[Okgrantsmanship] Uniform Guidance Q&A

[Mason, Linda]

Dear Colleagues,



This email message is an extension of our conference call discussions provided last month to help clarify the implementation procedures for compliance with the Uniform Guidance. Here is a very interesting question that has come up, and the discussion of several parts of the answer. I have yellow highlighted the most direct answers as well as indicated with asterisks**. Please contact me for more discussion!

Dr. Linda Mason



Q: The question is "What federal funds are affected by the Uniform Guidance regulations." Specifically, the question was "Do we need to check the students against the Suspension and Debarment list for federal Pell grants or other federally funded grant or scholarship programs, such as NSF scholarships?"



SHORT ANSWER:

**A: Those of us who receive federal funding to pass on to students in grants are required to provide appropriate oversight to prevent fraud.



LONGER ANSWERS:



A: **All Federal funding is affected by the Uniform Guidance Regulations. The intent is to reduce administrative burden and risk of waste, fraud and abuse. Specifically, financial aid personnel perform screening appropriate to student status to rule out fraud or criminal activity. The FAFSA process includes a check against a list of students with student loan defaults and overpayments; however, most traditional students wouldn't fall into the category of unethical or illegal activities involving other federal funds.  Schools generally do not check students against the SAM Suspension or Debarment list when awarding and paying federal student financial aid (Title IV) or when giving other federally funded scholarships.  There are quite a few "matches and screening" that take place when the FAFSA is processed (NSLDS, DHS, SSA, etc.). Those matches may lead to disqualification of a student if one was required. The intent is to prevent fraud or abuse of federal funding.



Q: Who will be impacted by the reform in federal expenditure regulations through the Uniform Guidance?



A: **This reform will impact Federal agencies, non-Federal entities (states, local governments, Indian tribes, institutions of higher education (IHE), and nonprofit organizations) that receive any Federal awards as a recipient or subrecipient, and their auditors.



Q: Where can I get more information about the policies that are changed?



A: Please visit www.cfo.gov/COFAR for more information on the following resources:

       o A link to a recorded webcast that was broadcast on December 20, 2013.

       o A link to a recorded training webcast that was broadcast on January 27, 2014.

o Crosswalks and side-by-sides that explain where to find revised sections of the old guidance in the Uniform Guidance and show the language from the old guidance next to the new language. These crosswalks and side-by-sides are available at http://www.whitehouse.gov/omb/grants_docs

**OSRHE is sponsoring another training session by Brustein & Manasevit, a Washington DC attorney firm that works closely with the US federal agencies. Training is October 2 and 3, 2015, at the Embassy Suites. Online registration will be announced soon.

Q: What is the impact of this reform? How does this reform reduce administrative burden and risk of waste, fraud, and abuse?

* Here is a list of ways that the Uniform Guidance reduces administrative burden and risk of waste fraud and abuse:

1. Eliminating duplicative and conflicting guidance by incorporating 8 circulars into 1 OMB guidance circular.

2. Focusing on performance over compliance for accountability.

3. Encouraging efficient use of information technology and shared services.

4. Providing for consistent and transparent treatment of costs.

5. Limiting allowable costs to make the best use of Federal resources.

6. Setting standard business processes using data definitions.

7. Encouraging non-Federal entities to have family-friendly policies.

**8. Strengthening oversight....review the risk associated with a potential recipient prior to making an award....Requires disclosure of relevant conflict of interest or criminal violations, expressly prohibiting profit, requiring certifications by senior officials of the non-Federal entity, and providing Federal agencies with strong remedies to address situations of non-compliance.

9. Targeting audit requirements on risk of waste, **fraud, and abuse.





Dr. Linda Mason

Coordinator of Grant Writing

Oklahoma State Regents for Higher Education

655 Research Parkway, Suite 200

Oklahoma City, OK 73104

405-225-9486 desk

405-706-8757 cell

405-225-9230 FAX

lmason at osrhe.edu

www.okhighered.org/grant-opps/






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