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United States Government Accountability Office: 

July 2009: 

Grants Management: Has Systemic Weaknesses That Require Attention: 


GAO Highlights: 

Highlights of GAO-09-589, a report to congressional requesters. 

Why GAO Did This Study: 

In response to the Federal Financial Assistance Management Improvement 
Act of 1999, the Office of Management and Budget (OMB), among other 
things, developed as the central grant identification and 
application portal for federal grant programs. OMB oversees the 
initiative and named the Department of Health and Human Services (HHS) 
its managing partner. officials have acknowledged noticeably 
degraded system performance, and grantees have reported difficulties 
submitting applications that have in some cases led to late or 
incomplete submissions and lost opportunities for both grantees and 
populations served. Through analysis of agency documents, a Web-based 
survey of federal grant-making officials, and interviews with agency 
officials and grantee associations, this requested report examines (1) 
the benefits of and applicant experiences with submitting 
applications, (2) the governance structure of, and (3) the 
range of agency policies for processing applications. 

What GAO Found: has made it easier for applicants to find grant 
opportunities and grantors to process applications faster, but 
applicants continue to describe difficulties registering with and using, which sometimes result in late submissions. 
customer service staff do not always resolve these issues, especially 
during off-peak hours and peak submission periods. 

Clear roles and responsibilities for the oversight entities 
and coordination among them are critical, yet insufficient, and there 
are no written policies for how these entities are to work with each 
other. HHS’s Chief Information Officer and the Grants Executive Board 
(GEB) share responsibility for approving major initiatives and funding 
for, but there is little evidence that GEB-approved funding 
for is considered in HHS’s review of as an IT 
investment. This created a disconnect between the services 
is to provide and the funding needed to purchase them. Untimely payment 
by the 26 agencies that fund also negatively affects system 
performance. After informing agencies that it was unable to pay its 
vendors, the Project Management Office (PMO) developed a 
system shutdown plan and implemented the first step—it eliminated Web 
site updates and moved all notices to the blog. 
also lacks performance measures for important aspects of the system. 
Finally, grantees lack a structured forum for input on the 
system and standardized governmentwide grant application policies, 
limiting grantees’ ability to affect a system designed, in part, to 
streamline the grants application process and ease applicant burden.  

Disparate agency policies on important aspects of processing 
applications—such as the criteria for granting appeals for late or 
incomplete applications and for what constitutes a timely application—
burden applicants and sometimes puts applications submitted through at a disadvantage compared to applications submitted through 
other means, such as other electronic systems or the USPS.  

Figure: Entities Involved in the Federal Grants Pre-Award Stage of the 
Grants Life Cycle: 

[Refer to PDF for image: illustration] 

Grant-making partner agencies: 26: 
Grant-making officials from the 26 partner agencies comprise board and 
policy committee of the Grants Executive Board. 

Managing partner agency (HHS): IT management (Governance body): 
Execution team: Program Management Office (PMO): Provides 
leadership and resources to Grants Executive Board. 

Grants Policy Committee (Governance body): 
Execution team: PL 106-107 Pre-award working group: Provides 
coordination between Grants Executive Board and OMB. 

Source: GAO analysis of OMB data. 

[End of figure] 

What GAO Recommends: 

GAO is making four recommendations to OMB to develop system 
performance measures, guidance clarifying the governance structure, a 
structured means for applicant input, and uniform policies for 
processing grant applications. OMB and HHS generally agreed with our 
findings and recommendations. 

View [hyperlink,] or key 
components. For more information, contact Stanley J. Czerwinski at 
(202) 512-6806 or 

[End of section] 



Background: Offers Benefits, but Cumbersome Registration Requirements 
and Uneven System Performance Burden Applicants and Create Potential 
for Late Submissions: 

Accountability and Responsibility for Performance among the Governance Entities Is Unclear: 

Disparate Agency Policies for Processing Grant Applications Can Result 
in Different Treatment for Applications Submitted through Various 


Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Detailed Survey Description: 

Appendix II: Comments from the Department of Health and Human Services: 

Appendix III: GAO Contact and Staff Acknowledgments: 


Table 1: Top 10 Grantor Agencies by Submissions, Fiscal Year 

Table 2: Key Steps and Time Frames in the Organization 
Registration Process: 

Table 3: Top Reasons for Applicants' Late Submissions as Reported by 
Grantor Agencies for Fiscal Years 2007 and 2008: 


Figure 1: Entities Involved in the Federal Grants Pre-Award Stage of 
Grants Life Cycle: 

Figure 2: Partner Agency Funding Structure, Fiscal Year 


AAU: Association of American Universities: 

AOR: authorized organization representatives: 

CCR: Central Contractor Registration: 

CFO: Chief Financial Officers: 

COGR: Council on Governmental Relations: 

CPIC: Capital Planning and Investment Control: 

CSR: customer support representative: 

D&B: Dun & Bradstreet: 

DUNS: Data Universal Numbering System: 

EPA: Environmental Protection Agency: 

FACA: Federal Advisory Committee Act: 

FDP: Federal Demonstration Project: 

GEB: Grants Executive Board: 

GSA: General Services Administration: 

HHS: Department of Health and Human Services: 

HUD: Department of Housing and Urban Development: 

IRS: Internal Revenue Service: 

MPIN: marketing partner identification number: 

NGP: National Grants Partnership: 

NIH: National Institutes of Health: 

NSF: National Science Foundation: 

OCIO: Office of the Chief Information Officer: 

OMB: Office of Management and Budget: 

PMO: Program Management Office: 

POC: Point of Contact: 

USPS: U.S. Postal Service: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

July 15, 2009: 

The Honorable George V. Voinovich: 
Ranking Member: 
Subcommittee on Oversight of Government Management, the Federal: 
Workforce, and the District of Columbia: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Edolphus Towns: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Stephen F. Lynch: 
Subcommittee on Federal Workforce, Postal Service, and the District of 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Danny Davis: 
House of Representatives:[Footnote 1] serves as the central grant identification and 
application portal for more than 1,000 federal grant programs that 
fund, for example, training, research, planning, construction, and the 
provision of services in areas such as health care, education, 
transportation, and homeland security. However, since's 
inception, the system administrators have acknowledged the 
technical limitations of; more recently, they acknowledged 
noticeably degraded performance, and applicants have reported 
difficulties in submitting applications through In some 
cases, these issues have led to late or incomplete applications and 
lost opportunities for both grantees and the population that may have 
benefited from the grantee's programs and services. 

In early March 2009, the Office of Management and Budget (OMB) 
highlighted the critical nature of by stating that the 
implementation of the American Recovery and Reinvestment Act of 2009 
(Recovery Act)[Footnote 2] could be hampered by the failure of, which had already been experiencing noticeably degraded 
performance. Noting that was at significant risk of failure 
because of the expected increase in application volume from Recovery 
Act grants, OMB instructed agencies to identify alternative methods for 
accepting grant applications to reduce demand on's limited 
resources.[Footnote 3] At least 10 agencies are temporarily accepting 
some or all applications through alternative methods[Footnote 4] during 
the Recovery Act peak filing period, which is expected to continue 
through August 2009. However, the expectation is that agencies and 
grantees will return to their reliance on for submitting 
applications as fiscal year 2010 approaches. 

