Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
There needs to be alignment of Federal Spending elements and the elements in the CDERL and elements like entity classification
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal Award recipient, I want to easily correct errors I find in government data systems. I want to be able to alert the contracting office, for them to quickly make a correction, for this process to be seamless.
I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...more »
Last year, the Coalition for Government Procurement submitted a number of recommendations in response to the Chief Acquisition Officers Council (CAO) Council Open Dialogue to improve the economy and efficiency of the Federal acquisition system. The Coalition urges the government to take action on the previously submitted recommendations to increase the efficiency and the effectiveness of Federal procurement. Implementing ...more »
AAU, COGR and APLU recommend that OMB clarify in regulation that personal activity reports are not required under the Uniform Guidance (UG); that awardees do not have to certify payroll expenses; and that cognizant agency approval is not needed to implement alternatives to effort reporting that meet the UG standards of documentation. The Uniform Guidance provides institutions with increased flexibility to document ...more »
AAU, COGR and APLU recommend that OMB clarify the conflict of interest regulations in section 200.112 of the Uniform Guidance. OMB should make a technical correction to the UG, removing “selection of a subrecipient” to clarify that the intent of the regulations is to address conflicts that might arise around how a non-Federal entity expends funds under a Federal award and not to individual financial interests and work ...more »
AAU, COGR and APLU recommend that OMB clarify that where a subrecipient has a current Single Audit report, prime recipients can rely on the subrecipient’s auditors and cognizant agency oversight for routine audit follow-up and management decisions. Science is engendering an increased number of collaborative projects, resulting in significant growth in the number of subawards issued and received by institutions of higher ...more »
AAU, COGR and APLU recommend that OMB raise the micropurchase threshold from $3,000 to $10,000 to reflect current practices. As data supports a higher threshold, OMB should consider future adjustments. The UG has introduced a category known as “Micro-Purchases,” defined as purchase transactions up to $3,000, below which there is no requirement to document competition. This was not included in the proposed guidance so ...more »
AAU, COGR and APLU recommend that OMB eliminate the DS-2 requirement for institutions of higher education. The DS-2 is a document setting forth an institution’s accounting practices with regard to federal funds that requires approval by the institution’s cognizant agency for indirect costs. It is a transposition of accounting policies and practices that are already documented elsewhere, usually on an institution’s website ...more »
Since the publication of the Uniform Guidance UG), institutions have seen various Conflict of Interest (COI) terms and conditions embedded within broad agency announcements and proposal solicitations, despite the lack of formal agency-wide policies or guidelines in most cases. The specific requirements for what financial interests and relationships need to be disclosed, the nature and timing of reviews, and even definitions ...more »
Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »
OMB should clarify the parameters for the risk analyses that universities are required to make for their subrecipients under the Uniform Guidance. Such a move would help to curtail the proliferation of individualized standards or action plans established by individual universities seeking to carry out their responsibilities under the as prime recipients with respect to their subrecipients.