Grant Review and Pre-Award Process Elisa Gleeson Senior Grants Management Specialist 1
Learning Objectives Participants will gain an understanding of the elements of preaward and how to think through required elements from Uniform Grants Guidance including how to incorporate minimum requirements and working with varying timelines. Participants will learn of best practices in utilizing Community/Peers for conducting a review of submitted applications. Participants will explore tools for conducting review, methods for providing feedback to applicants and options for notification of selection. 2
Grant Making Agencies 3
Federal Grants A grant is a way the government funds your ideas and projects to provide public services and stimulate the economy. Grants support critical recovery initiatives, innovative research, and many other programs listed in the Catalog of Federal Domestic Assistance (CFDA). A grant is one of many different forms of federal financial assistance. Federal financial assistance is a broad term to refer to the various ways the U.S. government redistributes resources to eligible recipients Source: Grants.gov 4
Federal Grants Billions of dollars in Federal grants are awarded each year for programs and projects that benefit the public. This assistance is rooted in the Constitution and its call to "promote the general Welfare." The Federal Grant and Cooperative Agreement Act, passed in 1977, set out to guide government agencies in their use of Federal funds particularly by defining the roles of contracts, cooperative agreements, and grants. Contracts, should be awarded when a Federal agency is acquiring something Grants, should be awarded when a Federal agency is providing assistance Source: Grants.gov 5
Federal Grant Legislation Legislation has addressed everything from lobbying efforts to auditing requirements, to reporting procedures, to transparency and cross-agency data-sharing. The Office of Management and Budget (OMB) plays an important role in interpreting and implementing the laws among the Federal government's awarding agencies. Grant policies are shaped by a range of statutes, regulations, Executive Orders and guidance. Source: Grants.gov
Federal Grant Legislation 1977 Federal Grant and Cooperative Agreement Act 1995 Lobbying Disclosure Act 1996 Single Audit Act Amendments 1999 Federal Financial Assistance Management Improvement Act 2006 Federal Funding Accountability and Transparency Act
Federal Grant Legislation 2009 American Recovery and Reinvestment Act 2010 Government Performance and Results Modernization Act 2011 Executive Order 13576 - Delivering an Efficient, Effective, and Accountable Government Grant Reform and New Transparency Act 2014 Data Act OMB Uniform Grants Guidance
Federal Grant Legislation Federal Grant and Cooperative Agreement Act 1977 To distinguish Federal grant and cooperative agreement relationships from Federal procurement relationships, and for other purposes. Lobbying and Disclosure Act 1995 To provide for the disclosure of lobbying activities to influence the Federal Government, and for other purposes. Single Audit Act Amendments 1996 To streamline and improve the effectiveness of chapter 75 of title 31, United States Code (commonly referred to as the Single Audit Act ). Federal Financial Assistance Management Improvement Act 1999 To improve the effectiveness and performance of Federal financial assistance programs, simplify Federal financial assistance application and reporting requirements, and improve the delivery of services to the public. Federal Funding Accountability and Transparency Act 2006 To require full disclosure of all entities and organizations receiving Federal funds.
Federal Grant Legislation American Recovery and Reinvestment Act 2009 Making supplemental appropriations for job preservation and creation, infrastructure investment, energy efficiency and science, assistance to the unemployed, and State and local fiscal stabilization, for the fiscal year ending September 30, 2009, and for other purposes. Government Performance and Results Modernization Act 2010 To require quarterly performance assessments of Government programs for purposes of assessing agency performance and improvement, and to establish agency performance improvement officers and the Performance Improvement Council. EO: Delivering an Efficient, Effective and Accountable Government 2011 President Obama issued an executive order outlining the creation of the Government Accountability and Transparency Board (GATB). GATB's responsibilities include studying data sharing tools and creating a set of best practices that can guide the Federal government in its spending transparency reforms.