This report responds to your request to examine applicant experiences 
submitting grant applications through the Web site. To 
accomplish this, we reviewed the 1) benefits of and 
applicants' experiences when submitting applications; 2) governance and 
accountability structure of, especially with respect to 
setting policy and resolving performance issues; and 3) range of agency 
policies for processing applications, including late and 
incomplete applications. This report follows our April 2009 report on Recovery Act issues,[Footnote 5] in which we provided our 
initial observations on improving grant submission policies to help 
minimize disruptions to the grants application process during the 
Recovery Act's peak filing period.[Footnote 6] 

The information presented in this report is based on our review of 
policies and procedures related to grant applications from the Program Management Office (PMO) and federal grant-making 
agencies. We also examined documentation from the Department of Health 
and Human Services (HHS), the Grants Executive Board (GEB), the Grants 
Policy Committee, and OMB.[Footnote 7] We conducted a Web-based survey 
in December 2008 and January 2009 of 80 agency officials representing 
the 26 federal grant-making agencies and subcomponents within those 
agencies that have distinctive grant application submission and 
processing policies. Throughout this report, we call these 
organizations grantor agencies.[Footnote 8] Our survey contained 
questions on agency policies and practices with respect to competitive 
grant application submissions, and questions on agency experiences 
assisting applicants who submit applications through To 
design the questionnaire, we interviewed agency grant officials and 
pretested the survey instrument with five grantor agencies to ensure 
that the questions were clear and unbiased and that the questionnaire 
could be completed in a reasonable amount of time. When the survey 
closed in late January 2009, we had received responses from 74 grantor 
agencies for a response rate of 92.5 percent.[Footnote 9] For more 
details on how the survey was constructed, administered and analyzed 
for this report, see appendix I. We also conducted interviews with 
officials from the PMO, HHS, GEB, the Grants Policy 
Committee, and OMB. To obtain more information from the grantee 
perspective on using and other application submission 
methods, as well as agency submission policies, we reviewed documents 
from several associations representing communities of grant applicants 
and interviewed staff from these organizations. 

We conducted our work from May 2008 to July 2009 in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives. 


Over 1,000 federal grant programs are disbursed and managed by 26 
federal agencies and other federal grant-making organizations. Because 
of concerns about the burden on grantees of the varying requirements 
imposed by these different grant programs, Congress enacted the Federal 
Financial Assistance Management Improvement Act of 1999, commonly 
referred to by the grants community and OMB as Public Law 106-107. 
[Footnote 10] Public Law 106-107 sought to improve coordination among 
federal grantor agencies and their nonfederal partners. It required 
federal grant-making agencies to streamline and simplify the 
application, administrative, and reporting procedures for their 
programs. The act also required OMB to direct, coordinate, and assist 
agencies in developing and implementing a common application and 
reporting system that included electronic processes with which a 
nonfederal entity can apply for multiple grant programs that serve 
similar purposes but are administered by different federal agencies. 
Our previous reports have reviewed several aspects of Public Law 106- 
107's implementation, including 1) what agencies did to implement the 
law; 2) the coordination among OMB, the agencies and grantees; and 3) 
grantees' views of areas where the goals of the law had not been met. 
[Footnote 11] 

In response to Public Law 106-107, OMB, among other things, created (initially known as e-Grants). was included among 
the E-Government initiatives designated in OMB's 2002 E-Government 
Strategy.[Footnote 12] The Web site was deployed with both 
the "Find" and "Apply" tools on October 31, 2003, and was meant, in 
part, to improve the announcement and application stages (together 
known as the pre-award stage) of the grant-making process for 
grantees.[Footnote 13] Almost all federal discretionary grant 
opportunities are posted to the Web site; applicants can 
search for grant opportunities by agency or across agencies using the 
"Find" mechanism.[Footnote 14] Many grant announcements include a link 
to application forms and instructions. 

In order to log in and submit an application, first-time applicants 
must register with complex process involving multiple 
entities. Once registered, an applicant can log in and upload a 
completed application to[Footnote 15] notifies 
the applicant by e-mail that the application was received and provides 
a tracking number and submission time stamp. then attempts 
to "validate" the application, which includes scanning for viruses and 
verifying the applicant's eligibility to apply. If validation was 
successful, notifies the applicant by e-mail. If validation 
was not successful, notifies the applicant via e-mail that 
the application was "rejected due to errors," and the application must 
be resubmitted. makes the successfully validated application 
available to the grantor agency and notifies the applicant via e-mail 
when this occurs.[Footnote 16] Once an application is completed by the 
grantee and successfully submitted through, it is then 
retrieved and reviewed by the grantor agency. The agency then 
determines which applicant(s) is awarded the grant. If a grantor agency 
determines that an application is late or incomplete, the applicant can 
often appeal this determination. 

As with all E-Government initiatives, OMB established a management 
structure to oversee the initiative and to facilitate a collaborative 
working environment for This management structure included 
a managing partner agency--HHS for the initiative--to manage 
the system and to coordinate agency involvement in managing and 
developing procedures supporting the use of the system. Because supports "governmentwide common solutions" it is included on 
OMB's High Risk List, indicating it is to receive special attention 
from oversight authorities.[Footnote 17] The oversight and 
management structure includes an OMB portfolio manager, a managing 
partner agency, the GEB, and the PMO. 

* OMB Portfolio Manager. Categorized as a "government-to-government" 
initiative, was assigned to the government-to-government 
portfolio manager within OMB's Office of Electronic Government and 
Information Technology (Office of E-Government). The portfolio manager 
is to provide oversight and guidance to the initiative.[Footnote 18] 

* Managing Partner Agency. As managing partner for, HHS is 
responsible for managing; HHS is responsible for managing as an IT investment through the HHS's Office of the Chief 
Information Officer (OCIO). OCIO is required to manage 
through HHS's capital programming and budget process. The HHS Office of 
Grants provides departmental input to and other 
governmentwide grant initiatives, and key leadership and oversight on management and implementation. 

* GEB. The GEB was established in 2002 at HHS's request to help 
coordinate agency involvement in managing and consists of 
grant-making officials from the 26 partner agencies; the OMB government-
to-government portfolio manager is a non-voting member of the board. 
The GEB's role is to provide strategic leadership and resources to, including reviewing implementation and operational 
policies, the budget, and the level of financial 
contribution of each partner agency. The GEB charter states that it 
"will serve as an authoritative voice for the grant-making agencies, 
providing a governance body that can vote on proposals and deliverables 
as representatives of the grant-making agencies." The chair of the GEB 
in fiscal years 2008 and 2009 is a senior grants policy official from 
the Environmental Protection Agency (EPA). 

Like many E-Government initiatives, is funded by voluntary 
contributions from its partner agencies. Memorandums of understanding 
between the PMO and the partner agencies lay out the amount 
and timing of the contributions to be made and the services 
to be provided. The GEB uses a funding algorithm--based primarily on 
the total dollar amount of each agency's discretionary grant awards--to 
determine the contribution required from each of the 26 grant-making 
agencies. In a 2005 report, we reported that most of the 10 E- 
Government initiatives that were funded by voluntary agency 
contributions experienced shortfalls from their funding plans for 
fiscal years 2003 and 2004; in most cases contributions from partner 
agencies were made in the third and fourth quarters of those fiscal 
years.[Footnote 19] 

* PMO. Day-to-day management of the initiative 
and its budget is the responsibility of the PMO, which is 
located within HHS and is currently staffed by nine employees plus 
supporting contractor personnel. The PMO is also responsible for 
managing the process to update the standard grant application forms (SF 
424 series) approved by OMB for governmentwide use.[Footnote 20] 

The Grants Policy Committee, established by the Chief Financial 
Officers (CFO) Council,[Footnote 21] has overall responsibility for 
implementing Public Law 106-107. One of its goals is to "simplify 
federal financial assistance processes to make them more uniform across 
agencies and eliminate unnecessary burdens on applicants, grantees, and 
federal agencies."[Footnote 22] Specifically, the Grants Policy 
Committee is to, among other things, coordinate all federal grants 
policy recommendations submitted to OMB, recommend uniform forms and 
formats for grant applications and post-award reports, recommend 
standard and streamlined federal-to-grantee business processes, 
facilitate greater community input and outreach in streamlining federal 
financial assistance and collaborate with the GEB on and 
other streamlining issues. The committee's pre-award working group is 
responsible for developing policy proposals for streamlining and 
simplifying the pre-award stage of the grants life cycle. Figure 1 
illustrates the various entities involved in the grant pre-award stages 
at the federal level. 

Figure 1: Entities Involved in the Federal Grants Pre-Award Stage of 
Grants Life Cycle: 

[Refer to PDF for image: illustration] 

Grant-making partner agencies: 26: 
Grant-making officials from the 26 partner agencies comprise board and 
policy committee of the Grants Executive Board. 

Managing partner agency (HHS): IT management (Governance body): 
Execution team: Program Management Office (PMO): Provides 
leadership and resources to Grants Executive Board. 

