Background: During the month of May 2002 the Streamlining Nonprofit Grants Management Project conducted an online survey to determine priorities for nonprofits in implementation of the Federal Financial Assistance Management Improvement Act of 1999 (FFAMIA). The project is a joint effort of OMB Watch, the Urban Institute and Guidestar. We are working on implementation of FFAMIA, which mandates federal agencies to develop uniform grant application and reporting forms, procedures and definitions. For more information on grant streamlining see www.ombwatch.org Notice of the survey was sent to email lists representing a wide array of nonprofits, including national, state and local groups and faith and community based organizations. The response was enthusiastic: � 365 survey responses; � 264 respondents signed up to receive information on proposed grant application forms and procedures so they can have an opportunity to comment further; � 177 respondents provided examples of inconsistent standards and duplicate reporting requirements. Summary of Findings: There is very strong overall support for the streamlining process. Given the need for resources for many of the programs government supports, it was not surprising that nonprofits rated “finding grant opportunities” and “filing grant applications” as their top priorities, both for uniform standards and need for electronic transactions. However, uniform standards for activity and financial reports also received high ranks for usefulness, not far behind the grant application process. The same is true for electronic transactions, where grant applications and reporting received almost identical levels of support. Electronic payment transactions and audits received somewhat lower support, but all were well above 3 on a 1-5 scale (5 = the highest priority). The complexity of the current system is reflected by the fact that most respondents report funding from multiple levels of government (federal, state, local), and nearly half have funding from four or more government agencies. Six out of ten offer four or more programs with government support. However, all this activity accounts for less than half the total budget of most respondents. A significant number (47.7%) of respondents reported cash flow problems as a result of government funding. One-third of respondents say they are required to file multiple reports for the same activities, while 42.4% say their funding agencies have more than one definition for the same thing. Clearly there are enormous savings of time and resources to be had if the federal government is successful in creating uniform grant application and reporting standards and forms. 73.7% of respondents report receiving federal grants. However, for these gains to be fully realized it will be necessary for state and local governments to adopt the same standards, since nearly as many, 69%, report receiving grants through states and 55.1% report receiving grants through local government. It will be very important for states, who are also federal grantees, to be part of the federal streamlining process and move toward adoption of uniform standards as well. Survey Results: Q 1. Please rate the most useful areas for streamlining grant procedures and forms. 5 = most useful 1 = least useful. Results: Average Rank Grant Applications 4.5 Financial Reports 4.0 Activity Reports 3.9 Q 2. Please rate the following priorities for electronic grant transactions. 5 = most useful 1 = least useful Results: Average Rank Finding Grant Opportunities 4.4 Grant Applications 4.3 Payment Transactions 3.8 Filing Reports 4.2 Audits 3.3 Q 3. Does your organization receive government funds? Yes 84% No 16% Q 4. If your group does not receive government funds are you interested in finding grant opportunities? Yes 94% Not sure 6% Q 5. If you receive government funds please indicate the funding source by checking all that apply: Federal 73.7% State 69.0% Local 55.1% International 3.8% Q 6. How much of your budget comes from government funding? Budget Portion % Respondents 75-100% 28% 50-74% 16% 25-49% 17.4% 0-24% 38.6% Q 7. How many different programs do you offer that are supported with government funding? No. Programs % Respondents 1 17.3% 2 11.9% 3 10.6% 4 or more 60.2% Q 8. How many government agencies provide funding for your organization? No. Agencies % Respondents 1 14.5% 2 17% 3 20.6% 4 or more 47.7% Q 9. Do you get grants from different levels of government (federal, state, local) for the same program? Yes 58% No 42% Q 10. Does your organization have problems with cash flow resulting from government funding? Yes 47.7% No 52.3% Q 11. Do your funding agencies have more than one definition or standard for the same thing? Yes 42.4% No 57.6% Q 12. If yes, please give an example. See summary of examples below. Q 13. Are you required to file multiple reports for the same activities? Yes 32.8% No 67.2% Q 14. If yes, please give an example. See summary of examples below. For further information contact: Kay Guinane kguinane@ombwatch.org Q 12. Examples: More Than One Definition of Standards for the Same Thing (Some examples fit more than one category, and appear in all relevant categories.) Grant Applications � Funding through HUD Community Planning and Development vs. HUD Housing Division is like two completely different agencies. The application and development process for Section 811 funding is archaic and involves at least 100 times thew paperwork and effort as opposed to accessing McKinney act funds through HUD CPD. � Separate grant applications from local sponsor, local government and federal government. Also funding periods are different making this more confusing � HUD proposals are particularly repetitive. Questions are asked in different ways at least twice in the grant application. Other federal funding applications are similar. State and local funding applications have greatly improved over the last couple of years but could still be more streamlined. � definitions for terms within guidelines/applications, such as goal, objectives, impact, benchmarks, outcomes, etc. � Request for Proposal vs. Request for " " � Categories within programs and disciplines are often confusing in their definitions and subtleties. Budget