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Office of Grants Management Grants Management Fundamentals

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1 Office of Grants Management Grants Management Fundamentals
Office of the National Coordinator for Health Information Technology (O N C) Grants 101

2 Office of Grants Management – Organization and Functions
Systems and Data Management Bianca Costa Collect, report, and manage grants management data Analyze grant data to identify trends in implementation of funds ONC administrator for grants management systems GMO: Workforce Training and Technical Assistance Jen Cramer Develop and deliver grants management training for external stakeholders and ONC staff Provide customized, direct technical assistance services Coordinate overall grants management training and technical assistance efforts GMO: Beacon and SHARP Grant Operations Arlene Ramsey Provide procedural and technical business support to award recipients and ONC program offices Conduct on-site monitoring visits and desk reviews Develop grants management standard operating procedures GMO: REC and State HIE Office of Grants Management (OGM) Lisa Lewis Chief Grants Management Officer Policy Wendy Kilgore Develop and manage ONC grants management policies Facilitate objective reviews Liaison with other HHS Grants Management Offices Systems and Data Support Bianca Costa Cameline Toro Geoffrey Ntosi Policy Wendy Kilgore Training/TA Jen Cramer Wes Day Operations Arlene Ramsey Monifa Constant Kiki Halloun Yolanda Teagle Front Office Ellen Wesley 2

3 O G M - Responsible for the Portfolio of O N C Cooperative Agreements
Workforce: Competency Examination Curriculum Development Centers University Based Training Community College SHARP Beacon Regional Extension State Health Information Exchange 156 Cooperative Agreements Totaling $1,554,218,978 HIE - $547,703,438 REC (62 awards) SHARP – (4 awards) $60,000,000 BEACON – (17 awards) $219,999, new awards $30,000,000 Community Colleges - $35,725,590 Curriculum Development - $10,000,000 Competency Exams - $6,000,000 University Based Training - $32,000,000 9 non-ARRA agreements

4 O N C’s Program Offices and Grants Office Partnership
Answer grantee questions on complex technical grants business management matters Perform budget analyses & business mgmt capability assessments & perform budget negotiations Take action to withhold payment, suspend or terminate award or to lift withholding or suspension Provide input on satisfaction of business mgmt special conditions; lift restrictions via NGA Identify potential or existing problems (business mgmt & program) & alert PO Ensure effective use of funds by monitoring commitments & projecting future funding requirements Review financial status reports & evaluate financial performance against budget, program plan, etc. Document site visits & desk reviews & coordinate results with program office Conduct financial monitoring site visits & provide post-award TA Establish & maintain official award, program information, & institutional files Grants Management Team What is my role as a Grants Management Professional? Grants management experts GMO delegated specific authority to enter the Government into legally binding agreements Grants management team (GMOs and Specialists) handle the business and other non-programmatic areas of grant award and administration Ensure that for grants under their cognizance, both federal staff and grantees fulfill applicable statutory, regulatory, and administrative policy requirements, both pre and post award The GMO will ensure consistency across all programs: (1) bi-weekly Grants Steering Group Meetings (2) Program Information Notices and Program Announcement Letters (3) Standardized implementation of the same requirements – financial status reports; contract prior approvals; budget reviews, etc. AAGAM Chapter

5 O N C’s Program Offices and Grants Office Partnership
Answer grantee questions on programmatic grants matters Assist in ensuring budget submissions & expenditures comply with statute, regulation, & policy Provide program input on proposed withholding of payment/suspension/ termination of award & input before lifting Provide input on whether programmatic special conditions are satisfied or whether other action should be taken Identify potential or existing problems (program & business management) & alert program officials & GMO of findings Ensure adequate progress toward meeting milestones Review program progress reports & evaluate program performance, progress & changes in scope or objective Document reviews & grantee discussions & provide documentation to GMO for official file Conduct site visits to gauge progress and compliance or to provide post-award TA Establish and maintain PO files Project Officers What is my role as a Project Officer (PO)? Implement and execute program grants administration functions Subject matter experts Define programmatic objectives; describe objectives in program announcements; evaluate compliance with objectives; provide advice on the scientific or programmatic suitability of applications for funding Provide subject matter expertise in post-award administration  AAGAM Chapter

6 Partnership – The Key to Success
Maximize program success and integrity Foster program credibility Ensure rigor in stewardship Minimize audit findings Reduce disallowed costs Strengthen internal controls to prevent fraud, waste, and abuse Manage inherent risk Encourage professional development Foster synergy/collaboration

7 Grants Management Lifecycle
Review FOA Submit Application Revise Application Review Award Package Accept Award Drawdown Funds Submit Financial Reports Submit Performance Reports Submit Post-Award Requests Ensure Audit is Complete Generate Final Performance Reports Complete Drawdown of Funds Generate Final Financial Reports Submit Closeout Package Retain Records Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Program and Grants Management Training and Technical Assistance Assist Applicants Establish Commitments APPLY Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Establish Disposition of Funds Evaluate Final Performance Reports CLOSEOUT Obligate Funds Set Up Congressional Notification in System Release Funds Create Notice of Grant Award AWARD Notify Grantee of Award Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute ESTABLISH Allocate Funds Review and Approve Post-Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring MANAGE Review /Recommend Post-Award Actions Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo REVIEW Assess Funds Availability The grants management life cycle has many stages. In each stage there are key actions that must happen in order for a grant program to be successful. During the presentation we will walk - each stage and discuss the foundational rules and regulations, different roles and responsibilities, importance of each. 7

8 Grants Management Lifecycle – Establish
Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute Review FOA APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Allocate Funds Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Establish stage 8

9 Appropriations and Funding Process
Phase 1: Budget Formulation Phase 2: Budget Presentation and the Congressional Process Phase 3: Budget Execution 9

10 Budget Formulation HHS Budgets for Grant Programs HHS Budget Request HHS Total Budget Request O M B/President’s Budget to Congress

11 Appropriations Budget Presentation to Congress Congressional Budget Resolution Appropriation

12 Office of Management and Budget (O M B) Apportionment
Budget Execution Office of Management and Budget (O M B) Apportionment Budget Authority to distribute funds HHS Allotment O N C Allotment Allocations to Each Grant Program

13 Types of Appropriations
Annual: Must be obligated within the fiscal year O N C funds in HHS appropriations Multiple Year: Available for obligation for a definite period in excess of one fiscal year HHS has multi-year funds No-year: Available for obligation without financial year limitations A R R A funding no longer no year (Bennett Amendment) Annual funding expires at the end of the fiscal year in which it was appropriated.