Grants Policy Committee (Governance body): 
Execution team: PL 106-107 Pre-award working group[A]: Provides 
coordination between Grants Executive Board and OMB. 

Source: GAO analysis of OMB data. 

[A] The other Grants Policy Committee working groups are: 1) post-
award, 2) mandatory, 3) audit oversight, 4) training and certification, 
and 5) electronic (new as of May 8, 2009). 

[End of figure] 

The E-Government Act of 2002 and the Clinger-Cohen Act of 1996 are 
relevant to as an IT investment. 

* E-Government Act of 2002.[Footnote 23] In implementing this act, 
OMB's Office of Electronic Government and Information Technology is 
responsible for, among other things, providing overall leadership and 
direction to the executive branch on electronic government and 
oversight of governmentwide implementation of information technology, 
including monitoring and consulting on agency technology efforts. 

* Clinger-Cohen Act of 1996.[Footnote 24] Among other things, Clinger- 
Cohen requires agencies to better link their IT planning and investment 
decisions to program missions and goals and to implement and enforce IT 
management policies, procedures, standards, and guidelines. The act 
also requires that agencies engage in capital planning and performance 
and results-based management.[Footnote 25] OMB's responsibilities under 
the act include establishing processes to analyze, track, and evaluate 
the risks and results of major capital investments in information 
systems made by executive agencies. OMB must also report to Congress on 
the net program performance benefits achieved as a result of these 
investments.[Footnote 26] 

In response to the Clinger-Cohen Act and other statutes, OMB developed 
a policy and a Capital Programming Guide for the planning, budgeting, 
acquisition, and management of federal capital assets that direct 
agencies to develop, implement, and use a capital programming process 
to build their capital asset portfolios.[Footnote 27] Among other 
things, this guidance directs agencies to: 

* evaluate and select capital asset investments that will support core 
mission functions and demonstrate projected returns on investment that 
are clearly equal to or better than alternative uses of available 
public resources, 

* institute performance measures and management processes that monitor 
actual performance and compare it to planned results, and: 

* establish oversight mechanisms that require periodic review of 
operational capital assets to determine if mission requirements have 
changed and whether the assets continue to fulfill those requirements 
and deliver their intended benefits. Offers Benefits, but Cumbersome Registration Requirements 
and Uneven System Performance Burden Applicants and Create Potential 
for Late Submissions: offers benefits to grantees and grantor agencies alike. 
Grantees and grantor agencies reported the benefits of the "Find" 
feature, noting that a single, searchable source for all federal grants 
makes it easier to find grant opportunities, especially for similar 
activities offered by different agencies. Grantor agencies also 
reported that the find feature allows them to reach a larger, more 
diverse pool of applicants than before. 

The "Apply" feature of allows applicants to avoid some steps 
necessary for paper applications, such as making multiple photocopies. 
Some grantor agencies report that eliminates the need to 
develop an agency-specific electronic system or allows them to process 
applications more quickly because they no longer need to manually enter 
application data. Use of the "apply" feature has grown 
considerably since October 2003. Of the 489,252 total submissions 
received between October 2003 and September 2008, more than three 
quarters were processed in fiscal years 2007 and 2008.[Footnote 28] 
Sixty-four percent (47) of the 74 grantor agencies responding to our 
survey--including the National Institutes of Health (NIH), the agency 
with the largest number of submissions (see table 1)--said 
they require the use of for most to all of their 
applications.[Footnote 29] 

Table 1: Top 10 Grantor Agencies by Submissions, Fiscal Year 

Grantor agency: National Institutes of Health (HHS); 
Number of submissions: 101,000. 

Grantor agency: Department of Defense; 
Number of submissions: 12,458. 

Grantor agency: Department of Education; 
Number of submissions: 8,861. 

Grantor agency: National Endowment for the Arts; 
Number of submissions: 6,544. 

Grantor agency: National Endowment for the Humanities; 
Number of submissions: 5,481. 

Grantor agency: Health Research Services Agency (HHS); 
Number of submissions: 5,150. 

Grantor agency: Office of Justice Programs (Department of Justice); 
Number of submissions: 4,840. 

Grantor agency: Cooperative State Research, Education and Extension 
Service (U.S. Department of Agriculture); 
Number of submissions: 4,818. 

Grantor agency: U.S. Department of Housing and Urban Development; 
Number of submissions: 4,732. 

Grantor agency: Administration for Children and Families (HHS); 
Number of submissions: 3,892. 

Source: As reported by GAO survey respondents. 

Note: We did not verify the accuracy of reported numbers. 

[End of table] Registration Is Complex and a Common Reason for Late 

Before submitting an application through, grantees must 
first register--a complex and sometimes lengthy process. The GEB 
established the registration process to ensure that only authorized 
applicants apply on behalf of an organization.[Footnote 30] According 
to the PMO, the registration process should take 3 to 5 
business days but can take 2 weeks or more for some applicants. We 
previously reported applicant issues with the registration process in 
July 2006.[Footnote 31] Table 2 highlights key steps and time frames in 
the registration process. 

Table 2: Key Steps and Time Frames in the Organization 
Registration Process: 

Steps: Obtain DUNS number from Dun & Bradstreet (D&B)[A]; 
Estimated time required and considerations: Typically 1 business day; 
* Requires organization information to be submitted to D&B via phone or 

Steps: General Services Administration's (GSA) Central Contractor 
Registration (CCR)[B]; 
Estimated time required and considerations: Typically 1 to 2 business 
days. (Can take 2 weeks or more); 
* Requires DUNS number; 
* Requires an employer identification number (EIN) from the Internal 
Revenue Service (IRS). An EIN must be obtained from IRS if the 
organization does not already have one. It may take 2 to 5 weeks for a 
newly assigned EIN to become active for purposes of registering with 
* Requires CCR to check the organization information provided against 
the IRS data on file; delays could result if there are inconsistencies; 
* Establishes organization's E-Business Point of Contact (POC) who 
creates a unique identification number for the organization called the 
marketing partner identification number (MPIN). Only the E-Business POC 
can authorize individuals to submit for the organizations as authorized 
organization representatives (AOR)[C]. 

Steps: Obtain username and password; 
Estimated time required and considerations: Typically 1 day; 
* Requires DUNS number; 
* Requires complete and active CCR registration; Requires CCR 
registration to be updated annually to be valid; 
* Requires AOR to create profile on, which will serve as the 
electronic signature when submitting grants. 

Steps: Register with to establish an AOR; 
Estimated time required and considerations: Typically 1 day (Can vary 
because it depends on the E-Business POC); 
* E-Business POC receives e-mail from asking him/her to log 
in using MPIN and confirm the AOR; 
* This takes about 24 hours from when the E-Business POC responds to 
the request for authorization. AORs cannot submit an 
application until the E-Business POC responds to with a 
confirmation of their AOR status; 
* advises the AOR to verify that the organization's E-
Business POC has confirmed them as authorized to submit grant 
applications for the organization through 

Source: GAO presentation of and CCR information. 

Notes: See [hyperlink,] 
(accessed as of July 6, 2009) for complete details of the registration 
process and links to the entities described here. 

[A] The federal government uses DUNS numbers, which identify an 
organization, to track how federal grant money is allocated. 

[B] CCR is operated by GSA. 

[C] AORs are the only people who can apply for grants through on behalf of an organization. 

[End of table] 

The PMO and grantor agencies widely acknowledge 
registration delays and strongly advise applicants to allow 2 to 3 
weeks to complete the registration process. In our survey, 37 of the 74 
grantor agencies cited difficulties with the overall registration 
process as one of the top three reasons that applicants gave for late 
applications. Applicants may not realize that, although they can 
download and complete an application without registering, in order to 
upload the application to is, actually submit the 
application--they must register. In contrast, applicants who can e-mail 
or mail paper applications do not need to register with 
before submitting an application.[Footnote 32] Grantee and agency 
officials noted that they only use some of the applicant verification 
information required for registration, such as the DUNS 
number, once an applicant is to receive a grant award. According to HHS 
officials, in January 2009 the PMO recommended to the GEB an 
alternative process that would defer the applicant verification 
activities to the agency level, but the GEB elected to stay with the 
existing registration process. In commenting on a draft of this report, 
OMB officials said that since 2003, OMB has required all grant 
applications, regardless of whether they are submitted through or some other means, to include a DUNS number. Table 3 
describes common reasons for applicants' late submissions. 