Federal Grant Legislation Grant Reform and New Transparency Act 2011 To amend title 31, United States Code, to provide transparency and require certain standards in the award of Federal grants, and for other purposes. The Digital Accountability and Transparency Act 2014 To expand the Federal Funding Accountability and Transparency Act of 2006 to increase accountability and transparency in Federal spending, and for other purposes. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2014 The reforms that comprise the Uniform Guidance aim to reduce the administrative burden on award recipients and, at the same time, guard against the risk of waste and misuse of Federal funds.
Life-Cycle Components Public Law 106-107 Initial Plan Although there are variations in the specific requirements of each component of the life cycle for different types of grants or recipients, the life cycle generally includes: Legislative authorization and appropriations Announcement of a funding opportunity by a Federal Program Preparation and submission of applications by non-federal organizations to the sponsoring agency; Award to those entities meeting eligibility and program requirements and that are selected for funding following a merit or other comparative evaluation of applications; Post-award performance and administration by the recipient in accordance with the terms and conditions of award, including general administrative requirements and cost principles;
Life-Cycle Components Public Law 106-107 Initial Plan Reporting on financial and programmatic performance and other activities, such as inventions and environmental impact, as applicable; Agency monitoring and technical assistance; Payment; Audit; and Closeout Government-wide and agency processes, systems, and standards support the grant life cycle. They are intended to provide the foundation for agency and recipient compliance with Federal laws, regulations, and requirements, including fiscal accountability. With the advent of advanced technology and a greater appreciation of the burdens the Federal grant process places on recipients, we need to recognize how our processes, systems, and standards affect recipient business processes.
14 Uniform Grants Guidance
Pre-Award 200.203 Notices of funding opportunities The Federal awarding agency must announce specific funding opportunities by providing the following information in a public notice: a) Summary Information in Notices of Funding Opportunities. The Federal awarding agency must display the following information posted on the OMB-designated governmentwide Web site for finding and applying for Federal financial assistance, in a location preceding the full text of the announcement: 1) Federal Awarding Agency Name; 2) Funding Opportunity Title; 3) Announcement Type (whether the funding opportunity is the initial announcement of this funding opportunity or a modification of a previously announced opportunity); 4) Funding Opportunity Number (required, if applicable). If the Federal awarding agency has assigned or will assign a number to the funding opportunity announcement, this number must be provided; 5) Catalog of Federal Domestic Assistance (CFDA) Number(s); 6) Key Dates. Key dates include due dates for applications or Executive Order 12372 submissions, as well as for any letters of intent or pre-applications. For any announcement issued before a program's application materials are available, key dates also include the date on which those materials will be released; and any other additional information, as deemed applicable by the relevant Federal awarding agency. 15
Pre-Award 200.203 Notices of funding opportunities b) The Federal awarding agency must generally make all funding opportunities available for application for at least 60 calendar days. The Federal awarding agency may make a determination to have a less than 60 calendar day availability period but no funding opportunity should be available for less than 30 calendar days unless exigent circumstances require as determined by the Federal awarding agency head or delegate. 16
Pre-Award 200.203 Notices of funding opportunities c) Full Text of Funding Opportunities. The Federal awarding agency must include the following information in the full text of each funding opportunity. 1) Full programmatic description of the funding opportunity. 2) Federal award information, including sufficient information to help an applicant make an informed decision about whether to submit an application. (See also 200.414 Indirect (F&A) costs, paragraph (c)(4)). 3) Specific eligibility information, including any factors or priorities that affect an applicant's or its application's eligibility for selection. 4) Application Preparation and Submission Information, including the applicable submission dates and time. 5) Application Review Information including the criteria and process to be used to evaluate applications. See also 200.204 Federal awarding agency review of merit proposals and 200.205 Federal awarding agency review of risk posed by applicants. 6) Federal Award Administration Information. See also 200.210 Information contained in a Federal award. 17
Pre-Award 200.204 Federal awarding agency review of merit of proposals. For competitive grants or cooperative agreements, unless prohibited by Federal statute, the Federal awarding agency must design and execute a merit review process for applications. This process must be described or incorporated by reference in the applicable funding opportunity. (see Appendix I to this part, Full text of the Funding Opportunity.) See also 200.203 Notices of funding opportunities.
