Office of Federal Financial Management; Standard Data Elements for Federal Grant Applications

AGENCY:

Office of Federal Financial Management (OFFM), Office of Management and Budget (OMB).

ACTION:

Notice of proposed requirement to establish standard data elements.

SUMMARY:

OMB proposes (1) to establish a standard set of data elements and definitions as found on the SF-424, plus five additional data elements for Federal agencies and grant applicants to use on both paper and electronic applications for discretionary grants, and (2) to require a new assurance statement to replace the current assurances found on the SF-424. The Federal E-Grants initiative calls for the development of a one-stop, electronic grant portal where potential grant recipients will receive full service electronic grant administration as part of the implementation of the Federal Financial Assistance Management Improvement Act of 1999 (Pub. L. 106-107).

The grantee community is familiar with most of the data elements, which have been required by Standard Form (SF) 424, “Application for Federal Assistance,” SF-424A, Budget Information Non-Construction; SF-424B, Assurances—Non-Construction Programs; SF-424C, Budget Information Construction Programs, and SF-424D, Assurances—Construction Programs. OMB is adding the following five new standard data elements to those already appearing on the current SF-424 and will revise the form accordingly. The five new standard data elements being added are:

(1) Requesting entity's universal identifier (see proposal to use the Duns Universal Numbering System (DUNS) in the October 30, 2002 Federal Register, Vol. 67, No. 210, pp. 66177-66178;

(2) Requesting entity's e-mail address;

(3) Requesting entity's country location for address purposes;

(4) Requesting entity's facsimile (Fax) number; and

(5) Requesting entity's indictor for “Not-For-Profit” under “Type of Applicant” based upon how the entity is classified with the Internal Revenue Service.

The use of government-wide standard data elements by grant applicants and the Federal agencies that award discretionary grants or cooperative agreements establishes the data standard for grant applications submitted via the E-Grants portal grant application software known as E-Apply. In order to establish data standards, this Notice also identifies how the data will be transmitted for E-Apply. The proposed electronic transmission of the data set is to use the conventions established by the American National Standards Institute (ANSI) 194 Data Transaction Set. These data elements will be incorporated into the first version of E-Apply, scheduled for release in October 2003, which will permit applicants to apply electronically for Federal grants.

The consolidated assurance statement, which is being proposed to replace the current assurances found on the SF-424B and SF-424D, is designed to provide a streamlined way for Federal agencies to obtain assurance about compliance with applicable requirements. OMB believes the addition of the consolidated assurance statement will allow applicants to proceed through the application process in a more efficient manner. Only at time of award would the grantee address any specific agency assurances that are incorporated in the award and are above and beyond the standard assurances.

DATES:

Comments on the proposed data elements, definitions and consolidated assurance statement must be submitted by June 9, 2003.

ADDRESSES:

Due to potential delays in OMB's receipt and processing of mail sent through the U.S. Postal Service, we encourage respondents to submit comments electronically to ensure timely receipt. We cannot guarantee that comments mailed will be received before the comment closing date.

Electronic mail comments may be submitted to: sswab@omb.eop.gov. Please include “Standard Data Elements Comments” in the subject line and put the full body of your comments in the text of the electronic message and as an attachment. Please include your name, title, organization, postal address, telephone number, and E-mail address in the text of the message. Comments may also be submitted via facsimile to 202-395-3952. Comments may be mailed to Sandra Swab, Office of Federal Financial Management, Office of Management and Budget, Room 6025, New Executive Office Building, Washington, DC 20503.

FOR FURTHER INFORMATION CONTACT:

Sandra Swab, Office of Federal Financial Management, Office of Management and Budget, telephone 202-395-3993, and E-mail: sswab@omb.eop.gov.

SUPPLEMENTARY INFORMATION:

Standard Set of Data Elements and Definitions

The Federal E-Grants initiative, one of 24 initiatives of the Administration's overall E-Government program for improving access to Government services via the Internet, calls for the development of a one-stop, electronic grant portal where potential grant recipients will receive full service electronic grant administration. OMB is seeking to develop a standard set of data elements that will be used by grant-making Federal agencies to develop web-based grant application software. The application software, E-Apply, will permit the use of on-line grant applications by October 2003. This Federal Register announcement seeks public comment on establishing the current data elements and definitions of the SF-424 with the proposed five additional data elements as the standard data set that Federal agencies would include in the first version for electronic grant applications. The standard data elements are found in the attachment to this notice. The attachment identifies the current data elements and definitions found on the SF-424. The proposed data elements have been required of grant applicants when submitting SF-424s to which OMB is proposing to add five new elements: (1) Requesting entity's universal identifier (see proposal to use the DUNS in the October 30, 2002 Federal Register); (2) requesting entity's e-mail address; (3) requesting entity's country location; (4) requesting entity's facsimile (Fax) number; and (5) for Not-For-Profit entities only, requesting entity's indicator for “Type of Applicant.”

Additional efforts not included in this initial proposal, seek to have the Federal government review various grants management processes that focus on different types of business lines that cut across similar grant programs. For example, grant programs that focus on research may need to have different grant application information than programs that focus on education. However, many different agency grant programs may be similar in a broad subject category and collect similar information. For those grant programs found in broad subject categories and cut across various Federal agencies, the data may be standardized and shared by collecting the data only once. This cross-agency standard data may become a subset to the standard data collected on the SF-424. When such data is identified and approved, it is the intention to revise the suite of SF-424 standard collection forms to identify cross-agency data. This effort will be done in consultation with the grants community at-large through the public comment process. It is thought the standardization of data and establishment of standard data for similar types of grant programs will enhance the collection of data and help to overall simplify the grants application and management processes.

