Jonathan Mallahan

New grant guidelines could benefit families in need

Jonathan Mallahan, Community & Neighborhood Services Director, No Phone Number Available

Monday, October 13, 2014 at 11:42 a.m.

New grant guidelines could benefit families in need

The City is taking steps to make sure federal aid gets to local families in need as efficiently as possible.

The Federal Office of Management and Budget (OMB) is releasing a set of updated regulations guiding the administration of federal awards. These changes bring together many circulars and guidance documents into a single “Omni Circular”. The objectives of the Omni Circular are to reduce administrative burden in managing federal awards, increase a focus on funding meaningful outcomes and to lower the risk of fraud, misuse or waste of public funds. The Omni Circular becomes effective on December 26, 2014.

The City of Spokane has adopted a proactive approach in adapting to these new requirements through investing in a centralized office of Grants Management and Financial Assistance. In early 2014, we adopted new policies and procedures outlining the City's approach to ensure grant compliance with the Omni Circular while maintaining a focus on achieving meaningful outcomes for Spokane low and moderate income families who are in need.

This approach will ensure that Spokane remains competitive in bringing grant funding to our community to pay for needed services and housing. Here a few of the changes that agencies receiving grant funding through the City of Spokane can expect:

  • Expense Backup Documentation – Subrecipients will be required to provide detailed documentation to justify expenditure of grant funds. The City has amended our subrecipient agreements to include a requirement of submitting this documentation with invoices for reimbursement. Required documentation must provide adequate information to determine that dollars were spent on eligible grant activities and that the expense has been properly allocated according to the adopted budget and proportional benefit to the grant program.
  • Pre and Post Award Risk Assessment Information Requests – Additional risk assessment is required for all subrecipients. We will be asking some initial information about agency capacity, performance history, prior audit results, etc. be included in applications for grant funding. If your agency receives funding, we will require more detailed information on financial and administrative controls prior to entering into contract. This is being developed as an agency risk assessment to mitigate additional impact on our subrecipient agencies to the extent possible. One assessment will be completed per agency as opposed to per grant program.
  • Federal Guidelines Delineated in Contract Templates – In the past, City subrecipient agreements have referenced federal grant management regulations. We are now including these regulations in the contract language and/or as attachments to the contract to ensure agencies have an understanding of what requirements apply to the funds they are receiving.
  • A-133 Audit Threshold Increased – In the past, agencies receiving over $500,000 of combined federal awards were subject to A-133 single audit requirements. This threshold will be $750,000 under the Omni Circular. As the City uses A-133 audit reports as a risk assessment tool, your agency may be required to provide additional documentation of financial and programmatic controls if you are no longer subject to an A-133 audit.
  • Indirect Costs – A flat 10% indirect cost (admin) rate will be allowed for any agencies who do not currently, or previously, have a federally negotiated indirect cost rate, unless specifically prohibited by the awarding federal agency. This rate may be applied using a basis of modified total direct costs (all expenses with a threshold limit of the first $25,000 of any contractual and pass-through expenses). Any agencies who do have a federally negotiated cost rate will be authorized to use that rate, up the maximum percentage allowed under the award. If you are able to allocate and charge 100% of your costs as a direct expense, you will be allowed to continue to do so.

The list above includes a sampling of how the Omni Circular supports excellent grant management and there are many other changes that impact any organization that utilizes federal and state funding. Below is a list of training resources and opportunities that you can take advantage of in learning more about the Omni Circular:

In addition to the resources listed above, City of Spokane staff are available to you in answering questions or providing direct technical assistance in planning for these changes. Please contact Jennifer Stapleton at Jstapleton@spokanecity.org to schedule technical assistance related to the Omni Circular.

At the City of Spokane we are committed to supporting a strong, effective safety-net for individuals and families who are in need in our community. Effectively implementing systems that support compliance with these changing federal regulations is a key strategy in achieving this goal. Similarly, we want to hear from our nonprofit partners about these changes and how we can better support their success. If you would like to contact the City of Spokane and provide feedback about how well we are accomplishing this goal, please email me at jmallahan@spokanecity.org.

Thank you for your cooperation and understanding in working with the City of Spokane as we work towards becoming a best-practice grant management organization and continue to deliver excellent service and housing outcomes for our community.

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