Pre-Award 200.205 Federal awarding agency review of risk posed by applicants. a) Review of OMB-designated repositories of govermentwide data. 1) Prior to making a Federal award, the Federal awarding agency is required by 31 U.S.C. 3321 and 41 U.S.C. 2313 note to review information available through any OMB-designated repositories of governmentwide eligibility qualification or financial integrity information as appropriate. See also suspension and debarment requirements at 2 CFR part 180 as well as individual Federal agency suspension and debarment regulations in title 2 of the Code of Federal Regulations.
Pre-Award 200.205 Federal awarding agency review of risk posed by applicants. a) Review of OMB-designated repositories of govermentwide data. (Cont.) 2) In accordance 41 U.S.C. 2313, the Federal awarding agency is required to review the non-public segment of the OMB-designated integrity and performance system accessible through SAM (currently FAPIIS) prior to making a Federal award where the Federal share is expected to exceed the simplified acquisition threshold, defined in 41 U.S.C. 134, over the period of performance. At a minimum, the information in the system for a prior Federal award recipient must demonstrate a satisfactory record of executing programs or activities under Federal grants, cooperative agreements, or procurement awards; and integrity and business ethics. The Federal awarding agency may make a Federal award to a recipient who does not fully meet these standards, if it is determined that the information is not relevant to the current Federal award under consideration or there are specific conditions that can appropriately mitigate the effects of the non- Federal entity's risk in accordance with 200.207 Specific conditions.
Pre-Award 200.205 Federal awarding agency review of risk posed by applicants. b) In addition, for competitive grants or cooperative agreements, the Federal awarding agency must have in place a framework for evaluating the risks posed by applicants before they receive Federal awards. This evaluation may incorporate results of the evaluation of the applicant's eligibility or the quality of its application. If the Federal awarding agency determines that a Federal award will be made, special conditions that correspond to the degree of risk assessed may be applied to the Federal award. Criteria to be evaluated must be described in the announcement of funding opportunity described in 200.203 Notices of funding opportunities.
Pre-Award 200.205 Federal awarding agency review of risk posed by applicants. c) In evaluating risks posed by applicants, the Federal awarding agency may use a risk-based approach and may consider any items such as the following: 1) Financial stability; 2) Quality of management systems and ability to meet the management standards prescribed in this part; 3) History of performance. The applicant's record in managing Federal awards, if it is a prior recipient of Federal awards, including timeliness of compliance with applicable reporting requirements, conformance to the terms and conditions of previous Federal awards, and if applicable, the extent to which any previously awarded amounts will be expended prior to future awards; 4) Reports and findings from audits performed under Subpart F Audit Requirements of this part or the reports and findings of any other available audits; and 5) The applicant's ability to effectively implement statutory, regulatory, or other requirements imposed on non-federal entities.
Pre-Award 200.205 Federal awarding agency review of risk posed by applicants. d) In addition to this review, the Federal awarding agency must comply with the guidelines on governmentwide suspension and debarment in 2 CFR part 180, and must require non-federal entities to comply with these provisions. These provisions restrict Federal awards, subawards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal programs or activities.