Forms � Both local government agencies and state government agencies all have widely varying budget forms, that all are highly detailed and non-transferable. They also have variously differing format for presenting audience attendance data. � budgets are asked for in wildly varying formats and degrees of detail Matching Requirements � Definitions of matching of funds; � match--different funders define match differently � Many grants ask for match and the definition of match is not consistent. Eligibility � Income eligibility requirements for Head Start and Child Care, particularly in State of Illinois. � Medicaid funding for programs and HUD funding for programming require somewhat different criteria for a similar service to clients with mental retardation � Workforce requirements are significantly more stringent with regard to amendments, use of budget, and billing requirements than those received from the U.S. Department of Education or the state education agency. � Definition of Homeless � Definition of LEP or ELL students � Definitions of "low income" are different as are allowable costs. � Definition of disability � Different agencies have different standards: the definition of a "senior citizen" is 55 in some cases, 60 in other agencies. What is a low-income citizen is different between differing agencies. � homelessness and affordability have different definitions between HUD and the local Housing Authority. � Program - definitions for non-resident vs. resident, and SED children Financial - defintions for supplies � Definition of poverty level � The definition of homelessness varies among various funders � The definition of successful outcomes differs from the Department of Children and Families and the Department of Corrections. Additionally, providers must imput the same information into various "funder specialty" IS systems. � HOME, FLIHTC, SHP Continium of Care, Federal Home loan Bank all have definitions of homeless that are not quite consistent. There are also regulatory conflicts between HOME and FLIHTC Section 42 on eviction, HQS, and certification of tenants living in housing assisted from these sources. � We serve migrant and seasonal farmworkers and there are multiple definitions of "farmworker" at US Dept. of Labor and US Dept. of Agriculture, then several state programs have their own definition. These definitions indicate different types of work that constitute farmworker. Some include processing of farm commodities and some exclude this work. Some set minimum income from eligible farmwork thresholds and some just stipulate a maximum family income to qualify for services. Program Activities � Standards for participant confidentiality vary - some are relieved with a permission form from the participant, others are not. � It seems everyone has a different definition for standards, objectives and strategies. Activity Reports � What the progress reports look like and require. � Different report formats even within the same agency such as HHS. � Major issue in reporting - Demographics are requested in different distributions. This requires re-counts for different grants. Example: some what ages 0-5, 6-12, 13-18 others what ages 0-2, 3-6, 7-9, 10-18 � In-home services for the elderly, case management requirements, specifically the number of times an assessment is required varies by funding and licensing source. � State Department of Commerce wants outcomes based programmatic reporting but Dept. of Ed wants outputs reporting � Example: Calculating clients served as real numbers vs. percentage of clients completing the program. Funding is based on clients completing the program, but performance measures are base on clients entering the program. � Head Start (US Dept Health & Human Services) reporting versus Community Services Block Grant (Office of Community Services...also US Dept Health & Human Services) reporting requirements. The meaning of an "outcome" is different, thus, even within the same federal department the standards are not "standardized" � There are several areas. The agency needs for reporting on students served all have different data needs. We spend a great deal of time meeting these requirements. � What is considered prevention services for youth can vary between the general population, to at-risk students (broad term) to first time offenders. � Interpretation of contact information with those served. � service learning and community activities � Federal Rehab Act: independent living services HUD: housing counseling State: independent living servcies County: housing counseling � Unit of Service: (1) Unduplicated client (2) Per unduplicated client contact (3) One unit of service per contact (4) one unit of service per each type of service per contact � "Clients served" is a definition that is used to compare different nonprofits with programs funded by the same government agency. But some nonprofits serve individuals, some serve families, some serve institutions. The numbers when put into a cross-comparison are loony. � Different definitions for prevention & intervention � Definition of providing service in a runaway situation, for example: for one funder the only definition may be face-to-face contact, whereas, in actuality, the staff may have spent hours on the phone talking to the parent and then the youth. Also, if the situation is resolved and they decide not to come into the office for further services, the hours of phone contacts are not considered as service contacts and not countable on service reports, whereas a lot of time and work was involved. � service learning and community activities � Objectives - they can be grant specific benchmarks or very general ideas. Then they change again when they discuss finances. � What is a service offered? On hour of client contact, or one hour of staff time. For instance, if more than one client attend a group event - can we bill for each, or not. This depends upon the funder. Outcomes � State Department of Commerce wants outcomes based programmatic reporting but Dept. of Ed wants outputs reporting � Outcome measurements for the same project � Example: Calculating clients served as real numbers vs. percentage of clients completing the program. Funding is based on clients completing