14 Continuing Resolution
Applies if new Fiscal Year and annual appropriation is not passed Continues existing programs until annual appropriation passes Can impact internal operations and activities Legislation in the form of a joint resolution enacted by Congress, when the new fiscal year is about to begin or has begun, to provide budget authority for Federal agencies and programs to continue in operation until the regular appropriations acts are enacted.” The national government's budget calendar runs from October 1st - September 30th of each year. Each federal department, agency and program is authorized to spend congressionally specified amounts of money. That money cannot be spent, however, unless it is explicitly appropriated. For example, an agency might be authorized to spend $2 billion on a program, but it does not actually have that money to spend until it is appropriated for that program.

15 Funding Opportunity Announcement (FOA)
All information integral to the competition must be explicitly addressed General description Authorizing statute/Award information Eligibility requirements Cost share/matching requirements Application requirements Forms Budget and budget narrative Program narrative Other submission requirements Due dates Review Criteria Announcement dates Reporting requirements Other information The end result of the Establish grant period is the FOA. AAGAM Part 2: Pre-Award Chapter Information for Potential Applicants Competing for Grants

16 Grants Management Lifecycle – Apply
Submit Application Assist Applicants Establish Commitments APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Application stage 16

17 Applying for Funding HHS policy requires all competitive funding opportunities be announced at O M B mandated initiative No paper No other submission method accepted PL (which has since sunset) mandated that organizations move towards eGovernment. This law first required adoption of the DUNS in all grant systems/applications. This has since moved to posting announcements and receiving applications electronically… - Grants.gov Grants.gov is a portal to receive applications. There is no functionality to administer awards - grants.gov. Applications submitted - grants.gov are pulled into GATES, where ONC staff can review and process the applications/awards. Grants.gov Help Desk:   If applicants experience technical difficulties in Grants.gov, customer service can be reached by at or by phone at ( GRANTS). The Customer Support Center is open 24 hours a day, 7 days a week, excluding Federal holidays.  To expedite inquiries, grantees are asked to have the following information at hand:  Funding Opportunity Number, Name of Agency You Are Applying To, and the specific Area of Concern.

18 Critical Application Information
Applications must be complete and timely All forms and attachments must be submitted Incomplete applications will not be sent forward for review Late applications will not be sent forward for review All applicants must have a Dun and Bradstreet (D&B) Data Universal Numbering System (D U N S) number All applicants must register in the Central Contractor Registry (CCR) Applicants should allow a minimum of five days to complete the CCR registration. CCR online registration (http://www.ccr.gov) CCR registrations must be current and renewed every 12 months Applicants that do not have a D U N S number or have not registered with the CCR will not move forward for review.

19 Grants Management Lifecycle – Review
Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo Revise Application APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Assess Funds Availability Review stage 19

20 Objective Review Process
Completeness Review Grants staff All required forms All required attachments On-time submission Responsiveness Review Program staff All required program elements If YES to both → Panel review

21 Objective Review Process - continued
Panels of unbiased subject matter experts Endure no conflicts of interest and consistent examination of applications Intended to provide recommendations and advice on funding proposals Scores and ranking developed Final decisions determined by the program office Funding decision memo sent to Grants Management Office Objective review/panel scores are intended to provide recommendations. Minim of 3 reviews to each application Scores are normalized and applications ranked Justification necessary for applications funded out of rank order Program officials may perform additional reviews if necessary but must provide sufficient documentation Funding decision memo from PO to CGMO GMO for the program GMO policy Budget Deputy National Coordinators National Coordinator CGMO—final sign off

22 Program Office  Financial Review
Program Office Staff Review application budget to determine if costs are in line with program goals and objectives Review to ensure costs are for intended program purposes Signed transmittal slip indicating approval of budget Grants Management Staff Conduct detailed financial reviews Based on Program Office recommendations Coordination during the budget review process is critical to the success of the grantee’s projects and the program overall. Program reviews to tie program goals back to costs in budget. Grants reviews for compliance with rules and regulations

23 No Conflict of Interest
Financial Review A-133 Compliance No Conflict of Interest Applicant’s Standing (Good, Debarred, Suspended) https://www.epls.gov/ Dun and Bradstreet Budget Review A review the organization and past performance can indicate if a grantee may require additional oversight. Have audits been submitted on time? What findings related to HHS grants (or grants in general)? Dun and Bradstreet review—credit risk, cash, revenues, etc Historical Review of itemized budget

24 Budget Review and Approval Process
Each application must include a detailed budget (SF424A) and budget narrative for the project. The budget must be complete, reasonable, allowable, allocable and cost effective in relation to the proposed project. The budget narrative must provide a detailed justification for each cost included in the budget. All project related costs must be included in the appropriate cost categories. Generally in the grants management life cycle budgets are reviewed and approved during the pre-award “review” phase. In order to get the $ out the door, ONC made conditional awards. The awards were made without approval of the budget. Grantees were awarded funds but could not access until released by OGM.