Award 200.38 Federal award. Federal award has the meaning, depending on the context, in either paragraph (a) or (b) of this section: a) (1) The Federal financial assistance that a non-federal entity receives directly from a Federal awarding agency or indirectly from a pass-through entity, as described in 200.101 Applicability; or (2) The cost-reimbursement contract under the Federal Acquisition Regulations that a non-federal entity receives directly from a Federal awarding agency or indirectly from a pass-through entity, as described in 200.101 Applicability. b) The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance covered in paragraph (b) of 200.40 Federal financial assistance, or the cost-reimbursement contract awarded under the Federal Acquisition Regulations. c) Federal award does not include other contracts that a Federal agency uses to buy goods or services from a contractor or a contract to operate Federal Government owned, contractor operated facilities (GOCOs). d) See also definitions of Federal financial assistance, grant agreement, and cooperative agreement. 24
Award 200.51 Grant agreement. Grant agreement means a legal instrument of financial assistance between a Federal awarding agency or pass-through entity and a non-federal entity that, consistent with 31 U.S.C. 6302, 6304: a) Is used to enter into a relationship the principal purpose of which is to transfer anything of value from the Federal awarding agency or pass-through entity to the non-federal entity to carry out a public purpose authorized by a law of the United States (see 31 U.S.C. 6101(3)); and not to acquire property or services for the Federal awarding agency or pass-through entity's direct benefit or use; b) Is distinguished from a cooperative agreement in that it does not provide for substantial involvement between the Federal awarding agency or pass-through entity and the non- Federal entity in carrying out the activity contemplated by the Federal award. c) Does not include an agreement that provides only: 1) Direct United States Government cash assistance to an individual; 2) A subsidy; 3) A loan; 4) A loan guarantee; or 5) Insurance. 25
Award 200.207 Specific conditions. a) The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed, in accordance with paragraphs (b) and (c) of this section, under the following circumstances: 1) Based on the criteria set forth in 200.205 Federal awarding agency review of risk posed by applicants; 2) When an applicant or recipient has a history of failure to comply with the general or specific terms and conditions of a Federal award; 3) When an applicant or recipient fails to meet expected performance goals as described in 200.210 Information contained in a Federal award; or 4) When an applicant or recipient is not otherwise responsible.
Award 200.207 Specific conditions. b) These additional Federal award conditions may include items such as the following: 1) Requiring payments as reimbursements rather than advance payments; 2) Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; 3) Requiring additional, more detailed financial reports; 4) Requiring additional project monitoring; 5) Requiring the non-federal entity to obtain technical or management assistance; or 6) Establishing additional prior approvals.
Award 200.207 Specific conditions. c) The Federal awarding agency or pass-through entity must notify the applicant or non- Federal entity as to: 1) The nature of the additional requirements; 2) The reason why the additional requirements are being imposed; 3) The nature of the action needed to remove the additional requirement, if applicable; 4) The time allowed for completing the actions if applicable; and 5) The method for requesting reconsideration of the additional requirements imposed. d) Any specific conditions must be promptly removed once the conditions that prompted them have been corrected
Award 200.210 Information contained in a Federal award. A Federal award must include the following information: a) General Federal Award Information. The Federal awarding agency must include the following general Federal award information in each Federal award: 1) Recipient name (which must match the name associated with its unique entity identifier as defined at 2 CFR 25.315) 2) Recipient's unique entity identifier; 3) Unique Federal Award Identification Number (FAIN); 4) Federal Award Date (see 200.39 Federal award date); 5) Period of Performance Start and End Date; 6) Amount of Federal Funds Obligated by this action; 7) Total Amount of Federal Funds Obligated;
Award 200.210 Information contained in a Federal award. A Federal award must include the following information: a) General Federal Award Information. The Federal awarding agency must include the following general Federal award information in each Federal award: (Cont.) 8) Total Amount of the Federal Award; 9) Budget Approved by the Federal Awarding Agency; 10) Total Approved Cost Sharing or Matching, where applicable; 11) Federal award project description, (to comply with statutory requirements (e.g., FFATA)); 12) Name of Federal awarding agency and contact information for awarding official, 13) CFDA Number and Name; 14) Identification of whether the award is R&D; and 15) Indirect cost rate for the Federal award (including if the de minimis rate is charged per 200.414 Indirect (F&A) costs).
Award 200.210 Information contained in a Federal award. b) General Terms and Conditions 1) Federal awarding agencies must incorporate the following general terms and conditions either in the Federal award or by reference, as applicable: i. Administrative requirements implemented by the Federal awarding agency as specified in this part. ii. National policy requirements. These include statutory, executive order, other Presidential directive, or regulatory requirements that apply by specific reference and are not program-specific. See 200.300 Statutory and national policy requirements. iii. Recipient integrity and performance matters. If the total Federal share of the Federal award may include more than $500,000 over the period of performance, the Federal awarding agency must include the term and condition available in Appendix XII Award Term and Condition for Recipient Integrity and Performance Matters. See also 200.113 Mandatory disclosures.