Table 3: Top Reasons for Applicants' Late Submissions as Reported by 
Grantor Agencies for Fiscal Years 2007 and 2008: 

Reason for late submission [A,B]: 
Applicant had overall difficulty with the registration process; 
Total responses: 37. 

Reason for late submission [A,B]: 
The system was unresponsive, and the application would not 
Total responses: 37. 

Reason for late submission [A,B]: 
The applicant did not understand error messages generated by; 
Total responses: 20. 

Reason for late submission [A,B]: 
Technical issues with the applicant's computer prevented him or her 
from submitting the application; 
Total responses: 19. 

Reason for late submission [A,B]: 
The applicant was unable to receive timely assistance from the contact center; 
Total responses: 12. 

Reason for late submission [A,B]: 
The DUNS number provided by the applicant could not be verified by; Total responses: 10. 

Reason for late submission [A,B]: The applicant was unable to obtain e- 
Business POC authorization; 
Total responses: 9. 

Reason for late submission [A,B]: 
The applicant claimed that attachments submitted through 
were not transmitted to your organization, resulting in an incomplete 
or untimely application; 
Total responses: 9. 

Reason for late submission [A,B]: 
The applicant did not find the assistance provided by the 
contact center to be useful; 
Total responses: 8. 

Reason for late submission [A,B]: 
The applicant did not realize his or her application was late; 
Total responses: 8. 

Reason for late submission [A,B]: 
The applicant could not identify the organization's e-Business POC; 
Total responses: 4. 

Reason for late submission [A,B]: 
Personal reasons were given for late applications (e.g., death in the 
Total responses: 3. 

Reason for late submission [A,B]: 
The EIN number provided by the applicant could not be verified; 
Total responses: 1. 

Reason for late submission [A,B]: 
Natural Disaster; 
Total responses: 1. 

Reason for late submission [A,B]: 
Total responses: 22. 

Source: As reported by GAO survey respondents. 

[A] We asked survey respondents, "From the following list, what are the 
3 most common reasons given by applicants for submitting late 
applications for the period covering FY07-FY08?" and provided a list of 
15 answers (including an "other" category) from which respondents could 
choose. Total response is the number of grantor agencies that cited 
this as the first, second, or third most common reason for late 
submissions, not the number of times these reasons resulted in late 
applications. Of the 74 survey respondents, 68 cited a first most 
common reason, 66 cited a second most common reason, and 66 cited a 
third most common reason. Percentages of respondents answering the 
question are not provided because a respondent can answer more than one 

[B] Several of the reasons listed are external to the system 
and beyond the control of the PMO. 

[C] "Other" reasons, cited 22 times by 11 grantor agencies, included: 
not applicable (9); no late applications (4); applicant confusion over 
grant submission notice (3); no feedback mechanism from users to 
grantor organization (3); external factors not listed (1); multiple 
factors from list (1); and file too large to submit (1). 

[End of table] System Performance Has Limited Applicants' Ability to Submit 
Timely and Complete Applications and Has Increased Applicant Burden: 

In our July 2006 report and during the course of this review, we 
identified continuing system unresponsiveness and other intermittent 
system problems that at times limited applicants' ability to submit 
timely, complete applications and that increase applicants' burden. As 
shown above in table 3, system unresponsiveness is a top reason that 
survey respondents gave for late applications. This problem primarily 
arises before the deadline for a large grant or on days with numerous 
grant closings, when the number of log-ins increases significantly. As 
the system becomes overtaxed, grantees reported that they were 
experiencing delays with (1) logging-in, (2) uploading 
applications,[Footnote 33] and (3) determining if the upload was 
successful. Applicants noted that they sometimes spend hours or days 
trying to log-in, submit, and confirm receipt of their submissions. In 
an effort to address system slowness, in February 2009 the PMO upgraded 
the system to increase the capacity for simultaneous logins from 300 to 
2000 users, but applicants continued to report problems with 
application submission and logging-in, including after Recovery Act 
grants were posted in March 2009. In mid-April 2009, 
performed another upgrade that allowed applicants to track the status 
of their applications without logging into; this was 
intended to improve overall system performance and the ability to meet 
the demands of Recovery Act submissions. Afterward, reported 
that it successfully received 30,000 applications over an 8-day period 
from April 20 to 27; nearly as many applications as it received during 
March 2009. Still, on April 27, 2009, the closing date of a large NIH 
Recovery Act grant and 28 other grant opportunities,[Footnote 34] the blog[Footnote 35] reported that the system was 
unable to receive applications for about 2 hours.[Footnote 36] Both HHS 
and OMB told us that the problem was quickly identified and corrected, 
and that no applications were excluded as a result of the system 
outage. Further, as a result of the upgrade, the backlog of 
applications to be validated rapidly increased, and it took 5 or more 
days to validate applications; the problem was reported to be resolved 
one week later. 

Other reported intermittent system issues include software version 
incompatibilities, missing and corrupted applications, and unexplained 
error messages. In some cases, such system issues resulted in late or 
incomplete applications or confusion about the status of applications. 

* Software incompatibility. In late 2007 and 2008, 
experienced problems transitioning to a new forms software package. 
Applications prepared using an older version of the software were 
incompatible with the newer version used by and, when 
uploaded, were rejected. For example, in February 2008 a large state 
university's application for an approximately $250,000 grant to provide 
educational assistance to communities in Africa was rejected for this 
reason. The grantee was unable to resubmit the application before the 
application deadline and was unable to compete for the grant. 

* Missing and corrupted attachments. We also identified instances when 
grantees were unaware until after the deadline that attachments to 
their applications were corrupted or not received by the grantor 
agency, again resulting in missed opportunities to compete for grants. 
[Footnote 37] In 2008 two organizations applying for $100,000 to 
$250,000 grants to provide health services in rural communities were 
denied consideration because attachments were not successfully 
transmitted to the grantor agency, and despite evidence that they had 
submitted the attachments with their application. 

* Unexplained error messages. Between July 2008 and January 2009 
applicants received unexplained error messages that left many grantees 
unsure if their applications had been received or not. Applicants were 
left without a "work around" for up to a week at a time as the PMO and the IT contractor sought to understand the cause of 
the error messages. In commenting on a draft of this report, OMB 
officials told us that these problems have not recurred. 

Applicants Experiencing Difficulties Described Contact Center 
Assistance as Mixed: 

The contact center, grantees' primary source of assistance 
with the system, is not always able to help grantees, 
especially during off-peak hours and peak submission periods. The 
contact center can be reached by phone Monday through Friday from 7 
a.m. to 9 p.m., eastern time (except federal holidays) or by e-mail; 
the Web site generally accepts applications 24 hours a day, 
7 days a week. The PMO has encouraged applicants to submit applications 
during off-peak times to limit the strain on system resources. users had mixed views on the quality of the service provided 
by the contact center service; some said it was good while others 
described it as inconsistent. Specifically, some users commented that: 
1) the contact center was unable to solve their problems, 2) the 
contact center incorrectly directed callers to the grantor agency, and 
3) they had difficulty reaching the contact center during peak 
submission periods. 