Policy for Electronic Grant Applications

The SF-424 data elements, including the five proposed data elements, are attached for review and comment and are contained within the American National Standards Institute's (ANSI) Grant Application or Assistance Application 194 Transaction Data Set, a national electronic standard for the Federal grant application. The 194 Transaction Data Set has evolved under the auspices of the Inter-Agency Electronic Grants Committee (IAEGC), ANSI, Federal Demonstration Partnership, universities, research institutions, and Federal grant-making agencies. Using an established national electronic standard to implement the E-Apply software application helps to standardize the data conventions and provides a foundation upon which to build future applications. The attachment correlates the SF-424 data to the related data found in the 194 Transaction Data Set. Information on the 194 Transaction Data Set can be found on the Inter-Agency Electronic Grants Committee's (IAEGC) Web site at www.iaegc.gov .

Consolidated Assurance of Compliance for Grant Applicants

We further propose to revise the SF-424 to provide a streamlined way for Federal agencies to obtain assurances of compliance with applicable requirements. Currently, a Federal program office that uses the entire suite of SF-424 forms for its applications would require an applicant to submit assurances on, either a SF-424B, “Assurances—Non-Construction Programs,” or a SF-424D, “Assurances—Construction Programs.”

The assurance forms (SF-424B/D) list many individual national policy requirements and a few selected administrative requirements based in statute, Executive Order, regulation, or OMB circular language. The national policy requirements address societal objectives such as protection of the environment or ensuring civil rights. The selected administrative matters, such as conduct of audits, relate to stewardship of public funds. The forms require the applicant's “authorized certifying official” to sign, thereby agreeing that the applicant will comply with the requirements if an award is made.

We propose an approach that coordinates the business processes of application and award at the time of announcing funding availability. Agencies' announcements will identify administrative and national policy requirements with which applicants must comply if they receive awards, thereby helping potential applicants make more informed decisions about whether to apply. If an entity is unable or unwilling to comply with any of these requirements, it should not invest time and money in preparing an application.

At time of application, applicants would be asked to sign the following consolidated assurance on the cover page of the SF-424, which would replace the lists of individual requirements that currently appear on the SF-424B and SF-424D:

I have reviewed the requirements that apply to recipients of awards under this program* and assure, as the duly authorized representative of the applicant, that the applicant will comply with those requirements and other terms and conditions if it receives an award.

*If you are submitting this application in response to a Federal agency announcement of a funding opportunity, consult that announcement or any associated application instructions for the Internet site or other location where you may view the generally applicable requirements. Otherwise, if you do not know where to view them, contact the office to which you are submitting this application to ask about the location.

At time of award, a successful applicant would receive an award document with terms and conditions incorporating the applicable national policy and administrative requirements. These would be the same requirements for which the applicant provided an assurance of compliance at time of application, except for any award-specific requirements that the agency imposes or any new requirements or changes made to existing requirements after the agency issued its announcement.

This new approach for a consolidated assurance has a number of advantages:

• It is easier to give potential applicants up-to-date information on applicable requirements. National policy and administrative requirements change over time, due to enactment or adoption of new policies and repeal or revision of existing ones. Updating a standard form is a cumbersome and lengthy process, so it is difficult to keep forms up to date with the latest policy changes. The SF-424B and SF-424D, for example, are not fully up to date at this time.
• The consolidated assurance eliminates the need to update the electronic submission format each time a requirement changes. As the Federal Government moves from paper forms to electronic transactions, periodically updating the list of national policy and administrative requirements would require reprogramming the format for electronic submission of applications if each requirement was individually listed in the assurances of compliance. Reprogramming would increase costs and administrative burdens. Instead, the change would be addressed in agencies' terms and conditions, which are more easily updated.
• Potential applicants only need to consult a single source, the agency's terms and conditions, for all applicable requirements before providing assurance. Currently, an awarding agency or program office must supplement the SF-424B or SF-424D with information about agency-or program-specific requirements because the standard forms list only government-wide requirements.

It is anticipated that OMB would change the SF-424 to reflect the above assurance language changes when the additional data elements are added to the form and public comment supports such a change. Current grant application forms can be found at http://www.whitehouse.gov/omb/grants .

Questions and Comments

We welcome your input on any aspect of the data elements and inclusion of the consolidated assurance in place of those found on the SF-424B and SF-424D. Questions that you may wish to address include:

• Are the proposed data elements found on the current SF-424 the essential ones needed to apply for Federal grants? If you recommend adding or deleting any data elements, please explain why.
• Are the current definitions found on the SF-424 clear and explicitly define what is required for applicants to enter on the SF-424, “Application for Federal Assistance?”
• Are the names of data elements and any terms used in describing them readily understandable? Are the terms generic enough to cover all programs and agencies in which you might have an interest? Do you have suggestions for alternate terms?
• Is the current SF-424, plus the five additional proposed data elements and assurance language, sufficient enough to establish the SF-424 as the data standard? If comments indicate a more in-depth change to the SF-424, should OMB establish this as the data standard and then proceed with a more complete revision at a later date?
• Is the assurance language feasible for use by Federal agencies in lieu of those found on the SF-424B and SF-424D?

Attachment: The attachment is a series of tables that list the name of the data element found on the SF-424 with the description found on the grant application form. The attachment also lists the data element name found in the 194 Transaction Data Set for comparison. Use of the 194 Transaction Data Set is to help define data layout for electronic transmission. Each table is titled to help better understand the groups of the data elements.