Award 200.210 Information contained in a Federal award. b) General Terms and Conditions (Cont.) 2) The Federal award must include wording to incorporate, by reference, the applicable set of general terms and conditions. The reference must be to the Web site at which the Federal awarding agency maintains the general terms and conditions. 3) If a non-federal entity requests a copy of the full text of the general terms and conditions, the Federal awarding agency must provide it. 4) Wherever the general terms and conditions are publicly available, the Federal awarding agency must maintain an archive of previous versions of the general terms and conditions, with effective dates, for use by the non- Federal entity, auditors, or others.
Award 200.210 Information contained in a Federal award. c) Federal Awarding Agency, Program, or Federal Award Specific Terms and Conditions. The Federal awarding agency may include with each Federal award any terms and conditions necessary to communicate requirements that are in addition to the requirements outlined in the Federal awarding agency's general terms and conditions. Whenever practicable, these specific terms and conditions also should be shared on a public Web site and in notices of funding opportunities (as outlined in 200.203 Notices of funding opportunities) in addition to being included in a Federal award. See also 200.206 Standard application requirements.
Award 200.210 Information contained in a Federal award. d) Federal Award Performance Goals. The Federal awarding agency must include in the Federal award an indication of the timing and scope of expected performance by the non- Federal entity as related to the outcomes intended to be achieved by the program. In some instances (e.g., discretionary research awards), this may be limited to the requirement to submit technical performance reports (to be evaluated in accordance with Federal awarding agency policy). Where appropriate, the Federal award may include specific performance goals, indicators, milestones, or expected outcomes (such as outputs, or services performed or public impacts of any of these) with an expected timeline for accomplishment. Reporting requirements must be clearly articulated such that, where appropriate, performance during the execution of the Federal award has a standard against which non-federal entity performance can be measured. The Federal awarding agency may include program-specific requirements, as applicable. These requirements should be aligned with agency strategic goals, strategic objectives or performance goals that are relevant to the program. See also OMB Circular A-11, Preparation, Submission and Execution of the Budget Part 6 for definitions of strategic objectives and performance goals. e) Any other information required by the Federal awarding agency.
OneStar Foundation Federal Agency: Corporation for National and Community Service Grant Program: AmeriCorps OneStar Foundation serves as the State Commission for administering the AmeriCorps program in Texas. Nonprofit Organization Staff: Manager, Grants Management Specialist, 2 Program Officers, 1 Grants Officer, 1 Grant Coordinator, Controller, Chief Operating Officer, Executive Director Funds granted: $14.3 million annually Formula and Competitive funding Cost Reimbursement and Fixed Amount awards 35
Grants Life Cycle Pre-Award Award Post-Award Closeout Appropriation of Funds Notice of Funding Opportunity Application Instructions Outreach and Training Program Development Strategize with community and stakeholders Budget Development Performance Measure Development Site Location MOU/Outreach Sub-Grantee Plan Match Commitment Peer Review Staff Review Clarification Notification Terms and Conditions Pre-Award Document Review Pre-Award Site-Visits Award Acceptance Notification Pre-Award Cost Request Member Recruitment Financial Monitoring Programmatic Monitoring Site Visits Award Amendments Training and Technical Assistance Member Enrollment Program Activities Sub-Grantee monitoring Deobligation Evaluation Request for Payment Closeout Notification Reconciliation of Payments Records Retention Final Financial Report Final Programmatic Report Sub-Grantee Closeout Report Equipment and Supplies Unexpended Funds Record Retention 36
Grant Review Process OneStar selects applications for funding using a multiphase process that includes review by a panel of community experts, OneStar staff, and the OneStar National Service Commission Board of Directors. In evaluating each application for funding, we assess the program design, organizational capability, and costeffectiveness and budget adequacy. Additionally, staff assess required supplemental documents such as the organizational capacity survey, member placement chart, and audited financial statements. 37
Application Review Each applicant must clearly describe a project that will deploy AmeriCorps members effectively to solve a significant community problem. We expect organizations to submit high quality applications that follow the guidance in the Notice and in the Application Instructions carefully. The quality of the application will be an important factor in determining whether an organization will receive funding. 38