In April 2009, the start of the Recovery Act peak application period, 
the contact center was especially strained. officials and 
applicants reported very high call volume and long wait times-- 
sometimes 30 minutes or more--because of the large numbers of 
applicants seeking assistance. Although calls may be escalated to PMO 
staff or the IT contractor, given the staff size, this is a limited 
option on high volume days. Fewer than half of the 74 agencies 
responding to our survey have help desks of their own, and those that 
do may have more limited hours that the contact center and 
are not intended to have in-depth knowledge of system 

Delays in reaching the contact center are especially problematic 
because they could hamper an applicant's ability to support a request 
for an appeal. When applicants cannot submit timely applications 
because of technical problems, grantor agencies may request 
the applicant's case number that was given to them by the 
contact center; this helps them to obtain details of the case and 
confirm the technical problem.[Footnote 38] In February and March 2009, 
the overall customer satisfaction rate was 89 percent and 87 percent 
respectively (the target level is 90 percent or greater). From January 
to April 2009 the contact center failed to meet several of its other 
performance goals, such as the percentage of callers responded to 
within 30 seconds (i.e., service level) and the percentage of callers 
abandoning their attempt to reach the contact center (i.e., abandon 
rate).[Footnote 39] In April and May the PMO increased the number of 
phone lines and customer support representatives (CSR), and in May the 
contact center surpassed its goals for all three measures.[Footnote 40] 
Contact center customer satisfaction statistics are not collected on 
callers specifically seeking assistance with the registration process 
or submitting an application. 

Accountability and Responsibility for Performance among the Governance Entities Is Unclear: 

As the day-to-day manager of the Web portal, the 
PMO has primary responsibility for ensuring that the website is 
operating properly and that its customers--applicants and grantor 
agencies--are supported during the submission process. However, we 
found that the PMO has been inconsistent in its efforts to meet these 
responsibilities. Both grantees and grantor agencies stated that the 
PMO is at times slow to identify and address system problems, leaving 
grantees frustrated and uncertain of how to proceed when submitting 
applications. Identifying problems has been challenging for the PMO 
until very recently because system performance has been monitored 
anecdotally; that is, through manual checks and customer complaints. In 
March 2009, the PMO reported the use of new software to examine user 
volume and in early June 2009 installed software to monitor system 

Grantees and grantors also described problems with the adequacy of 
system fixes; in some cases the problem was not fully resolved or new 
problems arose as a direct result of the fix. For example, on the blog in February 2009 the PMO noted that applicants were 
having difficulty when logging in to the system. Shortly thereafter, 
the PMO reported the problem had been resolved; however, several 
grantees commented on the blog that they were still receiving the error 
messages and could not login. In another case, when 
transitioned to a new forms software package to address applicant 
issues with the original software, grantees began to experience 
rejected application submissions for applications completed using the 
new software. The PMO subsequently determined that older versions of 
the forms software were incompatible with the new forms. In addition, 
end users also reported that the system's slowness increased after the 
software change reportedly because the larger file size created when 
using the new software meant that more system resources were needed to 
transfer applications. Some agencies responded to these problems by 
delaying their adoption of the new software or even reverting to forms 
constructed using the old software. lacks performance measures to track important aspects of its 
performance. OMB described as a "cannot fail" system and 
defined failure as system unavailability, poor performance to the point 
of diminished usability, loss of data integrity, or any combination of 
the three.'s only performance measures that address system 
performance are tied to customer satisfaction. Information for these 
metrics is collected from a voluntary on-line survey that "pops up" 
when grantees use In May 2009, the customer satisfaction 
score for the 3,690 respondents surveyed was 53 out of 100.[Footnote 
41] Moreover, customer satisfaction of respondents whose primary reason 
for visiting is to submit an application--the area of in which problems are most likely to occur--is unknown 
because the survey does not specifically measure it. 

Untimely Agency Contributions Have Adversely Affected 

The PMO relies on voluntary contributions from the 26 grant- 
making agencies to operate (see fig. 2); however, agencies do not 
always pay in a timely manner, negatively affecting system performance 
and, according to PMO officials, making it more difficult to plan for 
the future. For example, in December 2008 had received only 
2 percent of agencies' fiscal year 2009 contributions; by the end of 
March 2009--halfway through the fiscal had only 
received 37 percent of their annual contributions. Unable to pay its 
vendors, the PMO developed a system shutdown plan and 
implemented the first step of the plan--it eliminated Web site updates 
and moved all notices to the blog. In February 2009, the PMO said that 
unless it received its unpaid contributions by April 2009, it would be 
unable to renew software licenses and would shut down 
[Footnote 42] In April 2009, OMB notified agencies that absent 
immediate improvements, would be unable to handle the influx 
of Recovery Act grant applications and requested agencies to 
immediately submit any unpaid fiscal year 2009 contributions and to 
provide additional funding to support system improvements.[Footnote 43] 
As of June 26, 2009 the PMO received 88 percent of the total 2009 
contributions and 72 percent of the total requested additional funding. 
According to OMB, reasons for late or nonpayment include internal 
agency issues and congressional limitations on agencies' use of funds 
for E-Government initiatives.[Footnote 44] 

Figure 2: Partner Agency Funding Structure, Fiscal Year 

[Refer to PDF for image: illustration] 

Grants Executive Board: Sets contribution rates based on size of agency 
(Total: $12,985,569). 

OMB: Requested FY 2009 additional contribution for system improvement 
(Total: $6,000,000). 

Extra large agency (based on discretionary grant dollars): 
$1,899,755 per agency (Grants Executive Board); 
($872,931) OMB; 
Partner Agency: HHS. 

Large agency (based on discretionary grant dollars): 
$1,067,885 per agency (Grants Executive Board); 
($493,131) OMB; 
Partner Agencies: DOT, HUD, DoED, USDA. 

Medium agency (based on discretionary grant dollars): 
$517,763 per agency (Grants Executive Board); 
($239,331) OMB; 
Partner Agencies: DOL, USAID, DHS, NSF, EPA, DOD, DOJ, DOE, DOC, NASA, 

Small agency (based on discretionary grant dollars): 
$129,299 per agency (Grants Executive Board); 
($59,931) OMB; 
Partner Agencies: CNCS, VA, IMLS, State, SBA, NEH, NEA. 

Extra small agency (based on discretionary grant dollars): 
$74,596 per agency (Grants Executive Board); 
($34,131) OMB; 
Partner Agencies: SSA, NARA, Treasury. 

Total agency contributions to support PMO operations: $18,985,569. Program Management Office (PMO) applies funding to program. 

Source: GAO presentation of and OMB data. 

Note: The GEB categorizes agencies as extra small, small, medium, 
large, and extra large based on the agency's total discretionary grant 
award dollars. That is, agencies with larger total discretionary grant 
dollars contribute more to, and agencies with smaller total 
grant award dollars contribute less to As the largest grant-
making agency, HHS contributes the most funding. Since fiscal year 
2007, the annual budget has been between about $13 to $13.4 
million. The 26 agencies in figure 2 are the: Department of Health and 
Human Services (HHS), Department of Transportation (DOT), Department of 
Housing and Urban Development (HUD), Department of Education (DoED), 
United States Department of Agriculture (USDA), National Science 
Foundation (NSF), Department of Labor (DoL), Environmental Protection 
Agency (EPA), Department of Commerce (DoC), United States Agency for 
International Development (USAID), Department of Defense (DoD), 
National Aeronautics and Space Administration (NASA), Department of 
Homeland Security (DHS), Department of Justice (DoJ), Department of the 
Interior (DoI), Department of Energy (DoE), Institute of Museum and 
Library Services (IMLS), Corporation for National and Community Service 
(CNCS), Department of State (State), National Endowment for the 
Humanities (NEH), Department of Veterans Affairs (VA), Small Business 
Administration (SBA), National Endowment for the Arts (NEA), Social 
Security Administration (SSA), National Archives and Records 
Administration (NARA), and Department of the Treasury (Treasury). 