the program, but performance measures are base on clients entering the program. � Head Start (US Dept Health & Human Services) reporting versus Community Services Block Grant (Office of Community Services...also US Dept Health & Human Services) reporting requirements. The meaning of an "outcome" is different, thus, even within the same federal department the standards are not "standardized" � "Performance-based contracting" -- federal (e.g., Dept. of Labor) definition conflicts with State and County interpretations. � Effective programs for substance abuse prevention � Employment retention is defined success as "full-tiome" and 90-days retention Financial Procedures and Cash Flow � A state agency allows only quarterly invoices, and takes 60 days to make payments. Thus, at the beginning of a project it will take 5 months (one quarter plus 60 days) to get the first payment. � We have several City contracts which became behind in reimbursement due to Government staffing issues resulting in an unpaid bill of $79,000 for a couple of months which presented a hardship for our agency with a $3 million annual budget. � Different government offices offer different payment rates for the same unit of service. � How the money comes to the agency - what kind of contract is required. � How much indirect is allowed for any particular grant. � The first thing that comes to mind is the varying fiscal years--some start March 1, some July 1, some October 1, and some follow the calendar year. � Budget object codes are different at federal, state, local levels. Reconciling expenditures across object codes for reporting is a nightmare. � What kind of changes are premitted in a budget without prior permission � We use CDBG and HOF funds. There are different environmental standards depending on which fund we use, as a result different reports to complete and different delays on approval of reimbursement creating a very difficult cash flow problem. � When vouchers are submitted to request payments we have agencies (State) that require documentation (payroll records and receipts for purchases) in extreme detail. Other agencies will process a voucher based on a listing of expenses and narrative progress report. � Audit terminology is different for funding categories for each agency. Indirect costs are defined differently and accounted for in different ways for each agency. � Administrative fees run from 5-12% allowable. Allowable expenses definitions vary. Financial Reports � Some agencies have on-line financial reports; some require reports on standard OMB forms. Some even require copied invoices for evry transaction, assuming we are a small non-profit with weak internal control. Compliance rules (budget revision rules, etc.) vary from agency to agency; this requires extra oversight. � HUD requires our A-133 Audits to be translated into their formats. � Workforce requirements are significantly more stringent with regard to amendments, use of budget, and billing requirements than those received from the U.S. Department of Education or the state education agency. � Objectives - they can be grant specific benchmarks or very general ideas. Then they change again when they discuss finances. � What is a service offered? On hour of client contact, or one hour of staff time. For instance, if more than one client attend a group event - can we bill for each, or not. This depends upon the funder. � varying definitions for what earned income categories should include Whether operating budgets should or should not include capital expenditures and what is considered a capital expenditure. � administrative cost definitions and their limits are quite varied between most grants and contracts Overhead and Misc. Expenses � Defin. of building improvements. Policy on purchasing cars but not stoves � Program costs are general in some grants and specific, tangible goods in other grants � Definition of overhead not clear � Unit cost and what it includes � definition of "equipment" based on different cost levels � Equipment, supplies, travel � Equipment anything over $1,000 and Supplies anything under $1,000 per unit. A chair and a desk are therefore supplies. At my institution these are equipment. This requires double bookkeeping. � Sometimes "equipment" is called "supplies." They think "contract services" and "consultant contracts" are different things. � definition of what is equipment vs supply � NYS defines equipment as $1,000 or more. Federal equipment is $5,000 or more � definition of rural definition of microcredit � indirect costs management and general � indirect costs, F&A � Indirect costs; administrative costs � Standards for any one technology vary from agency to agency. � 1) Definition of an eligible institution 2) Definition of a minority institution 3) Level of Indirect cost reimbursement 4) Definition of infrastructure 5) State, Local, Federal Differences � Both local government agencies and state government agencies all have widely varying budget forms, that all are highly detailed and non-transferable. They also have variously differing format for presenting audience attendance data. � When vouchers are submitted to request payments we have agencies (State) that require documentation (payroll records and receipts for purchases) in extreme detail. Other agencies will process a voucher based on a listing of expenses and narrative progress report. � Separate grant applications from local sponsor, local government and federal government. Also funding periods are different making this more confusing � HUD proposals are particularly repetitive. Questions are asked in different ways at least twice in the grant application. Other federal funding applications are similar. State and local funding applications have greatly improved over the last couple of years but could still be more streamlined. � Federal regulations require certain activities; when the funds are channeled through the state, the state adds its own set of regulations to the same RFP. � Technology funding is monitored differently between federal and state grants. State monitoring is more paper work and time consuming for the same standard of assistance. � Budget object codes are different at federal, state, local levels. Reconciling