25 Budget Review – Cost Principles
Uniform cost principles when implementing Federal grant programs 45 CFR and by reference 2 CFR Part 220 (A-21) – Educational Institutions 2 CFR Part 225 (A-87) – State Local and Indian Tribal Governments 2 CFR Part 230 (A-122) – Non-Profit Organizations 48 CFR 31.2 (Federal Acquisition Regulation (F A R)) – For Profit Organizations Grant regulations requires that a cost be: Necessary to the performance of the project Allowable (per FOA, cost principles, etc.) Reasonable Allocable to the project and consistently treated Permissible under State and Federal laws and regulations Must not result in a profit (Contractors generally have profit built in) For the prime or any subs that receive grants Claimed against only one award If an item of cost does not pass all tests –not allowed under grant

26 Budget Review – Object Categories and Key Requirements
Example of a 424a Classification of Costs: Direct Costs and Indirect Costs Direct Costs: Costs that can be identified specifically with a particular award, project or service

27 Budget Review – Personnel Budget Category
Must pay personnel at a rate paid with non-Federal dollars or comparable to like organizations/positions. Is the basis for determining each employee’s compensation described (annual salary and % time devoted)? Is each position identified by title/responsibility? Are time commitments and the amount of compensation stated and reasonable? Are salary increases anticipated during the grant period and are they justified (C O L A, etc) Are any personnel costs unallowable? Dual Compensation? Federal Employee? Besides the 424a, grantees need to provide a budget narrative which details each budget category. The first budget category is Personnel. Personnel - Must pay personnel at a rate paid with non-Federal dollars or comparable to like organizations/positions. Must justify top 3 highest paid executives.

28 Budget Review – Fringe Budget Category
Fringe Benefits – typically include health care, retirement plans, etc. Must consider: Is the amount specified as a separate line item? Is each type of benefit indicated separately or does the organization have an approved fringe benefit rate? Are fringe increases contemplated during the grant period? Are costs included in fringe benefits that are unallowable? Fringe Benefits - Must pay fringe benefits at the same percentage as paid with non-Federal dollars or comparable to like organizations/positions. A grantee cannot include costs that are not actual fringe benefits included in the organization fringe benefit policy. Parking/Bonuses—cannot include for folks working on grant if not normally FB

29 Budget Review – Travel Budget Category
Is the basis for computation provided? Is the travel necessary for the purpose of the program? Are travel costs separately identifiable and reasonable (location, transportation, hotel, meals, mileage)? Does the organization have a written travel policy? Is this travel policy being followed? If no written policy—must follow Federal guidelines Travel – Must be necessary for the program and must provide sufficient detail of costs. May use historical travel costs as basis. Items should be broken out; airfare, lodging, meals, etc.

30 Budget Review – Equipment Budget Category
Capitalization threshold Federal $5K and useful life more than 1 year Are equipment items specified by unit and cost? Is the request reasonable and allowable under the project? Does the organization have a procurement policy in place? Is a lease vs. purchase study necessary (vehicles, large items of equipment)? Are purchases distinguishable from rentals? Equipment - Must be reasonable and allowable

31 Budget Review – Supplies Budget Category
Are supplies listed separately? Office Training Research Other types of supplies How was cost determined? Is the basis for the cost reasonable? Monthly estimates are sufficient Consistently treated Supplies – Must be reasonable and allowable Consistently Treated – Direct/Indirect “Pick and Stick” Must be in IDC pool in indirect proposal/agreement

32 Budget Review – Contractual Budget Category
Is the type of each service to be rendered described? For Consultants/Individuals Is an hourly, daily or weekly base rate given? Are rates allowable, justified, reasonable and comparable to market? Is procurement method described? Are appropriate procurement procedures being followed? Contractual - Must maintain sufficient control of the program and meet fair and open competition requirements. Procurement standards 45 CFR Part 74.40; 45 CFR Part 92.36 Procurement GMM provides additional guidance on procurement standards/policy

33 Budget Review and Approval – Subrecipient Relationships
Subrecipient Relationships (Subgrants/Subawards or Contracts) Is a substantial portion of the programmatic work being performed by another entity - a grant or contract? Subawards are documented in the “other” category Subrecipient relationships in the form of a contract will be put in “contractual” If so, the following questions must be answered in regard to that specific grant or contract: Name of the subrecipient Method of selection Period of performance Scope of Work Method of Accountability Itemized budget and justification (separate SF 424As for the subrecipient) ONC Reviews Subrecipient Documentation to determine if: There are any programmatic eligibility restrictions on who may perform the work. The proposed subaward is necessary to meet the objective of the project or activity described in the application. The grantee will retain adequate oversight of the subaward activity, and The costs of the subaward are reasonable. OGM is not approving the contracts/subgrants themselves….we are approving the process the grantee is using to procure/award these contracts/grants. The grantees should have written policies and procedures which monitor activity/costs on subawards The grantee should have contractual deliverable tracking methods in place. The grantee is responsible for ensuring costs within contract/subawards are allowable

34 Budget Review – Other Budget Category
Are items listed by major type (space rental, printing, phone, maintenance, etc.)? Are all costs justified, reasonable and allowable? List each subaward and amount of award Ensure adequate subrecipient information is provided (see 6 elements) Include separate SF 424 A for each sub Other - Must describe costs in enough detail to ensure all costs are allowable. Must include subawards.

35 Budget Review – Indirect Costs
Costs incurred for a common/joint objective and cannot be readily identified with a specific activity typically include utilities, rent, administrative staff An organization may not charge specific costs both directly and indirectly Costs may not be assigned as an indirect cost to an award if any other cost incurred for the same purpose has been allocated to an award as a direct cost Indirect Costs - are not directly accountable to a cost object and often benefit more than one project To include in budget organizations must have a federally approved indirect cost rate agreement. HHS Division of Cost Allocation issues IDC agreements for non-profits. HHS DFAS issues IDC agreements to for profits organizations. Indirect Costs generally include: Maintenance of buildings Depreciation Rental expense Salaries of non program-specific employees (accounting, hr, legal, etc.)

