HHS Executive Committee on Grants Administration Policy (ECGAP)
Wednesday, December 12, 2007
Lluana McCann, ECGAP Chair and Director of the Office of Grants Policy, Oversight and
Evaluation (OGPOE), convened the meeting at 10am. Introductions were made among
the participants in the room.
OGPOE Director’s Report
o Follow-up on closeout of awards - OGPOE continues efforts to develop a
strategy to deal with 1) the 32,000-34,000 backlog of unclosed awards long
overdue for closing, and 2) with more current, ready to be closed awards. The
DAS Grants and OGPOE Director have visited with OIG on both of these issues;
the OIG has indicated willingness to provide comment on the draft strategy. The
Payment Management System and coordination/reconciliation with OPDIV
specific processes for financial management are central issues meaning ongoing
effort will involve financial management units at each OPDIV. It appears no
ECGAP members currently serve on the Change Control Board for PMS and
some issues may derived from a lack of OPDIV representation.
o Forecast – has been launched and is available on HHS home page at
www.hhs.gov/grantsforecast. The current Forecast is not a database but a
series of html records. OGPOE will request OPDIVs to make quarterly updates
of their opportunities. To officially announce the Forecast, Charlie Johnson and
Terry Hurst will send out email announcements later this week or early next.
The Forecast will also be featured in the Spotlight section of HHS home page.
Work has begun on a permanent, web-based solution that will allow direct
OPDIV-input of data. A requirements document is being prepared and
presentations have been made to the HHS Information Technology Review
Board for resources and approval. More details to come in future months.
o Alert List – According to the AGGAM, if special terms and conditions are placed
on an award, OPDIVs must submit that information to OGPOE to be included in
the Alert Listing. With the current suspension of the Alert Listing by OGPOE, this
places OPDIVs in a de facto position of deviating from internal policy. A
memorandum will be issued from OGPOE to manage this situation.
o Chief Grants Management Officers (CGMO) were reminded that prior to
accepting any segment of the award process—from program development to
announcement to application review/selection to formal award and post award
monitoring—that the CGMO (not GMO or other level grants staff) would have to
have reviewed and ensured a signed MOU is in place to lay out all OPDIV
activities and to identify related costs for such services to the other entity. When
a GMO signs an award, the GMO is signifying that the requirements of all
relevant law, regulations and HHS policy have been met in order for an obligation
of funds to take place. Please contact OGPOE if assistance is needed in relation
to this matter.
OGPOE Staff Presentations
o Cost Policy/Hospital Cost Principles – Heber Willis presented ECGAP members
with an overview of the targeted work regarding the cost policy function for the
next year. The work presented and the methodology described was approved by
Charles Johnson, Assistant Secretary for Resources and Training in a previous
briefing. Because the Hospital Cost Principles (HCP) have not been significantly
revised for many years, it was decided that they would be the first priority of
effort. Rather than simply publish a revised document, it was determined that a
recurring process of review is needed to ensure the HCP remains current in
future years. It is the intent of OGPOE to create and steer an advisory body that
will incorporate a broad representation of all HCP users for this purpose.
o Trafficking In Persons – Nancy Weisman reported that a Federal Register notice
was published on November 13, 2007 with interim final guidance establishing a
government-wide award term for agencies to include in grants and cooperative
agreements a condition authorizing termination of the award if the recipient or a
subrecipient engages in certain activities related to trafficking in persons.
OGPOE may issue an action transmittal to implement HHS policy.
o Grants Policy Update – Nancy Weisman provided the status of the updates for
the AAGAM and GPD Chapters that remain to be completed.
GPD 5.01 Mandatory Grants -Under management review
AAGAM 4.02.102 Debt Collection and Closeout - Under management
review; Potential issues in light of audit closeout report
AAGAM 4.01.101 Audit – Comments received from Policy Work Group
This will be revisited in light of comments indicating the process should be
reformed rather than working the policy around a flawed process. Heber
Willis will take over this effort.
AAGAM 6.99.107 Conference Grants - Under management review
AAGAM 6.99.102 Change of Recipient - Discussed at Policy Work Group
AAGAM 6.99.106 Construction Grants - Draft completed and revisions
need to be made; Next Step: Send to Policy Work Group for comments
AAGAM 6.99.104 Grants to Federal Institutions - Draft completed; Next
step: Send to Policy Work Group for comments
AAGAM 6.99. Financial Evaluation of Grant Applications - Draft due in
AAGAM 6.99.101 Public Policy Requirements - Draft reviewed by Policy
Work Group. On hold pending revisions to HHS GPS to ensure
o Grant Policy Statement Revision & Award Administration Guidance - This
overview provided an assessment of the current model of the Grants Policy
Statement (GPS); and the transition plan to differentiate between, reorganize and
relocate the policy, guidance, terms and conditions (T&C), and general
information that is currently co-mingled within the GPS to appropriate web-based
vehicles on an organized, intuitive, transparent ―Award Administration‖ site for
internal and external grant program management.
