Selected Agencies Should Clarify Merit-Based Award Criteria and Provide Guidance for Reviewing Potentially Duplicative Awards
GAO-17-113: Published: Jan 12, 2017. Publicly Released: Jan 12, 2017.
How do federal agencies decide who should receive grants?
Federal agencies must establish a merit-based review process for competitive grants. We looked at the design and implementation of this process at parts of the Departments of the Interior, Health and Human Services, and Agriculture.
We found that parts of these Departments could be more transparent about their criteria for evaluating grant applications, and that most could provide better guidance on identifying duplicative funding.
We made recommendations to improve this process, including more information in public notices and developing guidance for detecting duplicative funding.
Overview of the Federal Grant Merit-Review Selection Process
Overview of the Federal Grant Merit-Review Selection Process
What GAO Found
GAO found that all 6 selected subagencies in the Departments of the Interior (Interior), Health and Human Services (HHS), and Agriculture (USDA) applied a risk assessment review before making final grant award decisions for the 19 grant programs examined, as required by the Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). GAO also found that while selected HHS and USDA subagencies generally followed certain other required and recommended practices established in the Uniform Guidance for providing specific information in their notices of public funding opportunity (public notices) announcing grants, selected Interior subagencies did not. Specifically, the Uniform Guidance recommends that public notices include (1) the merit-based criteria that will be used to assess grant applications, (2) the relative weights that will be applied to those assessment criteria, and requires (3) whether and how cost sharing will be used as a factor in assessing an application. GAO found that for several grant programs in selected Interior subagencies, public notices either did not state merit-based selection criteria, did not state the relative weights assigned to selection criteria, or did not clarify how cost sharing would be used to assess an application. Omitting this information from the public notices limits transparency for potential applicants.
OMB's Uniform Guidance does not direct agencies to review applicants for duplicative funding, but federal standards for internal control state that management should use quality information to achieve objectives and that management should document its policies. GAO found that only 2 of the 6 selected subagencies (1 in HHS and 1 in USDA) had developed formal processes and guidance for identifying potentially duplicative funding. GAO's previous work has pointed to potential risks that can arise—such as awarding duplicative grants—when agencies do not have guidance in place to direct staff to check for duplication when making competitive award decisions. Officials from the other 4 subagencies (in HHS, USDA, and Interior) that relied primarily on informal processes for identifying potentially duplicative grant funding acknowledged the importance of identifying information about applicants' other funding before making final grant award decisions.
The Council on Financial Assistance Reform (COFAR) updated its priorities for fiscal year 2016 but has made limited progress in planning, coordinating, and communicating its priorities. COFAR is an interagency council established by OMB to provide policy-level leadership for the grants community and to support reforms to improve the effectiveness and efficiency of federal grants. In 2013, GAO identified challenges related to COFAR's priorities and its lack of a plan to achieve implementation of these priorities and GAO recommended that OMB provide an implementation schedule for COFAR, clarify roles and responsibilities of COFAR members, and improve two-way communication with stakeholders. However, in this review GAO found that COFAR's challenges remain and it has still not (1) released an implementation schedule that includes performance targets and evaluation mechanisms; (2) established roles and responsibilities for its members; or (3) made progress in developing effective two-way communication with the grant recipient community and other stakeholders.
Why GAO Did This Study
To improve the effectiveness and efficiency of grant-making in the federal government, in 2011 OMB created COFAR, and in 2014 OMB's Uniform Guidance came into effect. This included requirements for federal agencies to establish a merit-based review process for competitive grants and to assess grant applicants' risk. GAO was asked to review the design and implementation of merit-based grant award selection.
GAO reviewed the extent to which (1) selected subagencies followed certain required and recommended practices for evaluating competitive awards; (2) selected subagencies had processes to identify duplicative grant funding; and (3) COFAR has made progress in developing an implementation schedule for achieving its priorities. GAO assessed OMB and agency grant guidance for 19 grant programs at 6 subagencies—selected in part based on grant outlays in fiscal year 2014—and interviewed officials from these agencies and OMB as well as from associations representing different types of grantees. GAO's findings are not generalizable.