36 Budget Review – Indirect Costs
Indirect Costs (continued) Must have a current Federally approved indirect cost rate agreement Is the rate applied to the correct distribution base? Need to consider: Is IDC rate current? Applied to appropriate base? The rate agreement must indicate the rate, base, period, exclusions. Several types of rates Final/Provisional Predetermined Fixed (with Carry Forward) On-site Off-site Research Training F&A Bases Total direct costs Total modified direct (excludes capitalized equipment and portion of subcontracts over $25k) Total direct labor (Salaries and FB) Total direct salaries and wages (exclusive of FB)

37 Recently in the News TierOne loses $19 million federal grant over CEO's fraud allegations September 6, 2010 University of Florida professor and wife indicted for fraudulent grant proposals October 30, 2009 Cornell University Will Pay $2.6M in Fraud Case March 24, 2009 Former Professor Pleads Guilty to Fraud on NSF Grant May 3, 2007 Switching gear…. Why do we do all these reviews? Let’s talk about misuse of funds….ONC does as much financial review up front to ensure that grantees understand rules and regulations – avoid violations TierOne loses $19 million federal grant over CEO's fraud allegations A Dallas-based telecommunications company has had a $19 million federal grant rescinded after government officials learned the company's chief executive had been accused of securities fraud. tier1_04bus.ART.State.Edition1.26c2ad1.html Former Professor Pleads Guilty to Fraud on NSF Grant In a rare case of prosecuted fraud in a National Science Foundation grant, a former professor at Tennessee State University has pleaded guilty to a federal felony charge of making false statements. The professor, Barbara A. Nye, was a former faculty member in the department of educational administration and executive director of its Research and Policy Center on Basic Skills. UF professor and wife indicted for fraudulent grant proposals A UF nuclear engineering professor and his wife have been indicted by a federal grand jury and arrested on charges related to $3.7 million in fraudulent grant proposals submitted to NASA, the U.S. Air Force and the Navy. cc4c03286.html C.U. Will Pay $2.6M in Fraud Case Weill Cornell Medical College has agreed to pay over $2.6 million to settle civil charges that Cornell defrauded the National Institutes of Health and the Department of Defense as it sought more than $14 million in federal research grants, Acting U.S. Attorney Lev Dassin announced earlier this month. case

38 Categories of Misuse of Federal Funds
Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of causes. We must manage with due diligence to ensure that DHHS funds are not misused. Mistakes Gross Negligence Criminal Fraud Recipient includes costs in budget which are unallowable under specific O N C awards. Examples include: Food, Scholarships, Contingencies Direct recipient failed to implement proper internal controls and adequately monitor subrecipient activity and expenditures resulting in theft of Federal funds. Recipients used Federal funds to pay for a wedding reception, building construction, and personal credit card bills. Resulted in loss of $500K and jail time. Fraud is the intentional, unlawful acquisition of benefits (money & services) by perpetrating wrongful acts affecting government programs and operations

39 Who Commits Grant Fraud?
When business entities, individuals, communities, and other organizations receive federal grant dollars, they are entrusted with their appropriate expenditure. Grant fraud is most often committed by: Grant recipients, company officers, business partners, board members, and managers Bookkeepers, financial staff, and employees Contractors and subcontractors engaged with the recipient Recipient consultants Further information:

40 Common Grant Fraud Scenarios
Grant fraud occurs in many ways, but some of the most common fraud scenarios include: Charging personal expenses as business expenses against the grant Charging for costs which have not been incurred Charging for inflated labor costs or hours Submitting invoices for personal expenses False information on grant applications, progress reports, etc. Creating fictitious records Further information:

41 Fraud Indicators Fraud is often difficult to detect and is a conclusion that is determined only after a careful examination of all the facts and circumstances. Indicators of fraud include: One person in control Lack of internal controls Altered records No separation of duties No prior audit Lack of responsiveness Allegations of fraudulent conduct Internal controls are KEY

42 Grants Management Lifecycle –Award
Obligate Funds Ensure Congressional Notification Release Funds Create Notice of Grant Award APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Notify Grantee of Award Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Award stage 42

43 Notice of Grant Award (NGA)
The Notice of Grant Award NGA is the official document used for grants/cooperative agreements Establishes legally binding arrangement between O N C and recipient Establishes Period of Performance Contains or references Terms and Conditions of the grant or cooperative agreement Obligates Federal Funds

44 Notice of Grant Award (NGA)
NGA includes: Grantee information Award information Project Period of Performance Budget Period of Performance Terms and Conditions of the award Project Period of Performance (POP) Example: 04/01/2010 – 3/31/2013 May begin obligating expenditures 04/01/2010 Not earlier unless pre-award costs are approved Budget Period of Performance May or may not be for the entire POP The period in which the POP extends beyond budget period indicates intention to provided support contingent upon: Availability of funds Satisfactory performance Continued best interest of Federal government May require submission of non-competing application

45 Award Notification and Acceptance
Grants Solutions NGA Terms and Conditions Award Acceptance First request for disbursement of funds Agree to abide by all applicable laws, regulations, program requirements, policy and terms and conditions Specific A R R A terms and conditions (incorporated by reference) Specific program and/or award T&C are added, as appropriate. ONC/OGM has a set of standard T&C. These include references to the 45 CFR, 2 CFR, A-133, HHS Grants Policy Statement Green Procurement Reporting requirements Payment information ARRA specific T&C are also included. GPS: I-33 “A recipient indicates acceptance of an awards and its associated terms and conditions by drawing or requesting funds from the designated HHS payment systems or office.

46 Grant vs. Cooperative Agreement
Grants are awarded to States, units of local government, or private organizations at the discretion of the awarding agency or on the basis of a formula. Grants are used to support a public purpose. Cooperative Agreements are awarded to States, units of local government, or private organizations at the discretion of the awarding agency. Like grants, cooperative agreements also support a public purpose. Substantial involvement is anticipated between the awarding agency and the recipient during performance of the contemplated activity. View as a “partnership” Cooperative agreements are not contracts Key difference between a Grant and a Cooperative Agreement– Substantial involvement. AAGAM--Chapter : Determining Appropriate Award Instrument. Includes detailed descriptions, tables, authorities on funding instruments.

47 Grants Management Lifecycle – Manage
Review and Approve Post-Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Review /Recommend Post-Award Actions Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Manage stage 47

48 Order of Precedence-Who is Top Dog?
Constitution of the United States Statutes Program Statutes (Authorizing Statutes) Generally Applicable Statutes Annual Appropriations Regulations Executive Orders O M B Circulars Policies Procedures Sometimes it may be confusing as to what rules to follow. The statute may say one thing, HHS policy says something else, your terms and conditions…..this is the Federal order of precedence.

