OMB Grant Memoranda

The following Office of Management and Budget (OMB) memoranda offer a window into how grant policy is implemented through the Executive Office of the President:

M-18-24 Strategies to Reduce Grant Recipient Reporting Burden (2018)

OMB Memorandum M-18-24 provides guidance to federal agencies to implement lessons learned from the Digital Accountability and Transparency Act (DATA Act) of 2014. Some highlights include:

• Integrating New Data Standards - By September 30, 2018, "government-wide core grants management data standards are expected to be finalized by the Grants Management Federal Integrated Business Framework (FIBF)." By April 30, 2019, "agencies must submit a plan to OMB that describes their strategy for integrating the new data standards into current and/or future grant systems."

• SF-424B Form Phase-Out - Effective January 1, 2019, "the SF-424B will become optional and agencies shall make plans to phase out use in Funding Opportunity Announcements."

• Centralized Certifications and Representations using System for Award Management (SAM) - Effective January 1, 2020, SAM.gov "will become the central repository for common government-wide certifications and representations required of Federal grants recipients. ... Federal agencies will use SAM information to comply with award requirements and avoid increased burden and costs of separate requests for such information."

• Sharing of Systems and Services - Agencies are to "work with other agencies and OMB to reduce the number of existing legacy systems and grants recipient burden via sharing quality services and systems."

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M-18-18 Implementing Statutory Changes to the Micro-Purchase and the Simplified Acquisition Thresholds for Financial Assistance (2018)

OMB Memorandum M-18-18 announced, in accordance with recent statutory changes set forth in the National Defense Authorization Acts (NDAA) for Fiscal Years 2017 and 2018, an increase in the threshold for micro-purchases under federal financial assistance awards to $10,000, and increases the threshold for simplified acquisitions to $250,000 for all recipients. Federal awarding "agencies are required to implement these changes in the terms and conditions of their awards, and recipients of existing federal financial assistance awards may implement them in their internal controls."
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M-17-26 Reducing Burden for Federal Agencies by Rescinding and Modifying OMB Memorandum (2017)

OMB Memorandum M-17-26 identified and eliminated a variety of federal regulations to reduce burdens on federal agencies. This included removing three grants management related requirements, including the dissolution of Council on Financial Assistance Reform (COFAR). The U.S. Chief Financial Officers Council (CFOC) will now consider financial assistance priorities. Below is the grants management section of M-17-26:

"Grants Management Related Requirements - M-14-17, M-12-01, and OMB's Controller Alert of December 2016: To help reduce the burden for grants management related requirements, agencies are no longer required to: 1) report the metrics measuring the impact of the Uniform Guidance (2 C.F.R. Part 200), as instructed by OMB Memorandum M-14-17, and 2) prepare for an expanded Catalog of Federal Domestic Assistance numbering schematic,  as informed by OMB's Controller Alert of December 2016. In addition, the Council on Financial Assistance Reform (COFAR), an interagency group of Executive Branch 4Eliminated – Financial Management (Cont.): officials that was established by OMB Memorandum M-2-01, is disbanded. Moving forward, financial assistance priorities will be considered by the Chief Financial Officers (CFO) Council, consistent with the goal of involving a broader community of grant-making agencies to participate in developing priorities for reforming Federal grants management."
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M-14-17 Metrics for Uniform Guidance (2 C.F.R. 200) (2014)

The OMB summarizes the major reforms in the Super-Circular known as "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" – or simply as "Uniform Guidance" – and outlines metrics that will help the government gauge their effectiveness.
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M-10-16 Grants.gov – Return to Normal Operations (2010)

The OMB instructs Federal grant-making agencies that began using alternative methods to collect applications during the peak Recovery Act period to resume their normal use of Grants.gov's Find and Apply functions.
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M-09-17 Improving Grants.gov (2009)

The OMB asks Federal grant-making agencies to help cover the costs required to improve Grants.gov amid the Recovery Act implementation. Thousands of additional applications for assistance are coming through the Grants.gov system and improvements are needed to "establish a foundation for a more efficient, flexible, and reliable system in the future."
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M-09-14 Recovery Act Implementation – Improving Grants.gov and Other Critical Systems (2009)

The OMB instructs the Department of Health and Human Services and the General Services Administration to develop a plan to improve Grants.gov in light of the expected influx of applications as a part of the Recovery Act. Grant-making agencies are asked to make preparations to accept grant applications via temporary, alternative methods in case Grants.gov goes down during critical periods.
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M-08-19 Authority to Collect DUNS Number to Meet Requirements of the Federal Funding Accountability and Transparency Act of 2006 (2008)

The OMB instructs agencies to collect Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS) numbers in applications for all types of financial assistance subject to the Federal Funding Accountability and Transparency Act of 2006 ("Transparency Act," P.L.109-282). Prior to this, the OMB had previously only required agencies to collect DUNS numbers for grants and cooperative agreements.
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M-04-05 Clarification of Passback Language to Grant-Making Agencies (2004)

The OMB clarifies its directive to Federal grant-making agencies, explaining that they should designate funds to cover the cost of migrating existing grant management systems to Grants.gov. The new website is a platform through which agencies are to announce their funding opportunities and collect grant applications.
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M-04-01 OMB Issues Grants.gov FIND Policy (2003)

The OMB directs all Federal grant-making agencies to publish funding opportunity announcements – called "synopses" – on Grants.gov. These announcements allow the public to identify funding opportunities for which they can apply. Grants.gov is part of the extended implementation of the Federal Financial Assistance Management Improvement Act of 1999 (Public Law 106-107).
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