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 Federal Grants Updates and Overview Thomas Martin Grants Officer Grants Management Office Office of the Chief Financial Officer

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 Risk Assessment • 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. 5

MCSAP Conference – 2018 Federal Awarding Agency Review of Risk Posed by Applicants • 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). 6

MCSAP Conference – 2018 In addition, agencies may evaluate an applicant’s: • Financial stability • Quality of management systems • History of performance • Audit reports • Ability to comply with program requirements 7

MCSAP Conference – 2018 FMCSA High Priority NOFO Sect. E.3 • 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. 8

MCSAP Conference – 2018 FMCSA Risk Assessment Process • A debarment and suspension review that included a review of 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; 9

MCSAP Conference – 2018 FMCSA Risk Assessment Process • 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. 10

MCSAP Conference – 2018 FMCSA GMO • 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 11

MCSAP Conference – 2018 Pass-Through Entities • 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. 12

MCSAP Conference – 2018 Pass-Through Entities 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 13

MCSAP Conference – 2018 What’s happens next? • 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. 14

MCSAP Conference – 2018 FMCSA and/or Pass-Through 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 15

MCSAP Conference – 2018 Additional Federal Award Conditions • 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 16

MCSAP Conference – 2018 Going Forward • 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. 17

MCSAP Conference – 2018 DATA Act (P.L. 113-101) – 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. 18

MCSAP Conference – 2018 Impact of the DATA Act on FMCSA Awards • 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 ) 19

MCSAP Conference – 2018 New Federal Award Identification Numbers (FAIN)  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 20

MCSAP Conference – 2018 New Federal Award Identification Numbers (cont’d)  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 21

MCSAP Conference – 2018 Impact of the DOT-Wide FAIN on FMCSA’s Awards • An example of a new FAIN, 69A3601841234MCG0MN, with the breakdown as follows - 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 22