The Streamlining Grants Management Project filed comments on a proposed standard format for federal grant opportunity announcements, based on feedback from nonprofits. It praised the effort as a positive first step, and made suggestions about additional information nonprofits said would be very helpful. The text is below, or you can download a copy of the original comments. October 11, 2002 Elizabeth Phillips, Office of Federal Financial Management Office of Management and Budget, Room 6025 New Executive Office Building Washington, D.C. 20503 Re: Grant Announcement Format Comments, Vol. 67 Fed. Reg. No. 155, Pages 52548-52554 Dear Ms. Phillips, These comments are being submitted on behalf of the co-sponsors of the Streamlining Grants Management Project (OMB-Watch, the National Center for Charitable Statistics at The Urban Institute, and GuideStar. We appreciate the opportunity to comment on OFFM’s proposed Directive To the Heads of Executive Departments and Establishments, which would require a standard format for federal grant opportunity announcements. The Streamlining Grants Management Project distributed information on this and related Federal Register announcements widely in the nonprofit sector, and we collected suggestions from a wide variety of groups. These comments reflect that input. The issue of grant streamlining has been a priority of OMB Watch for some time. We worked with former Sen. John Glenn of Ohio to develop the legislation after participating in a series of online briefings sponsored by the Ohio Association of Nonprofit Organizations. The Federal Financial Assistance Management Improvement Act of 1999 (FFAMIA) attempted to address some of the concerns expressed during the online conference. Since that time we have joined with the Urban Institute and GuideStar to co-sponsor a project to give nonprofits information and a vehicle for input into how the federal government streamlines its grant application and reporting processes. This directive is a very positive first step in streamlining of the federal grants process. In May 2002 the project conducted an online survey to determine priorities for nonprofits in implementation of FFAMIA. Nonprofits rated “finding grant opportunities” and “filing grant applications” as their top priorities, both for uniform standards and need for electronic transactions. (A copy of the survey results is attached to these comments.) General Comments The proposed Directive creates consistency for all grant announcements, regardless of the means of distribution. Since nonprofits’ access government information in a variety of ways, it is important to provide consistency whether announcements appear in print or on the web. We urge you to define terms in the standard grants announcement format in a manner consistent with IRS Form 990, and to include a statement to that effect in standard instructions and explanations. This would greatly enhance the overall simplicity of nonprofit reporting to government. Since nonprofits receive roughly one-third of their revenue from government grants, and partner with government to implement a wide range of programs. The relationships are hampered, through, by highly complex, time-consuming, and duplicative grant procedures The Federal Register announcement notes that the proposed Directive is an “interim product”. As the streamlining process progresses, we urge you to consider requiring a standard format for presenting the information, similar to the sample table in the announcement. We agree with the announcement statement, “It can be difficult to extract all needed information from narrative paragraphs, even when they are well written.” Overview of Grant Opportunity The overview information is generally sufficient to meet the needs of interested nonprofits. The proposed Directive does not require these items to be presented in any particular sequential order. We believe it would preferable to create a standard format for presenting the information by requiring a standard sequential order. Many nonprofits looks for funding opportunities across agency or department lines, and a standard order would make their searches faster and more efficient. If both a Catalog of Federal Domestic Assistance (CFDA) number and agency based Funding Opportunity Number (FON) are used, the difference between two should be explained and clear directions provided about when to use which number, or when both are required. Additional information items nonprofits suggested that would be helpful in deciding whether or not to read the complete grant announcement are: · Is a match required? If so, must it be cash, in-kind, and a percent of the grant amount? · Are there mandatory outcomes or performance standards? · How much funding is available, over what period of time? What the anticipated number of grants or average grant amount? · What is the population to be served? · Is this a new opportunity? One way to present this information would be to require an Executive Summary that would include at least these facts. Full Announcement Categories and Subcategories The directive should instruct agencies to avoid the use of cross references wherever possible, and when they are necessary, to include a short summary of the information referenced. For online announcements, any cross reference should be hyperlinked to the referenced information. Some items of information are proposed as optional, but were cited by nonprofits as important items that should be required. These include: · Information about the level of funding available, the expected number of grant awards, and any subcategories in which funding is allocated. · Application submission information with clear references or hyperlinks to any general requirements that apply to multiple programs or grant opportunities. · Specific information on performance standards and goals, including whether or not there are outcome requirements. · Anticipated award dates. (This would greatly facilitate planning for nonprofits that deliver services.) · Eligibility requirements for the population to be served, and whether there are co-pay requirements for program beneficiaries. · Any mandated staff patterns. · Details on local match funds, including any requirement that funds be deposited in escrow prior to granting an award. Are Terms Understandable? We received several comments noting that the term “cost sharing” is confusing. Most nonprofits use the term “local match” to refer to requirements that grantees pay part of the cost of a federal program. In some state “cost sharing” refers to copayments by beneficiaries, creating further confusion. As a result, we suggest that the term “local match” be substituted for “cost sharing”. Conclusion Nonprofits are overwhelmingly supportive of the efforts of OFFM and the federal agency staff in pushing forward implementation of FFAMIA. We welcome any questions you may have about these comments, and look forward to providing further input as the process progresses. Yours truly, Kay Guinane, Counsel and Manager, Community Education Center Cc: Charles Havekost and Sandy Swab, E-Grants Program, HHS Tony Cavataio and Karen Evans, IAEGC State, Local and Nonprofit Workgroup Midori Morgan-Gaide, IRS Form 990 E-Filing