Sneak Preview: OMB Urged To Clarify Expired Grant Guidance
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Office of Management and Budget (OMB) should adjust its guidance to specific agencies to ensure they understand how to comply with reporting requirements for expired grants established under the annual Commerce, Justice, Science and Related Agencies Appropriations Act, also known as the Section 530 requirements, according to a recommendation in a recent Government Accountability Office (GAO) report.
The uniform guidance establishes closeout procedures that must be completed by both the grantee and the awarding agency (§200.344). Generally, within 120 calendar days of the period of performance end date, the grantee must complete its closeout actions and submit to the awarding agency all closeout documentation. The awarding agency then must take steps to complete its closeout action within one year of the grant’s period of performance end date, unless otherwise directed by authorizing statutes (see ¶466 in the Federal Grants Management Module). Agencies must return grant funds not disbursed before the award has expired to the Department of the Treasury.
Circular A-136 vs. Section 530
OMB Circular A-136 requires federal awarding agencies to report on the number of expired grants with undisbursed balances and zero-dollar balances. In addition, under the Section 530 requirements, the departments of Commerce (DOC) and Justice (DOJ), along with the National Aeronautics and Space Administration (NASA) and National Science Foundation (NSF), must report either within their annual agency financial report (AFR) or performance and accountability report (PAR) on: (1) future actions the agency will take to resolve undisbursed balances; (2) methods used to track undisbursed balances from expired grants; (3) identification of undisbursed balances from expired grants that may be returned to the Treasury; and (4) details about the total number of expired grants with undisbursed balances and the total amount that has not been obligated to a specific project remaining in the accounts for the preceding three fiscal years.
GAO conducted a review to determine if DOC, DOJ, NASA and NSF had complied with OMB Circular A-136 and the Section 530 requirements for federal fiscal years 2017 through FY 2021. While it found that all of the selected agencies met applicable governmentwide reporting requirements for expired grants under Circular A-136, GAO concluded that the agencies only effectively complied with the first two of the four Section 530 reporting requirements. For the other two requirements, agency information was inaccurately reported because OMB’s Section 530 guidance (OMB Memorandum M-16-18), issued in July 2016, was unclear.
(The full version of this story has now been made available to all for a limited time here.)
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