The federal government awards over $1 trillion in grants and other assistance to states, localities, tribes and territories each year. However, the process of applying for that money and understanding how it can be used is complicated. Federal agencies have interpreted the Office of Management and Budget’s (OMB) granting rules differently in some cases, adding to the uncertainty. Now, the federal government is working to change that through revised Uniform Grants Guidance and greater cross-agency coordination.
On April 29, 2024, Results for America and the Data Quality Campaign co-hosted a conversation with leaders from the White House and state and local governments exploring how OMB’s newly updated Uniform Grants Guidance cuts red tape and emphasizes opportunities to use federal grants for data, evaluation and community engagement. What follows are highlights from the conversation.
What is the OMB Uniform Grants Guidance, and How Is This Version Different?
The Uniform Grants Guidance lays out basic rules for how federal grants and other assistance are managed, both by federal agencies and by organizations that receive the money. OMB’s Deputy Director for Management Jason Miller described it as “the plumbing for our federal financial assistance system.” 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.
Miller described the new updates as including “a laser focus on burden reduction for recipients because we want our recipients spending dollars on outcomes, not on overhead.” For example, OMB uses plain language to make the rules clear, reduces the burden of applying for and reporting on grants, and is explicit about the ability to use grant funds for data, evaluation and community engagement.
How Do Federal Leaders Expect the Guidance to Help States and Localities?
As Results for America Chief Operating Officer David Medina noted about the guidance, “the changes will only have a positive impact when they are fully implemented by federal agencies and grantees.” As agencies do their part to implement the updated guidance effectively, here are some of the key results that federal leaders expect:
- Go-to guidance for the field. OMB Deputy Controller Deidre Harrison believes that the Uniform Grants Guidance should be the go-to place for answers about how federal dollars can be spent, including on data and evaluation. She stated, “If you don’t know how or what you should be doing at a specific moment, the Uniform Grants Guidance should be the place you are going.” Harrison added that writing the guidance in plain language was a key priority. “We wanted to make sure that we were creating a document that first and foremost didn’t require a lawyer to interpret.”
- Consistent federal rules. The goal is for agencies to interpret and implement the guidance consistently. The release of the guidance aligns with new efforts to speak with one voice across agencies about key grants management questions, particularly through the Council on Federal Financial Assistance established in August 2023. Harrison shared, “For the first time, we are bringing together senior leadership at all of the agencies that provide financial assistance to ensure that when we get questions asked of us, we are answering it consistently. That implementation as one government should be felt by recipients everywhere.”
- Stronger data infrastructure for grantees. OMB wants grantees to understand the impact of federally funded projects and to have the tools to know how to improve a program’s impact. The guidance explicitly allows funds to pay for data infrastructure, including integrated data systems, and capacity for analysis and evaluation. OMB Associate Director for Performance and Personnel Management Loren DeJonge Schulman explained, “We want grantees to feel as though they can research the impact of programs that are important to states and local governments and to understand what impact is this having over time, what might we do differently in the future, and how can we share that with friends and colleagues across the country who are doing similar work.”
- Better service to the public. Denice Ross, Deputy Chief Technology Officer for Tech Capacity at the Office of Science and Technology Policy, offered an example of how a public transit agency could use a federal grant for electric buses to illustrate how the updated guidance can support data and evaluation that directly helps the public. “They could use some of those funds to install GPS in each of the buses, and that way you can track where the buses go and integrate that location data with other data, for example, on how many people they pick up at each bus stop. Those data would be essential for that learning … for evaluating whether you’re meeting the needs of the most underserved communities, or if you need to adjust your routes or the timing between buses.” Ross extended the example to include using geographic data to let riders track buses on their phone and investing in an asset management system to track routine maintenance needs. She concluded, “So by carving out funds for tech, data, and learning and evaluation … you can better serve your constituents and deliver on the goals of the federal program.”
How Should States and Localities Leverage the Guidance?