[End of figure] 

The GEB selected's funding model after considering several 
different alternatives. OMB staff said that they monitor the funding 
status of all E-Government initiatives and that they ask program 
managers to notify them of any funding issues that could potentially 
affect performance. OMB staff stated that they recognize the challenges 
the PMO faces in compelling agencies to pay on time, but that with 
proper management such risks can be greatly mitigated. They added that 
other E-Government initiatives face similar challenges but still run 
successful systems with higher levels of customer satisfaction, such as 
Business Gateway [hyperlink,] and GovBenefits 

Coordination among Governance Entities Is Inconsistent: 

Given the number of entities with management and oversight 
responsibilities for, clear roles and responsibilities for 
each and coordination among these entities is critical. For example, 
the GEB and HHS's OCIO share responsibility for reviewing and approving 
major changes to, and funding for, the system, but there is 
little evidence that the GEB-approved funding for is 
considered in HHS's review of as an IT investment. In 
accordance with OMB's guidance on Planning, Budgeting, Acquisition, and 
Management of Capital Assets,[Footnote 45] HHS--as the 
managing partner--is to manage as an IT investment through 
HHS's Capital Planning and Investment Control (CPIC) process, which 
includes reviewing and approving's budget and major 
initiatives. However, the annual fiscal year 2008 status 
report--the documentation provided to us by the OCIO as evidence of 
OCIO's CPIC oversight of neither major operating 
changes, such as the GEB-approved July 2008 decision to move to "cloud- 
based computing"[Footnote 46] nor concerns about's fiscal 
difficulties. As early as 2002, noted that concerns about 
lack of timely contributions could hamper's ability to 
complete project milestones but the 2008 status report notes this risk 
as medium, and the status as managed. 

Officials from the PMO and HHS acknowledged that governance 
could be improved; it appears that some progress has been made in this 
area. PMO officials told us that since December 2008 they have had more 
interaction with the OCIO's office and that in March 2009, a former 
OCIO official became the acting program manager. However, an 
official in HHS's Office of Grants (the office responsible for told us that has matured considerably since its 
inception in 2003 and would benefit from a better defined governance 
structure. For example, she noted that HHS's role as managing partner 
is not well-defined and that while more clarity would benefit, the managing partner role should be flexible enough to 
permit it to evolve over time as circumstances change. Others have also 
noted the need to better define the relationship among and 
responsibilities of the governance bodies. For example, in 
the fall of 2008 the National Grants Partnership (NGP) sent specific 
recommendations to the Obama-Biden Transition Team highlighting the 
need to better coordinate the activities of with the policy 
recommendations of the Grants Policy Committee.[Footnote 47] 

There are no written policies or procedures for how the OCIO, the PMO, and the GEB are to work with each other to ensure 
system performance, resulting in confusion about roles, 
responsibilities, and accountability; and concerns about duplication of 
efforts that could hamper short-term efforts to make urgent 
improvements to and longer-term efforts to improve service. 
OMB's March and April 2009 memos to executive branch agencies on 
improving included steps to prevent an impending 
system failure, but these memos did not seek to clarify the roles of 
the various governance entities. The memos also noted that GSA--the 
governmentwide facilitator of E-Government solutions--would work with 
HHS to initiate immediate improvements to the system and 
assist with alternatives for select agencies while also identifying 
longer-term approaches to improve service delivery; this 
resulted in concerns about the future of In commenting on a 
draft of this report, OMB clarified that GSA has taken on a parallel 
effort to conduct a pilot system as a "proof of concept" and is not 
working with HHS on the system or building an active 
alternative system. They further noted that they have clarified GSA's 
role with all parties, including HHS and the GEB, in follow-up 
discussions.[Footnote 48] Finally, OMB said that it is clear to OMB 
that HHS is the entity responsible and accountable for the operation of, and that the PMO and GEB merely support HHS in managing the 

Grantees Continue to Lack Opportunities to Provide Structured Input on 
the System: 

Grantees lack opportunities to provide upfront, structured input on, which limits the ability of governance entities 
to obtain valuable customer input on a system meant, in part, to ease 
applicant burden. GEB bimonthly meetings are closed to the public, and 
the HHS OCIO does not have a forum for obtaining external input on Instead, the GEB and HHS OCIO rely on the PMO to provide 
information on system performance and issues affecting The 
PMO has an Integrated Change Board that considers proposed changes to, but none of its members are grantees.[Footnote 49] The blog and quarterly stakeholder Web casts allow 
limited two-way communication between the PMO and grantees while the blog provides daily information on system status, but 
neither of these provide for regular, systematic grantee input on 
issues such as proposed technical changes, system performance, funding, 
and governance. 

In our 2006 report on grantees' concerns with efforts to streamline 
grants management, we said that some technical issues may 
have been resolved more quickly if communication with grantees had been 
greater and concluded that has no systematic way to get 
grantees' views as it develops and proposes changes.[Footnote 50] 
Grantee associations continue to echo those sentiments and are still 
seeking opportunities to discuss their concerns about For 
example, in March 2009 the Association of American Universities (AAU) 
and the Council on Governmental Relations (COGR) wrote a joint letter 
to OMB requesting a meeting to discuss the need for short-and long-term 
enhancements to, especially in light of anticipated problems 
with Recovery Act applications.[Footnote 51] According to OMB 
officials, OMB and COGR have twice been in contact and are in the 
process of scheduling this meeting. COGR officials and officials from a 
major research university also contacted us and discussed their 
concerns.[Footnote 52] 

The PMO has taken some steps to get the perspective of the grantee 
community. In May 2007, the program manager described plans 
to involve end-users (both grantees and grantors) as changes were made 
to the system[Footnote 53] and noted that the PMO would 
implement these plans once OMB approved the plan and ensured that it 
would comply with the Federal Advisory Committee Act (FACA).[Footnote 
54] In February 2009, the program manager met with officials 
from the Federal Demonstration Project (FDP),[Footnote 55] a grantee 
association representing academic research institutions and others, to 
obtain informal input on issues that FDP constituents encounter with as well as how could be improved. After that 
meeting the program manager confirmed the PMO's intent to create a user 
group that could give systematic, across-the-board input on 
issues. He said that this type of input is important because applicant 
groups have the most exposure to using the system and are often the 
most knowledgeable about what problems exist and how to address them. 
However, he noted that it was difficult to reconcile the goals of 
Public Law 106-107, which calls for input and advice from the applicant 
community, with FACA's requirements for agencies seeking to obtain 
advice and recommendations from nonfederal employees. Both agency and 
OMB officials have described these requirements as restrictive. 

As we have previously reported, federal agencies have a reasonable 
amount of discretion with regard to creating committees, drafting their 
charters, establishing their scope and objectives, classifying the 
committee type, determining what type of advice they are to provide, 
and appointing members to serve on committees. Further, we have said 
that members appointed to advisory committees as representatives--as 
opposed to special government employees--are expected to represent the 
views of relevant stakeholders with an interest in the subject of 
discussion, such as an industry, a union, an environmental 
organization, or other such entity.[Footnote 56] GSA has promulgated 
regulations for federal agencies to follow when implementing FACA. 
[Footnote 57] These regulations explicitly note that groups assembled 
to provide individual advice rather than group consensus (e.g., public 
town hall style meetings or meetings of experts where they are not 
expected to reach consensus but rather share individual opinions and 
advice) are not subject to FACA requirements. 

Disparate Agency Policies for Processing Grant Applications Can Result 
in Different Treatment for Applications Submitted through Various 

Grantor agencies vary in the closing times they set for their grant 
opportunities. While accepts applications until midnight 
eastern time on a grant's closing date, about one-third of the 
responding grantor agencies we surveyed had grant opportunity closing 
times before midnight--often between 4 p.m. and 5 p.m. eastern time. 
[Footnote 58] For example, NIH, the largest grantor agency, has a 5:00 
p.m. local time closing time for all its grants. This presents problems 
for applicants using for two reasons. First, applicants 
could receive confirmation that an application was successfully 
submitted to, but the application can still be deemed late 
by the grantor agency. Second, officials have told 
applicants to submit applications during off-peak hours (i.e., before 
11:00 a.m. and after 8:00 p.m. eastern time) when the system 
is not experiencing overload issues.[Footnote 59] Some agencies 
unofficially provide applicants leeway on meeting the deadline closing 
time. For example, two grantor agencies said that though they do not 
advertise the fact to applicants, they will accept applications that 
arrive by midnight of the deadline date although the official closing 
time is earlier. 

Different closing times across agencies reportedly caused confusion 
among applicants. Several association representatives told us that it 
would ease applicant burden if there were a universal deadline across 
the federal government. Several suggested that agencies should 
coordinate their deadline times with so that it is not 
possible for a late application to be accepted by the 
system. Despite some discussions about this issue by agency 
representatives on the Grants Policy Committee--which has 
responsibility for recommending standard and streamlined federal-to- 
grantee business processes--it has been unable to come to agreement on 
a standard governmentwide closing time. Several of the agency officials 
we spoke with stated that there is no technical reason why a standard 
closing time could not be set. 