49 Administrative Requirements vs. Cost Principles
Prescribe standards for grant administration to achieve uniformity and consistency for recipients of Federal Assistance Define allowable costs for different types of recipients; failure to mention a particular item of cost in the Cost Principles is not intended to imply that it is either allowable or unallowable Administrative requirements– Prescribes standards for grants administrations. Promotes consistency across gov’t Financial management systems Procurement requirements Reporting Record retention Cost Principles – describes what is a cost allowable at the highest level Must refer to cost principle AND program policy (FOA) A cost may be allowable under circular and not allowable under a program

50 Applicable Regulations
Summary of Applicable Regulations Grantee Type Administrative Requirements Cost Principles Audit Requirements State & Local Governments 45 CFR Part 92 2 CFR, Part 225 (A-87) A-133 Educational Institutions 45 CFR Part 74 45 CFR and by reference 2 CFR Part 220 (A-21) Non-Profits 2 CFR, Part 230 (A-122) Hospitals 45 CFR Part 74 Appendix E – Principles for determining costs applicable to research and development under grants and contracts with hospitals For Profit Organizations 45 CFR Part 74 Subpart E- Special provisions for awards to commercial organizations (no additional alternative for program income) FAR 31.2

51 Recipient Grants Management Responsibilities
Grantee responsibilities include: Cash management Maintaining adequate financial records Returning Federal funds for disallowed expenditures Complying with reporting requirements Reviewing and recording financial operations Budgeting and budget review Reporting irregularities Refrain from doing business with debarred and suspended organizations Cash management includes Accounting of receipts and expenditures; Federal and non- Federal sources; Disbursements; Interest 45 CFR Parts 92 and 74 HHS Grants Policy Statement

52 Recipient Grants Management Responsibilities Managing Subawards
A recipient has full responsibility for the conduct of the project or activity supported and for the results achieved Direct recipients are responsible for adequate monitoring of subawardee activities 45 CFR Part or 74.51, Monitoring and Reporting Program Performance 45 CFR Part 92.40, Monitoring and Reporting Program Performance Grantees are responsible for managing day to day activities Monitoring activities of subs

53 Financial Management Systems
At a minimum, a grantee’s financial system should be able to: Meet 45 CFR or 74.21, Standards for financial management systems Provide financial and performance reporting required by 45 CFR Part 92 and 74, and other regulations Associate grant expenditures with the specific funding source and application of funds Provide a clear audit trail Comply with the Cash Management Improvement Act Minimize the time elapsing between the transfer of funds and disbursement by the grantee or subgrantee in accordance with Treasury Regulation 31 CFR 205. A State should follow the same state laws and procedures as they would for non-Federal funds Financial management systems must be able to record and report on the Receipt, Obligation, and Expenditure/Disbursement of grant funds

54 Financial Management Systems – continued
In order for an accounting system to be considered adequate, it must meet the following criteria: Internal controls / segregation of duties (For example, the person authorizing an expenditure should not sign the check) Ability to track expenditures on an accrual basis (budget control) Grantees can use a cash or accrual basis for their accounting method Ensure allowability of costs charged to Federal grants Documentation for all grant-related expenditures, broken down by award Ability to fulfill government-required financial reporting Internal controls - Person authorizing expenditure should not sign check Chart of accounts How costs are coded in the financial system Can be numerical, alphabetic, or alpha-numeric. The structure and headings of accounts should assist in consistent posting of transactions Reconciling of expenditures/payments to source documentation

55 Matching and cost sharing are often used interchangeably
Understanding Match Matching and cost sharing are often used interchangeably Matching usually refers to a statutorily specified percentage Specified as a fixed or minimum percentage of non-Federal participation in allowable program or project costs that must be contributed by a recipient in order to be eligible for Federal funding or a not-to-exceed percentage of Federal participation. Cost Sharing refers to any situation in which the recipient shares in the costs of a project other than as statutorily required matching Approved/accepted matching or cost sharing is shown in the NGA Unless restricted by statute or regulation, matching or cost sharing may be provided as direct and/or indirect costs. Recipient contributions may be derived from: any non-Federal source; or from other program income, if authorized by the OPDIV; otherwise, unless there is specific statutory authority, Federal funds may not be used to match HHS grant funds. Reference : AAGAM, Chapter GPS, II-45 45 CFR Part Part 92.24 55

56 Understanding Match – continued
Cash Match Cash spent for project related costs Matching costs must adhere to Federal rules If not allowed with Federal dollars, not allowable with matching dollars In-kind Match are the value of goods and/or services third parties donate for program or project purposes without charge to a recipient Third party in-kind contributions May satisfy a matching or cost-sharing requirement only when payment for them would be an allowable cost if the party receiving the contributions (recipient, subrecipient, or cost-type contractor) were to pay for them Cost-sharing requirements may NOT be met from the following sources: Costs paid by another Federal award or subaward. Costs or contributions used to satisfy a matching or cost-sharing requirement on another Federal grant In-Kind “In-kind contributions” are the value of goods and/or services third parties donate for program or project purposes without charge to a recipient (or subrecipient or cost-type contractor under a grant). By definition, recipients do not provide in-kind contributions. Third party in-kind contributions May satisfy a matching or cost-sharing requirement only when payment for them would be an allowable cost if the party receiving the contributions (recipient, subrecipient, or cost-type contractor) were to pay for them. Use fair market value to determine value Keep fair market value analysis in files Source documentation Volunteer services may be furnished by professional or technical personnel, consultants, or other skilled or unskilled labor. Volunteer services may be counted as matching or cost sharing if they provide an integral and necessary part of an approved program or project and if payment for them would constitute an allowable cost if the recipient had to pay for them.

