OMB Watch filed comments in October 2003 on the pilot web portal for federal grant announcements, based on suggestions made by nonprofits from around the country. 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: FedBizOpps Data Elements Comments, Vol. 67 Fed. Reg. No. 155, Pages 52554-52556 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 for input on standard data elements for electronic posting of synopses of federal funding opportunities. 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. General Comments Most federal funding opportunities that focus on grants and cooperative agreements will require eligible applicants to be some form of nonprofit organization. As a result, a web portal providing synopses of these opportunities should be tailored to the nonprofit sector. Nonprofits do not think of themselves as “businesses”. For this reason a unique name and homepage should be provided for the grant and cooperative agreement opportunities. The term “FedBizOpps” should be dropped in referring to the grant opportunity site, as it only causes confusion. The site name “fedgrants.gov” is a much better description, and we encourage all federal agencies to refer to it by that name. We urge you to define terms in the standard data elements in a manner consistent with IRS Form 990, and to include a statement to that effect. 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 homepage for the fedgrants.gov site should ultimately include the related information provided on the Federal Commons site. These include links to the Catalog of Federal Domestic Assistance, the Federal Assistance Awards Data System and online reporting and auditing transactions. Additional Proposed Data Elements In addition to the proposed information, nonprofits reviewing the fedgrants.gov site suggested the following additional information: · 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? Description of Data Terms 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”. Additional Comments on Fedgrants.gov Site Most of the nonprofits that visited both fedgrants.gov and the Federal Commons site prefer to have grant opportunities sorted by topic rather than agency. This can be because a service area, such as education, may have grants available from more than one agency. In addition, topical searches are easier for groups that are not experienced in applying for federal grants. All agreed synopses should be available both ways, by topic and by agency. However, on the fedgrants.gov site, the listing to search “All” agencies is at the bottom of the chart, and is not visible unless a user scrolls all the way down to the end. We suggest that the “All” category be put at the top. One commentor suggested that searches by eligible grantee categories be possible. There is an “eligibility” column in the fedgrants.gov site, but no information, so it is not clear if this is meant to allow searches by eligible grantee categories. Another commenter provided specific suggestions on ways to use clearer language and make the fedgrants.gov site more navigable: “The site is difficult at best. The language is all government and for the non-profit it's not clear. When you look at the table...say beside "Health and Human Services", shouldn't there be a button that says "Available Grants"? After clicking on a couple of buttons I found the list of grants under "Posted Dates" (this didn't make much sense to me). The way they're listed should be set up differently as well. Yes, the date should be first but you should list the grant title in bold right after that...then the office, the number, etc. Make it simple for all to understand: 1. When you go to fedgrants.org and pull up "Applicant", the chart should show "Health and Human Services", not just Health. 2. Where do you find information from the Office of Aging? 3. From chart, CDFA is not a term anyone outside government knows. Doesn't this really refer to "categories"? 4. From chart, when you select eligibility, add a drop down menu to select which category of eligibility you want to seek for grants. I had to scroll through four pages before I found the grants for which non-profits were eligible.” Conclusion Nonprofits are overwhelmingly supportive of the efforts of the federal agency staff in pushing forward implementation of FFAMIA, especially by making information available online. 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 Project