A state and local panel then discussed ways grantees can leverage federal grant funds to invest in integrated data systems to support performance management, evaluation or technology systems. Speakers included Dr. Yvonne Humenay Roberts, Chief of Performance Measurement and Evaluation at King County Department of Community and Human Services in Washington state and Josh Martin, Chief Data Officer and Executive Director of the Indiana Management Performance Hub. Their experiences show how states, localities and others can leverage the OMB guidance in impactful ways:
- Build data and evaluation capacity to meet your community’s near-term and long-term needs. Roberts shared how King County leveraged federal pandemic relief funding alongside state and local funds to invest in evaluation and data systems for the Eviction Prevention and Rent Assistance Program (EPRAP). The program, which lasted three years, focused on equitable access to rent assistance for groups that have historically faced discrimination and groups disproportionately impacted by COVID-19. EPRAP reached more than 40,000 people and distributed $390 million around the region, with 74% of recipient households headed by a person of color. A portion of federal funds received was used to support new evaluation staff to lead the work as well as data systems that helped the County establish housing stability metrics. Roberts encouraged states, localities and others to leverage the OMB Guidance to take key steps that made a difference for King County. These include developing a dedicated evaluation budget, supporting staff professional development opportunities, and building infrastructure to support data integration and community engagement efforts. “I also believe EPRAP is a good example of how to use federal funding to not only answer a specific question or set of questions, but to create something that outlasts and builds upon the initial investment,” she said. “Now, we have really clean data to assist in future evaluation work. This allows us to use our integrated data hub to match and merge our evictions, housing stability and EPRAP data to explore long term impacts of rental assistance programs.”
- Blend and braid funds to expand capacity and build integrated data systems. Reflecting on Indiana’s experience, Martin discussed the importance of blending and braiding funds from different federal sources to support Indiana’s Management Performance Hub (MPH), which began under a 2014 executive order and is now codified as a state agency. According to Martin, MPH relied on “a lot of blending and braiding of funding to slowly and incrementally build up our data platform and our data capacity, like using funding from [the Centers for Medicare & Medicaid Services] to create an open data portal for Medicaid data, and then leveraging that again as the open data portal for other state efforts.” Blending and braiding refer to strategies that use funds from multiple programs together to support shared infrastructure, outcomes and initiatives. MPH’s incremental work paid off, especially during COVID, when its integrated data system that brings together data from across areas of government allowed a first-of-its-kind study with the Fairbank School of Public Health to find out the population prevalence of COVID using random sampling.
- Use direct and indirect costing strategically. The Uniform Grants Guidance includes technical rules about classifying costs – including costs for data and evaluation – as direct or indirect, which can offer flexibility for grantees. Looking ahead to the value of the updated OMB guidance, Martin said, “In the past, we really left a lot of indirect cost funding on the table because it was just too complex to try to go through the calculations to get there. … But now there’s a lot clearer ways about how we can go about doing that and there’ll be consistency across all of our different state agencies and the way that they’re working with their federal programs about how we can leverage the funding.”
What Advice Do the Speakers Have for Each Level of Government?
The updated guidance covers a broad range of topics, many of them technical. Given that inherent complexity, what is the main advice that federal leaders hope that grantees hear? The webinar speakers emphasized communication and flexibility for states and localities.
- Deputy Chief Technology Officer Ross: “My number one recommendation is to have your tech, data and evaluation leaders at the table when you’re designing your federally funded initiatives.”
- Associate Director Schulman: “Use this as an opportunity to go back to conversations where the answer previously was no to say, actually, let’s explore this. The answer might be yes.”
- Deputy Controller Harrison: “If you’ve heard nothing else, it would be please keep communicating with each other and with us.”
Meanwhile, asked what they need from the federal government, state and local speakers encouraged strong leadership and communication.
- Dr. Roberts: “First, the federal government’s leadership and signaling and leading on the use of federal funds to support evaluation is so important and welcome and will bring broader support to state and local government investments and evaluation, which is really exciting about this moving forward. In terms of specific support, conversations like this one that’s been set up today are a great start, and I encourage federal partners to continue to create opportunities for shared learning and advancing the conversation.”
- Chief Data Officer Martin: “Just them getting on the same page at the federal level will be helpful and those programs being consistent in the way that they’re managing with the program level folks here at the state. Anytime you want to create a guidebook, a how-to guide, a show-me or have a helpline. If we can phone a friend and say, hey, this is what we’re thinking … or is there a better way for us to think about leveraging federal funding rather than what we’re planning?”
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.