As part of its effort to streamline the federal grants process, the Office of Management and Budget has published updated versions of its grants circulars that make definitions of key terms consistent for all types of grantees. The new Title 2 of the Code of Federal Regulations will centralize all policy guidance and rules for grants and cooperative agreements. The Federal Financial Assistance Management Improvement Act (FFAMIA) requires the federal government to simplify the grants process. In August 2003 OMB proposed changes to its guidance on cost principles that would reduce confusion by making descriptions of similar cost items consistent in three of its Circulars: A-21 (Educational Institutions), A-87 (State, Local and Indian Tribal Governments) and A-122 (Non-Profit Organizations). The OMB announcement includes a chart so that grantees can compare the old and new versions of the cost principles. There were no changes to the existing definition of lobbying in A-122, but a new section (d), Executive Lobbying Costs, was added. It disallows costs for "attempting to improperly influence, either directly or indirectly, an employee or officer of the Executive Branch of the Federal Government to give consideration or to act regarding a sponsored agreement or a regulatory matter. Improper influence means any influence that induces or tends to induce a Federal employee or officer to give consideration or to act regarding a federally-sponsored agreement or regulatory matter on a basis other than the merits of the matter." The definition of "executive lobbying" is consistent with federal law prohibiting use of federal funds to lobby for a grant award or cooperative agreement. It allows advocacy on federal regulatory matters as long as it is based on the "merits of the matter". The simplified cost principles will affect more than 600 programs administered by 26 federal agencies. Currently the federal government spends about $400 billion per year on these programs. The announcement acknowledged that many programs rely on more than one federal grant from more than one agency, adding to the complexity of grant administration. Some of the 184 comments OMB received suggested improvements to the circulars. However, OMB will consider such changes in the future. On May 11 OMB announced that it has created a new Title 2 in the Code of Federal Regulations that will be a central point of reference for all government wide guidance on grants. The announcement said subtitle A will include all government wide guidance for grants and cooperative agreements, and subtitle B will contain all specific agency regulations adopting OMB guidance. Subtitle A will be published in two phases. First, a Chapter II will include all guidance and circulars in their current form. As changes are made and finalized they will be published in Chapter I and the old version in Chapter 2 will be deleted. OMB Circulars will continue to be available on OMB's website. The announcement said OMB is working with an interagency group to "consider ways to improve the OMB guidance and to develop an outline, to the extent possible, for agency regulations implementing the guidance." After final changes to the Circulars are completed, OMB will review agency regulations to ensure conformity. However, OMB said the diversity of programs "makes it inappropriate for the OMB guidance to prescribe all of the agency-specific and program-specific requirements that may be needed." Agencies are required to provide OMB with justification for any alternative or additional provisions in their regulations.