What if the federal government made it simpler for states, tribes and localities to access and get results from the more than $1.2 trillion in federal assistance they collectively receive each year? In April, the U.S. Office of Management and Budget (OMB) released updated Uniform Grants Guidance designed to do exactly that by streamlining requirements, reducing burden on grantees, clarifying governmentwide grants policy and mandating that agencies actively simplify the process to apply for federal grants through notices of funding opportunity (NOFOs). When implemented effectively, these changes will increase access to grants, particularly for underserved communities, and allow grantees to devote more time to improving the lives of the people they serve.
On May 15, 2024, Results for America and the Data Quality Campaign co-hosted a conversation with leaders from federal and state agencies to examine these changes and how they will support a clearer, simpler grants process. Below are takeaways from the session, including five key ways the guidance is clarifying the grants process and insights on what simpler NOFOs mean in practice.
What is the OMB Uniform Grants Guidance, and How Does It Affect Grant Competitions?
The Uniform Grants Guidance lays out basic rules for how federal grants and other assistance are managed by federal agencies and organizations that receive the money. OMB’s Deputy Controller Deidre Harrison described it as “the least common denominator” where policy should largely be consistent across the federal government. The guidance covers a tremendous range of topics, such as defining key terms, stating what funds can and cannot pay for, setting reporting requirements, and telling agencies what to put in the notices of funding opportunity (NOFOs) that they use to announce competitive grants. While programs have specific rules and requirements, the guidance sets an overall framework that grants have to follow, unless a statutory requirement from Congress says otherwise.
The guidance directly affects agency NOFOs by providing a template for agencies to follow as they release grant competitions. OMB Deputy Director for Management Jason Miller said, “Organizations ultimately should be competing on merit, not on their ability to interpret complicated NOFOs. To help address this problem, the new Uniform Grants Guidance includes a streamlined NOFO template for agencies to use in order to shorten and simplify agency grant announcements. And agencies, in doing that, are directed in the guidance to use plain language and write the announcement at a level that is accessible for the potential applicants for getting grants.”
Five Ways the Updated Guidance Supports Clarity and Access in the Grants Process
OMB´s new guidance focuses heavily on streamlining requirements and using plain language. Harrison described OMB´s perspective in considering updates, “We tried really, really hard to think about if you’re a new recipient, working with the federal government for the first time, what are the steps you need to take in order to become in compliance?” She added that their goal with the new guidance was to use clear terms and reduce red tape.
Here are five ways that the guidance fulfills this goal:
- Streamlined NOFO template for shorter, simpler grant announcements. OMB first introduced a template for NOFOs in 2014, which appears in the guidance as Appendix I. This step brought cohesion to what Deputy Assistant Secretary for the Office of Grants at the U.S. Department of Health and Human Services (HHS) Dale Bell referred to as “a little bit of a wild west” in how NOFOs worked. However, strict and literal interpretations over time actually built new barriers. Bell affirmed that the new Appendix I will “build on the conformity that’s expected in it, but also be flexible in making sure that programs can reach their audiences.”
- Plain language in grant announcements. The guidance instructs agencies to write NOFOs that are concise and use plain language, including following the guidelines at plainlanguage.gov. Agencies like HHS are already taking the lead in agency-wide initiatives to make NOFOs simpler, more readable and more engaging so that a wide variety of organizations can apply. Bell described his goal, “I want people when they use HHS and other improved NOFOs to be blown away by how clear and understandable it is. And my goal, my vision is that people are going to see these improved NOFOs, and they’re going to demand them and it’s going to be a drumbeat that federal agencies do a better job.”
- Community input into program design. The guidance calls on federal agencies to develop their programs in consultation with the communities the program will benefit or impact, in addition to considering available data, evidence and evaluation results. Harrison emphasized, “We need to make sure in program design that agencies are engaging with communities such that they are creating programs to meet the communities where they are.” Otherwise, they risk overlooking key practical needs. She said that as part of the process, federal agencies can ask, “Did we simplify our NOFOs in such a way that we saw new entrants? Did we design our program in such a way that we are getting the output that we were expecting on the front end?”
- Money for data and evaluation. The updated guidance explicitly allows grantees to use federal funds to pay for data infrastructure, including integrated data systems, and capacity for analysis and evaluation. Lisa Morrison Butler, Executive Vice President and Chief Impact Officer at Results for America, used her experience as Commissioner of the Chicago Department of Family and Support Services to illustrate why this matters. “[In Chicago] we wanted to track residents across all of our programs and services to better meet their needs at the time. We used philanthropic dollars to build that data warehouse because we were not certain we could use federal dollars from different grants for that purpose – that’s exactly why this OMB guidance is so exciting.”
