessment Process

MCSAP Conference – 2018

• Using a risk-based approach, may consider following

items/reasons to designate high-risk:

– Financial Stability – Quality of management systems – History of performance – Audit findings/reports – Ability to implements requirements of the Federal award

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FMCSA GMO

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• The Uniform Guidance also requires pass-through

entities to conduct a risk assessment.

• Unlike Federal awarding agencies; however, pass-

through entities do not have to conduct the risk assessment prior to making an award.

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Pass-Through Entities

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• 2 CFR 200.331(b) explains that pass-through entities

may consider the subrecipients:

• Prior experience in administering similar awards
• Audit reports
• Personnel
• Management systems
• Results from Federal agency monitoring

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Pass-Through Entities

MCSAP Conference – 2018

• Federal awarding agencies and pass-through entities

should use the results of the risk assessment in developing an appropriate monitoring plan for each award.

• If the identified risks to Federal funds are significant,

Federal awarding agencies and pass-through entities may place specific conditions on the award.

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What’s happens next?

MCSAP Conference – 2018

• 2 CFR 200.207 identifies the conditions that may be

placed on a recipient

• Responsibilities of Federal awarding agencies and pass-

through entities when applying specific conditions.

– History of failure to comply with terms and conditions – Failure to meet performance goals

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FMCSA and/or Pass-Through

MCSAP Conference – 2018

• Withholding authority to proceed to next phases until

receipt of evidence of acceptable performance within a given funding period

• Requiring additional project monitoring
• Requiring additional and more detailed financial reports
• Requiring non-Federal entity to obtain technical or

management assistance

• Establish additional prior approvals

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Additional Federal Award Conditions

MCSAP Conference – 2018

• High-risk status is reassessed on a periodic or agreed-

upon scheduled basis.

• High-risk status will be removed when compliance with

all designated requirements has been demonstrated.

• When High-risk status is removed, all conditions and/or

restrictions will be promptly removed.

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Going Forward

MCSAP Conference – 2018

– The Digital Accountability and Transparency Act of 2014 (DATA Act) requires all Federal agencies to make certain spending information available to the public in a manner that is accessible, searchable and reliable. – USASpending.gov is the public-facing web site where spending data and other award information may be

• found. It is owned and managed by Treasury.

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DATA Act (P.L. 113-101)

MCSAP Conference – 2018

• Concurrent with the implementation of the DATA Act, all DOT

modes must begin using a standard federal award identification number (FAIN) structure by September, 2018.

 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 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)  Modification number cannot be included in a FAIN; mod information is a separate field of the NGA (unchanged)

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Impact of the DATA Act on FMCSA Awards

MCSAP Conference – 2018

 Applies only to new awards issued on or after the implementation date for FMCSA - June, 2018 (approx.)  All awards issued prior to the implementation date will retain their current award identification number and format  New award IDs will have 19 alphanumeric characters with no dashes

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New Federal Award Identification Numbers (FAIN)

MCSAP Conference – 2018

 All DOT grant awards will follow the same format  New FAIN structure for FMCSA is currently in development at HHS, timeline is -

• User testing in March and April, 2018
• Final adjustments made by HHS development team approx.

May, 2018

• Go-live approximately June, 2018

 NGA will support both award number formats

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New Federal Award Identification Numbers (cont’d)

MCSAP Conference – 2018

• An example of a new FAIN, 69A3601841234MCG0MN,

with the breakdown as follows -

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Impact of the DOT-Wide FAIN on FMCSA’s Awards

Elements of FAIN Field Character Positions 1-6: Agency identity for FMCSA; assigned by GSA 69A360 Positions 7 & 8: FY in which the award was issued 18 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 1234 Positions 14 - 17: Program Type established and designated by FMCSA MCG0 Positions 18 - 19: State of performance MN

MCSAP Conference – 2018

FAIN Award Format – 69A3601841234MCG0MN FAIN Character Current Award Format – FM-MCG-1234-18-01-00 Current Award Character Positions 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 18 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 1234- Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions 1234 Positions 12-14: Fiscal year

• f award with dash

18- 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 MN Positions 18-19: Modification number 00

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Impact of the DOT-Wide FAIN on FMCSA’s Awards (cont’d)

MCSAP Conference – 2018

• The final table is a crosswalk of the current and new

award structures:

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Impact of the DOT-Wide FAIN on FMCSA’s Awards (cont’d)

Crosswalk New FAIN Format Current Award Format Positions 1-6: Agency identity for FMCSA; assigned by GSA Positions 1-3: Agency identity with dash Positions 7 & 8: FY in which the award was issued Positions 12-14: Fiscal year of award with dash Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA N/A Positions 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 dash Positions 18 -19: State of Performance N/A

MCSAP Conference – 2018

• The illustration below is a side-by-side of the new and

the current award formats.

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

New FAIN Format Current Award Identification Format 69A3601841234MCG0MN FM-MCG-1234-18-01-00

MCSAP Conference – 2018

• 382 Grants Eligible for Closeout (Gone Act)
• 148 Grants Awards in Grant Solutions as

completed/closed.

• 234 Grants Remaining to be Closed
• $7,504,656.60 UDO De-obligations Processed
• $11,392,855.99 Remaining Balances to be De-obligated

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Closeout – FY 2018 Progress (as of March 2018)

MCSAP Conference – 2018

• Required Documentation and Checklist

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Closeout

MANDATORY CLOSE-OUT DOCUMENTS Checklist Description Approved Date Y/ N Verification from Program Office/field that award will not be continued Notification to Recipient - 90 day close-out period requirements Receipt of Final PPR Approval of Final PPR Receipt of Final Financial Status Report Receipt of Equipment Inventory Report (IF APPLICABLE) Receipt of Patent Report (IF APPLICABLE) Deobligation of Unliquidated Balance Delphi Closed Recipient Letter of Closed Status emailed Reconciliation of Final FSR with Delphi

MCSAP Conference – 2018

• GMO priority
• Revised required closeout package
• Additional contractor support (closeout only)
• Revised closeout workflow approval GrantSolutions

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Closeout – On the horizon

MCSAP Conference – 2018

• Revised/Rearranged Workflow Approvals

– Awards – Amendments

• Existing Roles in GrantSolutions

– Pre-award vs. Award – Pilot: FY 2018 CDL NOFO

• Updates to ARM

– New Version – 7.0 – Numeric Scoring

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GrantSolutions Update

MCSAP Conference – 2018

• Revised NOFO template
• Revised NGA
• Revised Terms & Conditions
• FMCSA System of Record
• MCSAP – no NOFA? No Grants.gov?

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Coming Soon…

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Questions?