Inside the Thinking of Federal Reporting Compliance Yesterday and Today
By Adam Roth on September 8, 2021
The Grant Reporting Efficiency and Agreements Transparency (GREAT) Act of 2019 was signed into law in December 2019. The GREAT Act was designed to create efficiency and oversight in Federal grant spending by improving reporting practices and data collection. One of the key provisions of the GREAT Act was the adoption of data standards. The data standards established by the GREAT Act must include, at a minimum, standard definitions for the data elements required for managing Federal awards, unique identifiers for both the award and the recipient that can be applied consistently across the Federal government, and they must be machine-readable.
The Uniform Grant Guidance (UGG) went into effect in November of 2020 as well, and while this guidance too centers on the importance of data-driven performance reporting, the UGG does not currently require this data to be machine-readable, or standardized, like the GREAT Act does. There are connections between the Office of Management and Budget’s (OMB) UGG and some key principals of the GREAT Act – namely the increased focus on programmatic reporting and tracking– that could benefit from the adoption of standard data, and the Federal government is taking steps toward aligning the data requirements between these two key pieces of legislation.
There is growing interest in using the Federal Integrated Business Framework (FIBF) as the core of the data elements and business processes required for reporting on Federal funds. The FIBF is “a model that enables the Federal government to better coordinate and document common business needs across agencies and focus on outcomes, data, processes and performance.” Through AmpliFund’s work with MITRE on a proof-of-concept pilot study, we have concluded that the incorporation of currently published FIBF data standards could be an effective solution. We have already begun building the API and the data exit points for the FIBF data in the event that the incongruence between the GREAT Act and the UGG reporting requirements is resolved soon.
Recipients should have access to a standard way of reporting data, and with the implementation of FIBF data standards, all you would need to do is make sure you have your data in the correct structures for reporting. Essentially, the FIBF would provide not only data standards that could be applied consistently, but also standardized business processes and standard ways of reporting data that would give you the freedom to focus on performance outcomes. The FIBF created use cases and business processes that are required to manage grants, and from these use cases, they have created a list of about 400 data elements that are relevant to the grant process and defined them. If these data standards are adopted and required by the UGG as well, this would significantly reduce recipient burden and provide the Federal government with oversight and transparency into outcomes.
AmpliFund has been at the forefront of the conversation about the adoption of data standards as well. In mid-August, our Head of Product, Jason Yu, and I were invited to speak to The House of Representatives Committee on Oversight and Reform – the Committee that owns the GREAT Act – about the implementation of GREAT Act data standards. We discussed the next steps that would need to be taken to adopt and implement these standards, and the possibility of bringing the Office of Management and Budget into the conversation as well.
Data standards will become even more important over the course of the next three years as more local governments and Tribes begin managing American Rescue Plan Act (ARPA) funds. Standardizing data and processes for reporting would not just provide the government with transparency, but it would allow you to focus more on your outcomes and programmatic success and less on duplicative paperwork.
If you’re looking for more information on how to start standardizing your data collection processes now, we have resources for you.