57 Understanding Match – continued
All costs and contributions used to satisfy a matching or cost- sharing requirement must be documented by the recipient at the same level of detail as Federal funds Matching contributions are subject to audit If a recipient fails to provide required cost sharing, the GMO generally will make a downward adjustment in the Federal award amount Matching is not in proportion to drawdowns but to expenditures. If on a cash basis would be as cash exchanged hands If on accrual would be based on when encumber—book in accounting system 57

58 Understanding Match – continued
Valuation of in-kind contributions: Rates for volunteers must be consistent with established rates paid for similar work by the recipient or subrecipient If a third party donates the use of equipment or space in a building but retains title, the contribution shall be valued at the fair rental rate of the equipment or space If a third party donates supplies, the contribution shall be valued at the market value of the supplies at the time of donation Value based on service being provided not title the person holds or the function they come from. Eg. Attorney provided services and doing work as an “accountant”. Would charge rate of accountant not attorney. May be less than hourly rate of position hold Determine how to make decision on value May require market research for specific grantee area Not all areas pay the same rate (Washington DC vs Mobile, AL) Market research may be necessary for the service If the recipient or subrecipient does not have employees performing similar work, rates used must be consistent with those paid for similar work in the labor market in which the recipient competes for the kind of services involved. When an employer other than the recipient, subrecipient, or cost-type contractor furnishes free of charge the services of an employee in the employee’s normal line of work, these services shall be valued at the employee’s regular rate of pay. If the donated services are in a different line of work, rates used must be consistent with those paid for similar work in the labor market in which the recipient competes for the kind of services involved. GPD II-47 58

59 Gross income earned as a result of the award
Program Income Gross income earned as a result of the award directly generated by the grant-supported activity or earned There would be no income of this type or level. Activities that generate program income include Registration fees Sale of videos, publications, other media Rental/usage fees Service fees Subject to same requirements as Federal funds Must be reported on FFR (SF 425) Grants Management Advisory Grants Policy Statement II-62-64 45 CFR part 74.24 45 CFR Part 92.25 Possible issue re Tuition—while it is income of the same type…would not be at the same level (difference courses, # courses) Royalties, Patents, Copyrights, inventions—only considered program income if noted in NGA (generally not program income) 92.34 Copyrights--Even if not program income the Feds reserve a royalty-free, nonexclusive and irrevocable license to reproduce, publish and use…forever

60 Program Income The Notice of Grant Award includes the type of program income applicable to the Program/award Deduction alternative Addition alternative Cost Sharing/Matching alternative Combination alternative Deduction alternative Deduct from total project costs Ex: Allowable costs for a budget period = $100K. PI = $10K. Net funding = $90K Addition alternative Add to the funds committed Used to further eligible project or program objectives. Allowable costs for a budget period = $100K. PI = $10K. Total project costs $110K Cannot use for For-Profit organizations Cost Sharing/Matching Alternative Used to finance some or all of the non-Federal share of the project Income must meet all of the tests of allowability for cost-sharing or matching contributions from a non-federal source Combination Alternative Used when large amounts of program income Must specify amounts and types CGMO will determine when this method is appropriate

61 Prior Approval Several changes to an award require O N C prior approval Changes of grantee organization Change in scope Transfer of substantive programmatic work if not previously approved Significant rebudgeting (lesser of 25% or $250K, cumulative) Other as defined by program office Changes in key personnel Carry over funds Indirect costs (if indirect costs not approved in initial budget) Request from grantee, with written justification, should be 30 days from when need approval Scope- Program office must define changes in scope other than those listed. Would be different for each program, and possibly each project/award E.g. HIE—3 CANS…moving $$ bw CANS A prior-approval request for a post-award change must be: Initiated by the recipient (who must obtain that approval before taking the proposed change); In writing; Signed by an authorized organizational official ( or facsimile requests may be considered if submitted by an authorized organizational official); and To ensure timely action, submitted directly to the GMO (see subparagraph A.3). MUST BE APPROVED BY PO BEFORE OGM WILL APPROVE References: GPS II-48 AAGAM Chapter

62 Payments to Grantees Grantees request funds from HHS’ Payment Management System (PMS) Payment requests may be made as often as needed: (daily, weekly, monthly, etc.) No checks; electronic transfers only Also used to submit quarterly financial reports PMS is administered by HHS’ Division of Payment Management PMS Helpdesk: (877) or Grantees must minimize time between draw and expenditure Cash Management Improvement Act (CMIA) Immediate needs basis; funds must be spent within three business days What may impact a grantee’s ability to draw funds? No budget approval Late report submission Other restrictions Remember the first payment is the grantee’s acceptance of the award’s terms and conditions. Advances accrue interest. Must consider CMIA annual interest caps: $250 NGO $100 Government The Payment Management System (PMS) is administered by HHS’ Division of Payment Management. PMS helpdesk: (877) or

63 Grantee Reporting Requirements
Report Required Frequency Reporting Period Due Date Submission Method American Recovery and Reinvestment Act (ARRA) Report Quarterly April 1 – June 30 July 10 Federalreporting.gov July 1 – September 30 October 10 October 1 – December 31 January 10 January 1 – March 31 April 10 Federal Financial Report (FFR) Federal Cash Transaction Report (SF-425) July 30 Payment Management System (PMS) October 30 January 30 April 30 Federal Financial Report (FFR) Federal (SF-425) Annually October 1 – September 30 December 30 Online Data Collection System (OLDC) Program Progress Report Semi-Annually Determined by Program Office CRM, , etc. Other requested questions… Cost share? Source of cost share Describe any deviations from your approved budget and budget narrative Does this change represent a change to your approved scope of work? Did you obtain prior approval from HHS/ONC for this change Are there any impediments to your progress against the grant milestones/objectives? If so, what impediments and will these impediments impact your drawdown rate? What are your projected outlays for the next 6 months? Did you earn program income? If so, how much? Will you be applying this funding to your cost-share? Does your organization have any other Federal grants? If so, was there any possibility of overlap in expenditures (i.e. shared personnel charging to multiple grants)? If so, please explain

64 Official Grant and Program Files
Office of Grants Management files Official award file All award transactions, financial information, correspondence, approvals, etc Program information file Information for each program announcement Information related to all applications Institution file Contains information on a specific entity which receives multiple awards from multiple programs Project officer files Documents project management activities from inception to closeout Record of that PO’s activities with respect to the award Auditor or reviewer will request to review for adequate documentation The first step to managing effectively is to have a filing system. Grantees are required to keep files with adequate documentation. It is critical that project officers develop and maintain individual files for each award.