What GAO Recommends
GAO is making four recommendations to address the concerns identified at the specific subagencies, such as including required and recommended information in public notices for grant opportunities and developing guidance on reviewing applicants for potentially duplicative funding. All agencies agreed with the recommendations.
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Recommendations for Executive Action
Comments: As of August 2017, Interior had updated its notice of funding opportunity template for competitive grant programs to clarify that the review process must ensure that applications are scored and selected based on announced criteria. In addition, competitive grant programs must establish a written merit review plan that details the merit review factors and sub-factors and the rating system and evaluation standards which explain the scoring basis. Furthermore, the Fish and Wildlife Service is developing new guidance to ensure discretionary grant programs include all required elements to be completed in December of 2017.
Recommendation: To improve transparency in the grant merit-review process, the Secretary of the Department of the Interior should direct the Fish and Wildlife Service to issue written guidance to require all competitive grant programs to clarify in the public notice of funding opportunity all review criteria, including cost sharing factors as relevant, and their related scores to be used to make final award decisions.
Agency Affected: Department of the Interior
Comments: The Fish and Wildlife Service issued guidance to ensure grant applications are reviewed for potential overlap and duplication, as GAO recommended in January 2017, but as of August 2017 the National Park Service had yet to issue such guidance. In August 2017, the Department of Interior (Interior) provided documentation showing that the Fish and Wildlife Service now requires discretionary grant applicants to provide a statement that addresses whether there is any overlap or duplication of proposed projects or activities to be funded by the grant. Fish and Wildlife also updated its guidance to grant awarding offices instructing them to perform a potential overlap and duplication review of all selected applicants prior to award. Interior said the National Park Service had yet to issue guidance on duplication and overlap review, but it would provide the guidance to GAO when it is finalized and implemented. Completing these improvements will help the Fish and Wildlife Service and the National Park Service reduce the risk of unnecessary or inadvertent overlap or duplication in grant funding.
Recommendation: To reduce the risk of duplicative and overlapping funding at the grant award level, the Secretary of the Department of the Interior should direct the National Park Service and the Fish and Wildlife Service to issue written guidance that ensures their grant management staff review grant applications for potential duplication and overlap before awarding their competitive grants and cooperative agreements.
Agency Affected: Department of the Interior
Comments: In August 2017, the Department of Agriculture (Agriculture) said the Food and Nutrition Service was developing written guidance that will ensure its grants management staff identify grant programs for potential duplication and overlap with other federal agencies before awarding competitive grants and cooperative agreements, as GAO recommended in January 2017. Agriculture officials said the guidance would be based on input from grants management staff, relevant Food and Nutrition program officials, and reviews of similar guidance already in place at other Agriculture sub-agencies. The Food and Nutrition Service plans to issue this guidance by the end of federal fiscal year 2017 for use beginning in fiscal year 2018. Issuing and implementing this guidance will reduce the risk of unnecessary or inadvertent overlap or duplication in grant funding.
Recommendation: To reduce the risk of duplicative and overlapping funding at the grant award level, the Secretary of Agriculture should direct the Food and Nutrition Service to issue written guidance that ensures its grant management staff review grant applications for potential duplication and overlap before awarding competitive grants and cooperative agreements.
Agency Affected: Department of Agriculture
Status: Closed - Implemented
Comments: CDC issued guidance to ensure grant applications are reviewed for potential overlap and duplication, as GAO recommended in January 2017. In August 2017, an HHS official provided documentation showing that effective in March 2017, the funding opportunity announcement templates included language instructing applicants to self-report duplication or overlap with another application or award. Issuing and implementing this guidance will reduce the risk of unnecessary or inadvertent overlap or duplication in grant funding.
Recommendation: To reduce the risk of duplicative and overlapping funding at the grant award level, the Secretary of Health and Human Services should direct the Centers for Disease Control and Prevention to issue written guidance that ensures its grant management staff review grant applications for potential duplication and overlap before awarding competitive grants and cooperative agreements.
Agency Affected: Department of Health and Human Services