- Coordination by the Council on Federal Financial Assistance (COFFA). Bell explained that the COFFA was started in October 2023 “to create a forum and a mechanism by which the [federal financial assistance] community can look at upcoming requirements together so that we can understand what the implementation challenges are going to be.” The COFFA includes representation from the major 24 federal agencies and some small agencies, and will focus on implementing the updated guidance effectively and consistently. Harrison said about the COFFA, “I hope that the big change, the big impact the recipients are going to see is that when they start to ask those questions that we know you’re all going to ask, you start to get the same answers from multiple agencies.”
What Do Simpler NOFOs Mean in Practice? Insights from Federal and State Leaders
- Clarity on how grants can be used is just as important as the money itself. Ninah Sasy, Director of Policy and Planning at the Michigan Department of Health and Human Services (HHS), explained how clear rules mean that even smaller grants have an outsized impact. Michigan’s HHS receives about $17 billion annually in federal funds, including large formula-based funding like Medicaid. Nonetheless, a smaller $125,000 competitive grant for their Social Determinants of Health (SDOH) Accelerator Plan to Prevent Chronic Disease played a key role because Michigan knew it could spend the funds in needed areas and that applying would be worth the staff effort. Sasy explained, “We needed something to complement what we already had in place and really allow us to have that community engagement element. Knowing that we can use [the award funds] for that purpose and allowing us to host these regional listening sessions complemented what we could do and what we wanted to bring forward. It was also helpful for us because it included that evaluation piece, which is also important as we think about our SDOH accelerator plan in the work that we’re doing. It has to speak to and it has to be inclusive of the voices of the community. We also have to be able to adapt based on the current environment. So having that evaluation component as well as being able to incentivize community engagement was so important.”
- Clarity supports on-the-ground partnerships. Sasy described how a better grants process helps local and community-based organizations that partner with the state, even when they are applying separately. Clear requirements make it easier to prioritize applications and to understand whether an organization has the capacity to meet the requirements. “So it’s not only beneficial for us as a state agency, but it also allows us to empower and make sure that our local partners are in the driver’s seat so that they can apply directly for funding,” she said.
Simplifying Agency NOFOs: Four Tips to Get Started
- Start small for agency-wide success. Julie Wiegandt, Senior Management and Policy Advisor at the U.S. HHS, explained how the department’s efforts to simplify their NOFOs started with research and a few prototypes before growing into a much larger effort. “Once we did those four prototypes, we were able to kind of expand those learnings into what we call our pilot phase, which is where we are now. So we’re working on about 80 pilot NOFOs. And we’re continuing to really focus on evaluation so we can kind of make them as best as possible before we scale even larger.”
- Look across NOFOs for what can be streamlined. Rather than going NOFO by NOFO, look across them for opportunities to streamline and simplify. Elizabeth Overstreet, Senior Adviser at the U.S. HHS Office of Grants, said, “We also wanted to simplify radically the content of the NOFO to only include what was really necessary to an applicant at that point in the grant lifecycle and redesign it for just a logical sense. … [The new guidance allows] freedom to move things to put content online, so you’re not filling up your NOFO with all this dense material that people really don’t need to have as part of that initial grant application document.” Using graphics and design can also significantly improve readability and length.
- Bring in the right skill sets. In addition to plain-language writing skills, strong NOFO design also calls for design experience, content development and even legal counsel. Overstreet illustrated the U.S. HHS experience, “We have somebody in our team who we call ‘the merciless editor.’ She was really instrumental in getting our boilerplate language down and using a combination of design and content development together. … Bring your legal counsel in early, especially as you’re working on your boilerplate language. We got a lot of questions along the way as we were streamlining boilerplate and standard language and moving things online.” Agencies can also look to existing examples like HHS for tools and resources to get started.
- Change management is essential for federal agencies. Wiegandt explained how she realized the importance of focusing on change management. “Really make sure you’re addressing the processes and people around the NOFO as much as you’re addressing the actual writing and design,” she said. “I am kind of by nature a person that’s like, oh, we want a shorter NOFO – cut it in half, and come back to me when you have a shorter one. And that’s what this process has really taught me, that it’s much more than that. It’s about change management. It’s about giving the programmatic teams ownership over their NOFOs. And just making sure that the whole surrounding process is as streamlined as possible so that the final product can be simple.” In addition, metrics can help show success and progress. For example, the HHS pilot has shown a 45% reduction in word count, a 39% reduction in sentence length, and a reduction of between three and four reading grade levels from the original to simplified NOFOs.
The updated guidance goes into effect for all federal awards as reflected in the Terms and Conditions beginning October 1, 2024. In addition, entities with existing federal grants can reach out to federal agencies now to discuss potential changes to the terms and conditions of their grants and if updates in the guidance could be applied to grants beginning earlier.
Visit Results for America’s Uniform Grants Guidance Resource Guide to learn more about important revisions and implementation actions for federal agency staff.