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Grants Gazette

HRSA Office of Federal Assistance Management Grants Gazette

Editor’s Note: The Grants Gazette is a resource you can use to successfully manage your HRSA grant. Please reach out to us and let us know what type of information you want to see in future newsletters. We look forward to hearing your opinions and feedback.

Financial integrity experts explain OMB extensions

Office of Management and Budget (OMB) Memo M-20-26, issued on June 18, 2020, rescinded many of the previous audit extensions that OMB Memo M-20-11 and M-20-17 provided. The only remaining extensions permitted relate to fiscal year-ends ending Dec. 31, 2019, and prior.

For your awareness, we've provided a summary of the OMB extensions:

Six-month extensions (Normal due dates between March 30, 2020, and June 30, 2020, based on fiscal- year-ends between June 30, 2019, and Sept. 30, 2019)

• HRSA recipients that are affected by the loss of operational capacity due to COVID-19;
• have not filed their audit by March 19, 2020; and
• have a normal due date from March 30, 2020, through June 30, 2020, may delay their Single Audit submissions up to six months beyond the normal due date.

Three-month extensions (Normal due dates between July 31, 2020, and Sept. 30, 2020, based on fiscal-year-ends between Oct. 1, 2019, and Dec. 31, 2019)

• HRSA recipients that are affected by the loss of operational capacity due to COVID-19;
• have not filed their audit by March 19, 2020; and
• have a normal due date from July 31, 2020, through Sept. 30, 2020, may delay their Single Audit submissions up to three months beyond the normal due date.

If you choose to delay your single audit submission, you are not required to seek prior approval; however, you should maintain documentation of the reason for the delayed filing.

If you have questions about your ability to obtain extensions, or if you want to inform HRSA you will be taking advantage of the flexibilities, email HRSA's Division of Financial Integrity.

Uniform Guidance revisions effective Nov. 12

On Aug. 13, 2020, the Office of Management and Budget (OMB) published a notice in the Federal Register about final changes to 2 CFR 25, 170, 183, and 200.

Also known as the “Uniform Guidance,” 2 CFR 200 – codified for HHS and HRSA at 45 CFR 75 – has the full title of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”

The revisions to the Uniform Guidance are effective Nov. 12, 2020.

The goal of the 2 CFR 200 revisions is to strengthen the government-wide approach to performance and risk by encouraging federal awarding agencies to measure the recipient’s performance in a new way. This new measure will help agencies and recipients improve program goals and objectives, share lessons learned, and spread the adoption of promising performance practices.

These changes reflect shifts in the President’s Management Agenda and set the stage for enhanced result-oriented accountability for grants; they also reflect a focus on improved stewardship and ensuring value for funds spent on grant programs.

HHS is developing an implementation strategy for the 2 CFR 200 revisions. In the coming weeks, we will provide you with updates, including a timeline for re-aligning HHS grant regulations 45 CFR 75 with the 2 CFR 200 updates.

HRSA begins using ‘Document Number’ as ‘Sub-Account Code’

For better tracking of grant funds, HRSA is now using the Document Number as the Sub-Account Code for new and competing continuation awards issued after Oct. 1, 2020.

Notices of Award (NoA) with Project Periods of on and after Oct. 1, 2020, will display the "Document Number" within the "Sub Account Code" field.

You will continue to use the PMS account number and sub-account code to draw down funds from PMS; however, the sub-account code will be the document number for new awards.

Additionally, recipients will continue to use their existing sub-account code to draw funds from PMS for awards with project periods prior to Oct. 1, 2020.

Check your HRSA NoA to ensure you are using the correct sub-account code to access your grant funds.

If you have any questions about the change to the HRSA sub-account codes, contact your Grants Management Specialist listed on the NoA.

The Mailbox: You submit a question, we provide an answer

Question: Do Legislative Mandates expire when the fiscal year ends?

Answer: Legislative Mandates are restrictions that govern how you can spend federal assistance. We receive questions about legislative mandates almost every year when the fiscal year is closing. Our grants policy experts explain why the answer is “Yes and No."

Yes – The Legislative Mandates are part of the annual appropriation bills restricting how we use federal funding in that particular fiscal year. As Congress provides funding for HRSA programs through appropriation bills, they also restrict how you spend grant dollars. Each year, lawmakers place restrictions on the funding they approve, and while each year these restrictions could change, for the last few years, the Legislative Mandates for HRSA have remained the same.

No – The Legislative Mandates are part of the annual appropriation bills. If Congress does not pass a new appropriation before the next fiscal year begins, the Legislative Mandates from the previous fiscal year remain in effect. Therefore, Fiscal Year (FY) 2020’s mandates are in effect until Congress passes the FY 2021 appropriation bill.
So, if someone asks whether they have to follow the same restrictions as last year, just check to see if Congress has passed a new appropriation bill funding HRSA. As soon as HRSA receives a new appropriation, we will post a grants policy bulletin on HRSA.gov, on the Policies, Regulations, & Guidance Web page.

Learn more about the 12 current Legislative Mandates governing HRSA funding. Check out our Grants Policy Bulletin: Legislative Mandates in Grants Management for FY 2020 (PDF - 398 KB).

Date Last Reviewed:  October 2020