expenditures across object codes for reporting is a nightmare. Forms � Forms 269 and 270 from one funding agency to another bear no resemblance to each other except for the form number; The legal forms requirements are all the same but every agency has a slightly different form. � Fed Form 424A can be filled out differently by agency apparently due to Congress giving different instructions to each agency Q. 14 Examples: Multiple Reports for Same Activities (Some examples fit more than one category, and appear in all relevant categories.) General Comment � Each funding source has different reporting requirements - both financial and programatic - thus leading to up to 20 different reports for the same project - often due at different but similar dates with different definitions and different formats. It is enough to drive even the most calm and organized person insane! Data � The reporting data for federal reports and the reports for grants are rarely the same. � Activities reports for the DOE must also be reported to the state but data requested in each report differs � Homeless shelter and other programs with multiple funding sources each require different cuts on the same data. Thats alright, but lets get a standard format and use it for as many sources as possible. � Child Care Subsidy - client information and data - local child care funding agency - state government � If we have several different funders, each funding a program partially, the narrative report that is sent is similar for both (or more). Only the numbers would be different. Also, each one may be requesting statitical information about slightly different aspects of the same program, so information has to be gathered different ways, or the information extracted from the data and put into different reports. In reality, to maintain a broad base of funding so no program is totally dependent on one funding stream and therefore vulnerble to program failure if a source dries up, one has to have this type of multiple reporting. However, funders should realize that in this day and age with the technological possibilities that exist to support this type of multiple reporting, if they would pay for more tech support in the form of tech personnel, it would be easier to support the multiple reports. � Title 20, Child Care Development Fund and School Lunch require attendance records on forms unique to each. This is redundant and time consuming. We take attendance electronically when children enter and leave the facility, but we must transcribe this attendance onto the proper form and manually add the days of attendance Demographics � Each of these documents [county & state reports] has different definitions for the same questions. eg. population age 0-5, on one form and 0-18 0n another... county and state monthly reports: county requires significant documentation and specilized database system � I file annual county reports on the population we serve, a very comprehensive and time consuming task. As of last year, we are also required to file quarterly state reports on the population we serve. Outcomes � Reports are required by each government funder and these reports are different. Each has different demographic information requirements and outcomes. � Same program report restated according to the different outcome measurement definitions. � Homeless assistance services provided under McKinney and CDBG are the same services, but have different measures of success and reporting requirements Activities � Activities reports for the DOE must also be reported to the state but data requested in each report differs � when using federal,state and local funds to support an activity. Different activity recording requirements from each federal source or federal/state combination sources also seperate finance reporting � I submit activity and expense reports to at least 2 fudning sources for each of our 4 programs; one of them I will have to submit 6 or 7 next year. � Learning Disabilities Center at the University of Georgia must file separate reports with the State of Georgia and the Federal Dept. of Education for the same activities. Reporting requirements are somewhat different at the State and Federal levels. In addition, we must also file reports with the University and with the State Regents (separate from other state agencies). Format � Statistical reports on homeless services are required by local and state funding sources and the same information is requested but in different categories and formats. � Federal funding source and state source want to know same information but different formats. � Governemnt requires reports - Project Progress Report, Programming for Impact County requires report Sponsor (UW) requires report All with different formats and content � In our organization, we have a Domestic Violence shelter. This activity is supported by between 6 and 10 grants/contracts. Each source of support requires different financial reports, all in different formats, with none of the funding sources receiving a "total" report. We prepare "total" reports internally. � SHOP and HOME are both HUD funded and require very different reporting and documentation. All require far too much volume killing far too many trees! State/Local/Federal � Statistical reports on homeless services are required by local and state funding sources and the same information is requested but in different categories and formats. � Each of these documents [county & state reports] has different definitions for the same questions. eg. population age 0-5, on one form and 0-18 0n another... county and state monthly reports: county requires significant documentation and specilized database system � Activities reports for the DOE must also be reported to the state but data requested in each report differs � Federal funding source and state source want to know same information but different formats. � report to local, county, state all require different procedures � when using federal,state and local funds to support an activity. Different activity recording requirements from each federal source or federal/state combination sources also seperate finance reporting � Reports to federal source are different than to Cities and again