May 4 – 8, 2020
The following post is from Thompson Grants weekly delivery of grant- and audit-related news and analysis from their editors, conveniently organized in pre-award, post-award and audit categories. It also provides readers with the latest Grants Intelligence articles from experts in the grants community, responses to subscriber questions, links to their most recent newsletter issues and e-learning offerings, and upcoming webinars.
Because the nation’s response to concerns about the Novel Coronavirus 2019 (COVID-19) has dramatically affected traditonal grant processes, Thompson Grants is now offering a continuously updated roundup in our Top News section containing grant-specific links for grant applicants and recipients posted by federal agencies, as well as from Congress and the Office of Management and Budget. The roundup is available here.
Grants Development NewsED Provides $13B for COVID-19 Education Relief
The Department of Education (ED) has made available more than $13.2 billion to states under the Elementary and Secondary School Education Relief (ESSER) Fund to support continued learning for K-12 students whose educations have been disrupted by the response to the COVID-19 pandemic. States, however, should be aware of the statutory restrictions placed on the administrative portion of the funding.
Grants Management NewsGAO Urges Action on Key Open Recommendations
The Government Accountability Office (GAO) is calling for six federal agencies to respond to high-priority recommendations it made in its reports over the past several years, as many of these reports pertain to the need to reduce improper payments and address weaknesses in federal grant program oversight.
READ MOREORI Wants Input on Sequestering Digital Data During Misconduct Investigations
The Department of Health and Human Services (HHS) Office of Research Integrity (ORI) is trying to determine the best way to sequester digital evidence in a research misconduct investigation, and is asking for stakeholder input to this effort.
READ MOREFederal Agency Issuances
A Compilation of Award Guidance, Notices and Regulatory Updates Issued by Federal Agencies and Offices
Agriculture
National Institute of Food and Agriculture
Sought written stakeholder input on the Urban, Indoor and other Emerging Agricultural Production Research, Education and Extension Initiative. 85 Fed. Reg. 22124-22125, April 21, 2020; https://www.federalregister.gov/documents/2020/04/21/2020-08402/solicitation-of-stakeholder-input-for-urban-indoor-and-other-emerging-agricultural-production.
Single Audit NewsHHS OIG Calls for Iowa To Return Medicaid Funds
Although the Iowa Medicaid Enterprise (IME), which oversees the state’s Medicaid program, has taken steps to better monitor Medicaid home health services’ providers to ensure they document services billed to the program, the federal Department of Health and Human Services (HHS) Office of Inspector General (OIG), in a recent audit, recommended that the state return more than $37 million in improper Medicaid reimbursement claims charged during the audit period.
Grants Intelligence – May 2020The Bayh-Dole Act: 40 Years and Counting!
In December 1980, Congress passed the Bayh-Dole Act (Pub. L. 96-517), implementing special rules for patent rights of inventions resulting from federally funded research. With 2020 marking the 40th anniversary of its passage into law, the Bayh-Dole Act, and more specifically how its provisions relate to the federal government’s “march-in” rights, has been appearing in the news more frequently as lawmakers have been discussing possible steps to, among other things, lower drug prices. This discussion became more topical as the novel coronavirus spread across the world, pressuring countries to quickly create a vaccine that is both safe and affordable. On March 6, President Trump signed the Coronavirus Preparedness and Response Supplemental Appropriations Act (Pub. L. 116-123), which provided the Department of Health and Human Services (HHS) with $3.1 billion to develop a vaccine. As companies and scientists partner with federal agencies to work to create a vaccine, it’s important for nonfederal entities (NFEs) to be reminded of the Bayh-Dole Act and its tremendous benefits to NFEs.
Ask the ExpertHow Long Do Pass-Through Entities Have To Pay Funds to Subrecipients?
Q: Is there a time requirement for the payment of federal grant funds from a state pass-through entity to a subrecipient (providing that the pass-through entity has received all required reporting documents from the subrecipient)? Christy from Las Vegas
READ MORECan We Issue a Subaward to an Entity Without an Active Account in SAM.gov?