65 Sample Checklist Section 1 Applicant Submissions and Contacts – New Awards and Other Competing Awards Section 2 Review, Evaluation, and Negotiations – New Awards and Other Competing Awards Section 3 Award Notices and Restrictions/Special Conditions Section 4 Post-Award Prior-Approval Requests Section 5 Post-Award Monitoring and Closeout Section 6 Other See checklist

66 Financial and Programmatic Monitoring
Financial Monitoring Programmatic Monitoring Evidence of expenditures show that purchases are necessary, reasonable, allocable and allowable Flow of Funds Accounting System Internal Controls Cash Management A-133 Submission Interest accrual (as necessary) Programmatic Administration Compare accomplishments to goals and objectives Reinforce priorities and policies Adherence to project scope Performance according to Ops Plans Progress (completion on time) Objectives Grantee monitoring is another area where partnership between the program and grants office is important. Doing tandem site visits will allow for everyone, including the grantee, to see things holistically.

67 Financial Monitoring – Goals
The goals of financial monitoring include: To ensure that grant funds are used as intended and compliant with regulatory requirements To ensure O N C is meeting the highest of management and fiduciary standards To ensure grantee compliance with the terms and conditions of the grant award To meet requirements imposed on O N C by law (A R R A) 67

68 Financial Monitoring – Risk Factors
General Selection Criteria New Grantee Dollar Amount of Award Multiple Awards Entity Type Subawards Reporting Findings (FSR, Audit, A R R A) Unobligated/Unexpended Balances Program Office Referral/Recommendations Samples The above general criteria was weighted based on various factors Other risk factors not included above may also be considered based on data analysis -out life of award 68

69 Types of Financial Monitoring that OGM Conducts
Desk-based Financial Monitoring Cash Analysis Desk Review On-Site Financial Monitoring 69

70 Desk-based Monitoring – Cash Analysis
Cash analysis reviews: Recipient cash transactions Rate of draws Payment trends Unobligated balance Grant status Review of last program report Prevents minor issues regarding non-compliance from becoming major issues GMS shares analysis with Program Office staff to compare the financial and programmatic data Program Office should compare against milestones in Operations plan

71 Desk-based Monitoring – Cash Analysis continued
During the O G M quarterly review, O G M and Project Officers discuss the following : Has the grantee submitted timely performance reports? Is the grantee on target as outlined in their approved plan? Has contact been made with the grantee if not on target? If contact has been made, what corrective action has been discussed?

72 Desk-based Monitoring – Desk Reviews
Limited verification of grantee compliance Federal regulations Terms and conditions Identifies potential issues Grants reviewed on a regular basis Core review of a grantee’s general management practices May require further scrutiny - on-site financial monitoring Review key policies (procurement, accounting chart of accounts, etc.)

73 On-Site Monitoring Visits
On-Site Monitoring Visits are performed at grantee location Ensure adequate internal controls, policies, processes, and systems exist to appropriately manage awards Assess capability, performance and compliance against administrative regulations and public policy requirements Report on the effectiveness of O N C grantees and grant programs and the stewardship of public funds Collaboration with program office(s) is key to successful monitoring Joint site visits with program office when feasible Pre-site visit meeting with program staff Entrance Meeting Review Documentation Exit Interview / De-brief

74 Common Issues Discovered During Financial Monitoring
No written policies and/or procedures Inadequate procurement standards Lack of documentation Inadequate/untimely submission of reports Inadequate Subaward Monitoring Inadequate time and effort records Lack of competition during procurement Conflicts of interest Questioned expenditures Excess Cash on Hand Commingling of funds No written policies and/or procedures Inadequate procurement standards Lack of documentation Inadequate/untimely submission of reports Inventory management deficiencies Inadequate Subaward Monitoring Inadequate time and effort records Lack of competition during procurement Conflicts of interest Failure to manage audit results Inadequate accounting procedures Inaccurate reports Questioned expenditures Excess Cash on Hand Commingling of funds

75 Monitoring vs. Auditing
Monitoring is preventative Performed by grants and program staff Resolve before audits Auditing is corrective / curative Performed by auditors In the record books Monitoring is completed by OGM staff. Audits are of two types A-133 required annual audits IG audits

76 Audits – What is a Statewide Single Audit (A-133)?
Required for Entities that Expend $500K or More in Federal Funds during their Fiscal Year Review of All Federal Grant Programs and Requirements Audit Report Is Due 9 Months after the End of the Fiscal Year Submit the Audit Package to the Federal Audit Clearinghouse (FAC) Effective January 2004, The Office of Management and Budget Circular No. A-133, Audits of States, Local Governments, and Non-Profit Organizations, requires entities that expend $500,000 or more a year in federal awards to have a single or program-specific audit conducted.

77 A-133: Most Common Audit Findings
Unallowable activities Unallowable costs Poor cash management Inadequate equipment and real property management practices Expending funds outside of the period of availability of funds Inadequate procurement standards Untimely and inaccurate reporting Lack of subrecipient monitoring Examples of Audit Findings Conflicts of Interest Inaccurate Financial Status Reports Inappropriate Changes Inadequate Time and Effort Records Unallowable Costs Inadequate Submission of Reports Excess Cash on Hand Lack of Documentation Commingling of Funds Untimely Submission of Reports

78 Health and Human Services
Audit Resolution Health and Human Services ASFR, Division of Systems Policy, Payment Integrity, and Audit Resolution (DSPPIAR) is responsible for A-133 audit resolution OGM will assist in resolution of audit findings only as requested by DSPPIAR ASFR also serves as a liaison with O M B, the O P D I Vs, and the OIG on grant-related audit issues Recipient responsibilities Resolve audit findings of subawards Most O N C programs have a large number of subs Division of Systems Policy, Payment Integrity, and Audit Resolution (DSPPIAR), within the Office of Program Management and Systems Policy, Office of Finance, ASFR. ASFR, serves as a liaison with OMB, the OPDIVs, and the OIG on grant- related audit issues. This office also is responsible for audit resolution if OMB Circular A-133 audit findings (systemic and/or monetary) affect more than one OPDIV or an HHS OPDIV(s) and another Federal department(s) or agency(ies).