Agencies Have Different Policies for Determining the Timeliness and 
Completeness of Applications: 

Agency policies vary in determining whether applications submitted 
through are timely and complete. This sometimes results in 
applications' being deemed late or incomplete, even though an applicant 
may receive confirmation from that the application was 
successfully submitted. These policies may not apply to applications 
submitted outside of 

* Timeliness. Of the 74 grantor agencies responding to our survey, more 
than 60 percent (47) said that they determine whether an application is 
timely based on the time the application was submitted to; 
16 percent (12) said they determine whether an application is timely 
based on the time the application was validated by[Footnote 
60] However, validations can take up to 48 hours after an application 
is successfully submitted and on some occasions may take longer; 
[Footnote 61] this has resulted in late submissions.[Footnote 62] For 
example, in 2006 a university whose application failed the validation 
process was unable to resubmit the application before the deadline and 
lost about $1 million in grant funding. As a result, the university was 
unable to continue a program serving over 200 inner-city youth that it 
had administered for 12 years. In contrast, applications submitted by e-
mail or mailed in hard copy are not subject to validation. 
Instead, agencies use other means to establish the timeliness of these 
submissions. For example, the postmark[Footnote 63] or the arrival date 
is often used to determine the timeliness of paper applications. 

* Completeness. Some agencies require applicants to submit attachments 
to the grant application in a particular file format; however, the system cannot determine whether an application is in the 
correct format or as discussed earlier, if attachments are properly 
transmitted to the agency. For example, NIH requires applicants to 
submit attachments in Pure Edge or Adobe PDF file formats, and cautions 
applicants that other file formats are not acceptable, even though appears to accept these other formats. The National Science 
Foundation (NSF) may also reject applications if the attachments are 
not in certain file formats. Applicants submitting paper applications 
do not have to be concerned about file formats or transmission 
problems. Association representatives told us that requiring different 
file formats is burdensome for applicants. 

Agencies Differ in Notifying Applicants When and Whether Applications 
Have Been Successfully Submitted through 

Although the system notifies applicants via e-mail when 
their applications have been accepted or rejected, there are no common 
requirements for grantor agencies to notify applicants whether they 
consider the applications to be timely and complete. More than half of 
the agencies responding to our survey (39 respondents) said they notify 
an applicant "immediately or almost immediately" when an application is 
late and will not be forwarded for content review. Forty agencies said 
that when an application had "missing elements," they notified 
applicants "immediately or almost immediately." For example, EPA's 
grant submission policies state that an applicant must be informed that 
their application was rejected because of "a failure to meet the 
eligibility threshold" within 15 calendar days of receipt by the 
agency. According to EPA officials, 15 days is very early in the grant 
processing cycle, thus providing applicants sufficient time to appeal. 
In contrast, 13 respondents said that when an application is late they 
either wait until the time that the grant is awarded to notify 
applicants or do not notify applicants at all. Fourteen respondents 
said that when an application has "missing elements" they either do not 
notify applicants about incomplete applications or wait until the 
rejection letter goes out.[Footnote 64] Lack of notice, or untimely 
notice, can eliminate an applicant's chance to appeal a late or 
incomplete determination. 

Further, an applicant's ability to determine the timeliness and 
completeness of an application varies depending on how the application 
was submitted. For example, applicants who mail hard copies of 
applications know what they put into the envelope--and what it looks 
like--and can choose to track their applications through the U.S. 
Postal Service (USPS) or commercial delivery service. Conversely, 
applicants who submit their applications via e-mail or an electronic 
system have no way of knowing if their applications were successfully 
submitted unless the grantor agencies or electronic systems notify 
them. In addition, these applicants may be unable to determine if the 
entire contents of their application, including necessary attachments, 
were successfully submitted without corruption. 

Agencies Have Different Criteria for Considering Appeals, Sometimes Not 
Considering the Most Common Reason for Late Submissions: 

If a grantor agency determines that an application is late or 
incomplete, applicants can often appeal this determination; however, 
the criteria agencies use to determine whether they will consider an 
appeal vary. Our survey results and interviews indicate that being 
unable to register with is one of the most common problems 
experienced by applicants. However, more than half of the 23 survey 
respondents who provided data about appeals based on registration 
difficulties said that appeals on this basis were more likely to be 
denied than approved. In one case, an applicant provided evidence that 
he worked with the contact center to resolve a registration 
problem before the submission deadline, but as he was unable to 
register in time, this was not allowable grounds for appeal for a late 
application. On the other hand, most of the 27 survey respondents who 
provided data on appeals based on technical issues with, 
such as system slowness or unresponsiveness, said that these appeals 
were approved most to all of the time. For applications deemed 
incomplete, 50 of the 74 grantor agencies that responded to our survey 
said that an applicant can dispute or appeal at least some of the time 
if a submission is determined to be incomplete. Some of these agencies 
allow applicants to provide the missing information after the deadline, 
if that information is required solely for processing the application 
and will not affect the substantive content of the application. In 
contrast, 16 agencies said that applicants cannot appeal incomplete 
applications and that these applications will not be included during 
the competitive process.[Footnote 65] 

Agencies Vary in the Extent to Which They Assist Applicants Facing 
Difficulties when Submitting through 

In response to the recurring difficulties with the system, 
some agencies have made efforts to assist applicants by 
adjusting their policies on: 1) submission methods, 2) deadline grace 
periods, and 3) appeals processes. 

* Submission methods. Of the 74 agencies responding to our survey, 47 
normally require their grantees to use to apply for most to 
all grants. However, more than half of our respondents will accept 
applications through agency specific electronic systems, by e-mail, or 
mail, under at least some circumstances, such as when is 
experiencing system problems.[Footnote 66] One grantor agency began 
requiring all applicants to submit a hardcopy of their application in 
addition to applying through to avoid system delays and 
other problems. 

* Deadline grace periods. Some grantor agencies reject applications 
with a timestamp that is one second after the announced deadline; 
others have instituted a grace period. For example, the U.S. Department 
of Housing and Urban Development (HUD) officials told us that for 
fiscal year 2009 they implemented a one-day grace period for applicants 
who submit on time but fail the validation process; this 
allows applicants time to resubmit their applications. NIH has also 
instituted policies to accommodate applicants who encounter technical 
problems with, even if the process of resolving the 
technical issue extends past the due date. 

* Appeals processes. Some agencies have also instituted formal appeals 
processes to specifically accommodate system issues. HUD 
established a "quality assurance review" process, published in the 
Federal Register, which states that applications submitted by grantees 
who followed all of the application procedures and were unable to apply 
successfully through because of unanticipated technical 
problems, the forms software package, or error messages will 
be considered.[Footnote 67] NIH set up a system to hear and resolve 
complaints and appeals well before awards are made. 

Grantees Continue to Lack a Means for Structured Input into 
Governmentwide Grant Application Policies: 

In a July 2006 report, we concluded that action was still needed to 
ensure that grantees have adequate input early in developing solutions 
on grants streamlining, and recommended that the Grants Policy 
Committee and the GEB develop and implement approaches to soliciting 
grantee input on an ongoing basis. As of October 2008, the Grants 
Policy Committee said they were considering how to involve the grantee 
community as policies are being developed. During our current review, 
grantee associations continued to express the need for early input into 
policies that could help streamline and standardize grants policies 
governmentwide, such as those mentioned in this report, in order to 
improve the grant application experience for applicants and reduce 
applicant burden. 


The Recovery Act has highlighted the importance of in 
ensuring the flow of grant funds to struggling communities and 
organizations around the country. Over the past several months, OMB and 
the staff worked quickly to mitigate an impending system 
failure in the short-term. As the governance entities begin 
to consider longer-term improvements to, now is the time to 
reconsider whether's performance measurement efforts, its 
management structure, the current ad-hoc methods for obtaining 
stakeholder input, and disparate agency policies for processing grant 
applications will help or hinder Public Law 106-107's goals of 
simplifying and streamlining grant administration.'s performance measures do not provide a clear picture of 
system performance or how well applicants are being served. Absent 
measures that track the health of the system against OMB's definition 
of system failure, gaps in performance information will persist. 
However, collecting performance information is not enough; unless this 
information is used to inform decision making, the 
governance bodies will lack a valuable management tool for developing 
strategies to better achieve results. 