General Timeline In developing a timeline for your Grant Making, where do you have flexibility and where do you have hard deadlines? What factors do you need to take into consideration to ensure compliance with your organization s rules on publishing an RFP and selecting grants? 39
Community Experts The primary responsibility of a Community reviewer is to read all grant applications and score the applications based on the criteria provided and provide detailed comments to justify the score. Recruitment Training Selection Discussion Day Best Practices 40
Community Experts Community Review Scoresheet 41
Staff Review The purpose of the Staff Review is to perform a higher level review of applications in regards to organizational capacity, higher level performance measurement, audit, and budget. Past Performance considerations Discussion day Clarification period Make or Break Making corrections 42
Staff Review Staff Review Scoresheets Continuation New/Recompete 43
Preparing for the Review To ensure that a quality, thorough and fair assessment of all applications is conducted, the following principles should be applied. Do not discriminate for or against an applicant because of any personal bias you may have. For example, if you do not think that an applicant with religious character or affiliation should be a provider of services, that belief should not influence your assessment. Be completely familiar with the forms and background material provided to you. Read quickly through all the proposals once before completing any scoresheets. Make constructive comments about what is presented in the application and omit any comments which are personal opinion or unrelated editorial. Include comments that explain or justify the score you give for each category. Do not make cryptic notes that will be difficult for others to understand. 44
Preparing for the Review To ensure that a quality, thorough and fair assessment of all applications is conducted, the following principles should be applied. (cont.) Do not read into the application any biases you may have for or against a program model. Use the evidence provided in the application to determine a quality model. Do not make assumptions about missing background information or project meaning. Review only what is included and provided in the grant application (do not Google the applicant organization). Read for substance not style. Be thorough and objective. 45
Preparing for the Review Comments Your comments must match your scores. A perfect comment should be matched by a score of a 5. Questioning components of the response would not be a 5. Do NOT: Comment on program activities (judge what they are doing as an organization) Tell them how they should be doing things Compare their application with other applications, each application should be evaluated on its own merits against the criteria. Be Rude 46
Preparing for the Review Comments DO: Be Brief Be Specific Unclear What was unclear? Good What was good? Be Positive, when Possible Remember that each application represents a lot of hard work on the part of the organization. The goal of critiquing is to be helpful, not hurtful. Newer applicants are often the recipients of negative comments; if you can say anything good about an application with the bad, it can be less discouraging for the applicants. Be Honest, but not unnecessarily harsh. 47
Notification Upon approval of the OneStar Board, notification is sent to all applicants of their selection/non-selection via email letter. Who receives notification? Circumstances which may require a call. No option provided for reconsideration. Feedback provided to applicants. 48
Sample: Application Feedback 49
Notification of the Public Federal Embargo on funding announcements Press Release Notification to Legislators 50
Notification of the Public Publication of Grant funded programs. Own organization s website FSRS/USASpending 51
Pre-Award Publication of Grant funded programs. Own organization s website FSRS/USASpending 52
Pre-Award SAM.gov Application Review (Community and Staff) Organizational Capacity Survey Pre-Award Risk Assessment Document Review Start-Up Visit 53
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Start-Up Pre-Award Risk Assessment Document Review All programs are required to submit pre-award documents prior to being able to receive their Grant Award. Start-Up Visits For any new program, OneStar staff will conduct an on-site visit before the program year starts in order to meet staff, ensure understanding of the AmeriCorps program and to be available in person to address any questions. 56
Award SAM.gov Re-checked prior to issuing a grant award. Training and Technical Assistance Our goal is always to prevent mismanagement of federal grant funds and resulting disallowed costs. New AmeriCorps Staff Orientation. Offered three times per year. Required attendance for Primary Fiscal and Program during their first year. Suspension and Termination Included as part of all Grantee s Terms and Conditions at the time of award acceptance. 57
58 Questions?
Elisa Gleeson, MPSA, CGMS Senior Grants Management Specialist OneStar Foundation Austin, Texas elisa@onestarfoundation.org 512-287-2029 59