79 Corrective Action Plan (C A P) should include:
Audit Resolution Corrective Action Plan (C A P) should include: Description of each finding Specific steps to be taken to implement the recommendation Timetable for performance of each corrective action Description of monitoring to be performed to ensure implementation of the C A P

80 HHS Office of the Inspector General (OIG) Performance Audits
Evaluates HHS Goals and Objectives with grantee activities Rotating schedule of states and programs Annual audit plan Identifies key issues Implementation plan Conducted by OIG staff Compares expenditures to program impact Reports posted on OIG website (http://oig.hhs.gov/reports.asp) ONC grants are also subject to IG audits.

81 Examples of Inspector General Audit Findings
No measurable program goals and objectives Lack of monitoring and oversight Untimely/incorrect financial reporting Questioned costs Inadequate procurement practices Inadequate personal property controls

82 Grants Management Lifecycle – Closeout
Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Retain Records Establish Disposition of Funds Evaluate Final Performance Reports APPLY ESTABLISH REVIEW AWARD MANAGE CLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Closeout stage of grant lifecycle 82

83 Due within 90 Days after End of Award Final Progress Report
Recipient Closeout Due within 90 Days after End of Award Final Progress Report Final SF-269 Financial Status report Unobligated funds balance No unliquidated obligations Final drawdown Return excess funds Invention Disclosure (if applicable) Federally Owned Property Control (if applicable)

84 Retention of Records – Grantees
Grantee Requirements (45 CFR and 74.53) At least 3 years from the date of submission of the final expenditure report If litigation, claim or an audit is initiated prior to the expiration of the 3 year period, records must be retained until completion of the action and resolution of issues or the end of the 3 year period, whichever is later Records may be retained in an electronic format

85 Retention of Records – ONC
Office of Grants Management 1 year unsuccessful applications 6 years 3 months official files If open audit, litigation, administrative proceeding retention may be longer Project Officer files 2 years after closeout OGM-Program Files 6 years 3 months for successful 1 year unsuccessful

86 Grants Management Lifecycle
Review FOA Submit Application Revise Application Review Award Package Accept Award Drawdown Funds Submit Financial Reports Submit Performance Reports Submit Post-Award Requests Ensure Audit is Complete Generate Final Performance Reports Complete Drawdown of Funds Generate Final Financial Reports Submit Closeout Package Retain Records Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Assist Applicants Establish Commitments APPLY Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Establish Disposition of Funds Evaluate Final Performance Reports CLOSEOUT Obligate Funds Set Up Congressional Notification in System Release Funds Create Notice of Grant Award AWARD Notify Grantee of Award Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute ESTABLISH Allocate Funds Review and Approve Post-Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring MANAGE Review /Recommend Post-Award Actions Program and Grants Management Training and Technical Assistance Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo REVIEW Assess Funds Availability Review grants lifecycle 86

87 Critical Reference Documents
American Recovery and Reinvestment Act of 2009 (Recovery Act) What does the law say Statute is highest in order of precedence 45 CFR Part 74 and Part 92 - Administrative Requirements Part 92 – Government organizations (Including Tribal) Part 74 – NGO Uniform administrative rules when implementing Federal grant programs Cost Principles 2 CFR Part 220 – Educational Institutions 2 CFR Part 225 – Government Organizations (Including Tribal) 2 CFR Part 230 – Non-Profit Organizations FAR 31.2 OMB Circular A Audits of States, Local Governments, and Non Profit Organizations

88 Critical Reference Documents – continued
HHS Grants Policy Statement (GPS) Grants policy for recipients Incorporated as a term in NGA Dos and Don’ts ONC staff should also know the GPS in order to provide support to grantees Funding Opportunity Announcement (F O A) Notice of Grant Award (NGA) with Award Terms and Conditions Grants Management Advisories (GMAs) Grants Management Memorandum (GMM) Program Information Notices (P I Ns) Program Assistance Letters (P A Ls)

89 Critical Reference Documents – continued
Grants Management Advisories (GMAs) – technical assistance resource which will provide additional information in specific grants management areas for Grantees O N C-GMA Roles and Responsibilities Grants and Cooperative Agreements O N C-GMA Review of Proposed Subawards and Procurement Contracts Under Grants O N C-GMA Matching and Cost Sharing O N C-GMA Use of Unobligated Balances under Grants and Cooperative Agreements O N C-GMA Allowability of Food Costs O N C-GMA Program Income O N C-GMA Subrecipient Monitoring O N C-GMA Allowability of Payments to Uniformed Services and Civilian Federal Employees

90 Training and Technical Assistance Plan
ONC Office of Grants Management has a Training and Technical Assistance (T A) Plan based on three different levels of assistance: Level I: Guidance and Information Sharing – Consists of the daily technical assistance of grants administration. Level II: Sample Protocols, Templates and Models – Targeted telephone and electronic assistance involves assisting recipients in the development of protocols and templates, as well as other specific needs, as requested by a recipient. Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes targeted internal and external training sessions. Level 1 - The TA provided in level one may include answering simple grants questions, providing specific regulatory references and/or sharing readily available grants information. Issues raised during this level of TA will be catalogued and used to guide future TA. Level 2 - This level of TA also consists of more intensive support to recipients via telephone and . Issues raised during this level of TA will be catalogued and used to guide future TA. Level 3 - These sessions may be in the form of face-to-face training sessions, webinars, TA workshops, program office conferences. Level III also includes direct on- site assistance, consisting of intensive, site-specific guidance and consultation on recipient policies, procedures, and administrative capabilities.

91 Office of Grants Management – TA Requests
Grants Management T A request form Please use this form to request Training and Technical Assistance from the ONC Office of Grants Management Completed forms are available from, and should be submitted to This is should not be completed for specific questions. Please contact the appropriate GMS.

92 Grants Management Questions


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