OGPOE is tasked with removing appropriations-related provisions, which
could change year-to-year, from the GPS. Office of Budget, OS/ASRT
agreed to provide and post all appropriations provisions on the web and
clearly identify the OPDIV applicability of any cross-cutting provisions
(e.g., those currently in GPS).
Current GPS combines legally-binding T&Cs with policy and guidance.
Draft PL106-107 Government-wide administrative (A-102 & A-110) T&Cs
and national/public policy T&Cs will replace most GPS T&Cs, and must
be posted at an agency web site. Draft OMB Title 2 regs expected to be
available for review this spring.
Reorganize and relocate GPS policies, guidance, T&Cs and general info
to their respective areas of the Award Administration web site; ensure a
transition to plain language and Sec. 508 compliance; and ensure T&C
language is solidly legally-binding.
Comments and recommendations welcome!
Primary Contact: Scott Cooper at email@example.com, 202-690-7157.
Secondary Contacts: Gregg Ukaegbu at firstname.lastname@example.org, 202-690-
6574; Rodd Clay at email@example.com, 202-690-8723.
o PL 106-107 - Due to other discussions and time constraints, this presentation
was rescheduled for the February ECGAP meeting. It was noted that OGPOE
staff attend all GPC working group and subgroup meetings on behalf of all HHS
entities and work to coordinate HHS-wide information sharing. If you are heading
any GPC working group or subgroup, please accept responsibility for letting
Rodd Clay know the meeting times, agendas, and providing him with any follow-
up notes. Rodd, in turn, will route these to the appropriate OGPOE staff person
and will get back to you with the most appropriate OGPOE name for future use.
o Training and Certification – MariAnn Hollis presented a plan to develop and
establish an integrated competency-based system to train, provide learning
opportunities, and enhance skills of grants managers at all proficiency levels. In
the first year, OGPOE proposes to team extensively with ECGAP to identify
Federal financial assistance management competencies at HHS via a series of
3-4 focus group sessions using a ―job analysis‖ process, measure competency
gaps through an online assessment tool, and conduct a survey of HHS Federal
Financial Assistance Management personnel. The assessments will be used
HHS-wide and at the OPDIV level in assessing workforce skills, determining
gaps, identifying training needs, and improving organizational planning.
OGPOE asked ECGAP Members for their assistance with the following: identify
7-8 grant management professionals from each OPDIV (policy and operational),
at different proficiency levels for focus group participation; facilitate provision, in
the next few months, of name and email contact information of all staff involved
in federal financial assistance management in order to conduct the survey; and
begin to consider whom each OPDIV would recommend (policy & operational ) to
serve as a trainer and adjunct faculty. Requests for Information will be sent to
ECGAP Members in the new year.
Also, OGPOE expressed interest in forming a small Rapid Assessment Team
(RAT) to serve as Subject Matter Experts (SMEs) by providing input in the
competency development and analysis processes and in the conduct of the
survey instrument. Those interested in being a part of the RAT were encouraged
to contact OGPOE Training Team Lead, Mari Ann Hollis, at 202-401-2751 or
o Oversight and Evaluation - This presentation was rescheduled for the February
o Grants Forecast Update – Included in the OGPOE Director’s report.
o Learning Experience Plan –As part of the Individual Development Plans (IDPs) of
some OGPOE staff, staff would like to visit OPDIVs for three weeks a year, a week
each time, in order to learn more about OPDIV issues and operations. An
agreement would be made between an OPDIV and an OGPOE staff member to
spend up to three weeks (one week intervals) over the course of a year to shadow a
grants management specialist to better understand the policy and operational
procedures and issues at the OPDIV level. It’ll allow OGPOE staff to put the theory
of ―policy‖ into a practical application. This will provide OGPOE staff with invaluable
experience as future policy issues arise or existing policies are revised. It’ll also
allow the OPDIV staff to become better acquainted with OGPOE staff and to share
their expertise and/or concerns for policy-related issues. OPDIVs interested in
allowing OGPOE staff to come to their offices should contact Lluana McCann.
o HRSA raised concerns about a December 7, 2007 Federal Register final notice
regarding financial reporting of grants and cooperative agreements. OGPOE will
issue an RFI to the OPDIVs to solicit comments and will provide a combined
response to OMB on 1/7/08 with copies to each participating OPDIV.