different to United Way(s) � City and state sources fund same activities, yet we have to submit separate reports for same activities to two different sources, sometimes more. � Financial and narrative and different for different funders for the same program � Might have to file same report for state or federal grant. � so far we just get local funding however we have to report the same thing several times with minor changes on the paper work. � We file multiple reports to state and local funders for the same program. � Programs that are funded by federal and state grants--each level of government requires activity reports. � State literacy funding in Arkansas ask for the same as federal Adult Education funding in Arkansas. � Must send an annual report to local county commissioners and to the state-governors office. � Monthly reports on service activities and units of service/costs to county, state and federal agencies funding the same program. � Learning Disabilities Center at the University of Georgia must file separate reports with the State of Georgia and the Federal Dept. of Education for the same activities. Reporting requirements are somewhat different at the State and Federal levels. In addition, we must also file reports with the University and with the State Regents (separate from other state agencies). � In our adult outpatient program, we report separately to the State, City and County, the same demographic information for persons served. Matching Requirements � Federal Grants matched with State dollars require separate reports to both agencies. Audits/Reviews � On housing funded with HOME and LIHTC, there are multiple Housing Quality inspections, all very hard on tenants. Tenant certification process has become more invasive and time consuming. For 1 project, monitoring requirements require three seperate reports, all asking essentially the same info, just i9n slightly different formats � For Medicaid/State funding and for HUD, we are audited and reviewed by different agencies for similar services Same Report Many Times � Depending upon the funding source, some require on annual report, others require quarterly reports � Have to file a monthly report and then have to file a quarterly report which is basically the same thing only for three months instead of one. � I file annual county reports on the population we serve, a very comprehensive and time consuming task. As of last year, we are also required to file quarterly state reports on the population we serve. � Monthly report for CDBG funds, quarterly reports for OJJDP and local community funding. � Due to the overlap of Title 4e Medicaid and pass thru funding. � I submit activity and expense reports to at least 2 fudning sources for each of our 4 programs; one of them I will have to submit 6 or 7 next year. � Accounting reimbursements: file monthly request with one division then you must file the same information quarterly with another division. � We have some overlap of reporting to different agencies as well as progress/interim reports followed by final reports. � I file 5 different reports to support parents of children with disabilities � One local agency has not reviewed its own RFP in more than a year and has relied on 2-3 month contract extensions to continue funding. Each extension requires a new (lengthy) report with the same information. � Monthly reports on service activities and units of service/costs to county, state and federal agencies funding the same program. � A report for AmeriCorps A report to the City A report to FIA � Identical progress reports on student activities and outcomes three times throughout the year, then a final summarizing these three reports! � Every contract requires a specific funder report on project activities. Funders do not have a common form. Information must be captured one way for DJJ and another for DCF. � Receive partial funds from different agencies so must send separate reports to each. � so far we just get local funding however we have to report the same thing several times with minor changes on the paper work. � State Telecommunications Infrastructure Fund grants require multiple reports on expenditures. � On overall programs we file program reports to each funding agency modified to meet the objectives of that particular funding source. � Reports for CSBG funding plus reports for other funders who provide additional support (WIC, Dept. of Transportation, Dept. of Ed., etc) � I am not certain, but I believe that our transitional housing program for elderly and disabled homeless persons may file similar reports for the same activities to the State of Arizona and the City of Phoenix. � The grants that have over one year delivery time require reports that repeat the same collected material every year. � If we get GOS support from NYSCA and project support for NEA we need to fill out 2 final reports to cover the overlapping project. � It is understandable that there will be multiple reports on the same activity since there are multiple funders. Each funder may need feedback on different aspects of the activities. Miscellaneous Responses � Centers for Disease Control has divided its HIV prevention funding up into so many disparate parts that it has become a nightmare for agencies trying to work with ethnic populations. At one time, all these HIV prevention activities were undertaken with a single cooperative agreement. � Most of our work is project work driven by local need. Funds support pieces of project work, so we explain project in as many different ways as funds that support it. Most funding streams emphasize sustainability, but some projects are not intended to turn into programs. This forces us into some odd boxes � We have to report work completed for funds as they are requested during the infastructure period from SHOP. Even when the SHOP monies are spent, we still have to supply monthly reports until the entire house is built even though the money from SHOP only funds the infastructure. � Since govt. funding from one source is insufficient to cover the cost of services, more than one source is needed. When one succeeds in getting full funding, then, one must complete reports to each funder, and to allocate outcomes somehow among them.