Q: We are in the process of contracting with a subrecipient and during the vetting process, we noticed that they have not renewed their SAM.gov status and they are currently expired. They have not been suspended or debarred. My question is, can we still contract with them and advise them that they need to renew? I reviewed the uniform guidance and it states that we should check for the suspension and debarment status, but not necessarily the active status. I also know that there is some lag time in getting the system updated. Please advise. Juan from Los Angeles, Calif.
Monthly Newsletters and Recent Handbook Updates
We take all the news each month and compile into a monthly newsletter for your files, and make continuous updates to our publications to keep them current.
Federal Grants Development Handbook:
¶270 — Updated links and made editorial revisions
¶113 — Updated section to include information about the GREAT Act
¶114 — Created new section to discuss COVID-19 response’s implications for grants
Federal Grants Management Handbook:
Federal Grants Management Handbook Newsletter, May 2020
¶370 – Added new section entitled “COVID-19 Implications for Grants”
¶474 — Made editorial revisions and updated links
¶476 — Added information on Performance.gov and made other editorial revisions
¶516 — Made editorial revisions and updated links
¶519 — Added information about Never Contract With the Enemy
Single Audit Information Service:
Single Audit Information Service Newsletter, May 2020
Guidance ¶332 — Made editorial revisions
Guide to Managing Federal Grants for Colleges and Universities:
Federal Grants News Newsletter, May 2020
¶370 – Added new section entitled “COVID-19 Implications for Grants”
¶741 — Added decision making chart and made editorial revisions
| WEBINARS AND TRAINING OPPORTUNITIES YOU DON’T WANT TO MISS |
Indirect Costs and Cost Allocation Plans – An eLearning Course
Karen Norris | Self-guided course
In this eLearning course, Karen Norris, a national consultant and subject matter expert for k4rnoco, a K4ren Norris Company, and formerly with Thompson Information Services, will discuss the changes in the new uniform grant reform guidance related to calculating and charging indirect costs to federal grants. The presentations will include: an overview on indirect cost rates, including developing and submitting indirect cost rate proposals; how the rules governing indirect costs have changed; and provide practical examples how agencies can prepare for these changes.
Revising Your Policies for a Standard Emergency Policy Framework
Sandra Swab |Thursday, May 14, 2020 | 1:00 – 2:30 PM ET
If you receive or manage federal funding, chances are your grant policies will need to be revised. For starters, OMB has proposed uniform guidance revisions. Many of the requirements would also tie in new ways to CAP Goal #8, Results-Oriented Accountability for Grants. Plus, OMB’s issuance of exceptions for the COVID-19 emergency raises questions about where new SOPs may be needed. Remember, many of the coming changes will have implementation deadlines. Prepare now with expert help on what policies you may need to revise—and how long it will take.
May’s COVID-19 Grants Management Update
Jack Reagan |Thursday, May 21, 2020 | 1:00 – 2:30 PM ET
During these unprecedent times, the grants management process has been changing. With each month bringing new regulations, researching federal aid for your organization can be time consuming. From the new $2 trillion Coronavirus Aid, Relief and Economic Security (CARES) Act to The Office of Management and Budget’s (OMB) actions affecting grants management, it’s critical to understand the opportunities and how to take advantage of them. This new webinar provides the up-to-date information you need to take the right steps.
Be Prepared for Post-Pandemic Audits
Dismas Locaria |Thursday, May 28, 2020 | 1:00 – 2:30 PM ET
What happens when noncompliance is discovered after federal funding has been awarded? You immediately face disclosure obligations. It is critical to handle disclosure and agency interaction effectively. It helps if you can point to a strong compliance program that shows your commitment to meeting your obligations under the uniform guidance. Preparing now can make all the difference in avoiding severe enforcement, including staggering penalties under the False Claim Act. Let an expert on the uniform guidance show you how.
Asking Permission vs. Begging Forgiveness: Unraveling the Need for Prior Approval
Toni Demaglio |Tuesday, June 09, 2020 | 1:00 – 2:30 PM ET
There are times when it may be better to beg forgiveness than to ask permission. Modifying your grant budget isn’t one of them. Neither is making changes in your project activities. Procuring goods or services without prior written approval from a federal funding agency can trigger consequences no grant recipient wants to face: unallowable costs. In this upcoming webinar, a seasoned grants expert shows you steps you can take to seek the required permission—and win approval.