GEB provides strategic direction and oversight, while HHS, as managing 
partner, is expected to take the necessary steps to resolve concerns 
and issues raised at GEB meetings. However, inconsistent coordination, 
unclear lines of authority, and confusion over roles and 
responsibilities have contributed to system unreliability at critical 
points in the application submission process and, if not addressed, 
could threaten distribution of Recovery Act grants in the short-term 
and risk the system's long-term performance. Finally, until HHS better 
links its review of as an IT investment with the GEB's 
review and approval of's budget and funding mechanism, HHS 
will have difficulty weighing the relative costs and benefits of and lack assurances that adequate funding is in place to 
support the level of capital investment desired. 

As managing partner for, HHS continues to lack a systematic 
way to obtain grantees' views on proposed changes to the 
system; the Grants Policy Committee continues to lack such a mechanism 
as it implements policies to streamline federal-to-grantee business 
processes. If grantees remain isolated from the development of systems 
and policies that directly affect them, the systems and policies will 
be less effective, and opportunities to better streamline the 
application process will be missed. 

Finally, inconsistent agency policies relating to, for example, 
application deadlines and notifications both increase applicant burden 
and, in some cases, disadvantage applicants who submit applications 
through as compared to applicants who submit applications 
using other electronic systems, e-mail, the USPS, or a commercial 
delivery service. Further, some agencies do not recognize 
registration issues and technical issues such as system 
unresponsiveness--problems identified by our survey respondents as 
among the most common causes of late applications--as a valid basis for 
appeal. On the other hand, some agencies have successfully modified 
their policies to reflect these types of applicant challenges; these 
efforts could be a starting point for considering consistent, 
governmentwide policies in these areas and could assist the Grants 
Policy Committee in its efforts to develop policy proposals for 
streamlining and simplifying the pre-award stage of the grants life 

Recommendations for Executive Action: 

We are making the following four recommendations to the Director of OMB 
to increase the effectiveness and long-term viability of 

* OMB should (1) work with HHS to develop performance measures related 
to system availability, usability, and data integrity and (2) direct 
HHS and the PMO to review performance results on a regular 
and recurring basis and communicate decisions based on performance 
information to show that performance information is reviewed and acted 

* OMB should work with HHS to develop guidance that: 

- ensures that the budget and funding model adopted by the 
GEB adequately supports the package of IT services approved 
through the HHS CPIC process; 

- clearly defines the roles and responsibilities of the GEB, HHS OCIO, 
and PMO with respect to, including how these 
entities are to coordinate with each other to resolve system 
issues; and: 

- addresses GSA's role and specific responsibilities in developing 
approaches for longer-term solutions. 

* OMB should work with HHS and other stakeholders as appropriate to 
identify and implement a "applicant user group" or other 
systematic, periodic approaches for obtaining grantees' input on 
changes and improvements to system. 

* OMB should work with HHS, the Grants Policy Committee, and other 
stakeholders as appropriate to identify and implement, to the extent 
permissible by law, governmentwide policies for processing grant 
applications, with the goals of minimizing applicant confusion and 
burden and creating a level playing field for all application 
submissions, no matter the submission method. These policies could 

- criteria for what constitutes a timely and complete application; 

- notifications grantor agencies provide applicants when an application 
has been received or been deemed late or incomplete; 

- criteria for granting appeals for applications deemed late or 
incomplete; and: 

- the registration process. 

In doing so, OMB should also ensure that grantees have a structured, 
ongoing means to provide input on the development and implementation of 
governmentwide grant application policies and procedures such as those 
mentioned above. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Director of the Office of 
Management and Budget and the Secretary of the Department of Health and 
Human Services. OMB staff provided us oral comments and generally 
agreed with our overall findings and recommendations. OMB staff stated 
that it is the responsibility of HHS as the managing partner agency to 
manage system requirements and development for, and that the 
PMO, GEB, and Grants Policy Committee are merely resources that HHS 
uses to assist it with its management responsibility. Given where is in its useful life cycle, OMB staff said that they do not 
foresee any system changes beyond those needed to keep the system 
stable and operational, and that should be in an operations 
and maintenance mode until requirements for a new system are developed. 
OMB staff also provided technical comments that were incorporated as 

In written comments, the HHS Acting Assistant Secretary for Legislation 
concurred with our overall findings and recommendations and suggested 
additions to our recommendation on governmentwide grant policies; we 
agree with HHS and clarified our fourth recommendation. HHS's written 
comments are reprinted in appendix II. Key comments include that 
"systemic issues remain regarding standardization of grants application 
policies and procedures across the federal government and the governance and funding model" and "the system 
funding model is institutionally biased against investing adequate 
resources in system improvements and could benefit from review." In 
addition, HHS provided an update on activities since April 
2009 and said that operations have been essentially normal since that 
time, with NIH receiving more applications per hour than ever before 
through Technical comments and suggested edits were 
incorporated where appropriate. 

We are sending copies of this report to the Director of the Office of 
Management and Budget, the Secretary of Health and Human Services, and 
other interested parties. The report also is available at no charge on 
the GAO Web site at [hyperlink,]. 

If you or your staff have any questions regarding this report, please 
contact me at (202) 512-6806 or by e-mail at 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. Major 
contributors to this report are listed in Appendix III. 

Signed by: 

Stanley J. Czerwinski: 
Strategic Issues: 

[End of section] 

Appendix I: Detailed Survey Description: 

We conducted a Web-based survey of federal grant-making agency 
officials to obtain information on 1) agency policies and practices 
with respect to competitive grant application submissions, and 2) 
agency experiences assisting grant applicants who have had problems 
while using Our background research indicated that agency 
officials are knowledgeable about agency grant application policies and 
have experience assisting grantees who are trying to submit 
applications through We did not survey grantees because of 
the difficulty and resources needed to identify and sample the 
thousands of grantees who have submitted or attempted to submit 
applications using 

To design the survey, we reviewed documentation from the PMO 
and grant-making agencies and interviewed agency grant officials to 
gain an understanding of 1) agency grant application policies and 
procedures and 2) their knowledge of applicant experiences using We worked with a social science survey specialist to design 
a draft survey instrument and then pre-tested the instrument with five 
grant-officials from five different agencies to ensure that the 
questions were clear and unbiased and that the survey could be 
completed in a reasonable amount of time. We made revisions to the 
survey instrument in response to each of the pre-tests and presented a 
final draft to the Grants Executive Board (GEB) members for expert 
review; they suggested minor changes that were incorporated. 

To identify the population of federal "grantor agencies" to survey, we 
asked the 26 members of the GEB to identify all organizations within 
their agency that have established distinct grant application policies 
for competitive, discretionary grants and to provide us a contact 
person within the grantor agency who would be responsible for 
responding to the survey. This was necessary because policies for 
processing grant applications can be centralized at the agency level or 
can differ within an agency by subagency or program office. With 
knowledge of a particular agency, the 26 GEB members (or their 
designees) provided us contact information for officials from 86 
grantor agencies, and the survey was provided to those individuals 
during the first week of December 2008. During December 2008 and 
January 2009, we sent three e-mail reminders to and in some cases 
telephoned nonrespondents, asking them to complete the survey. We 
eliminated six of the respondents from the population after discussions 
led us to determine that 1) their grantor agency does not offer 
competitive, discretionary grants or 2) we had received contact 
information for multiple respondents from the same grantor agency. The 
final population of 80 respondents represents the universe of grantor 
agencies with distinct grant application policies. When the survey 
closed on January 29, 2009, we had received responses from 74 of the 80 
grantor agencies that offer competitive grants for a response rate of 
92.5 percent. 

Data analysis of the survey was conducted by a GAO data analyst working 
directly with the GAO staff with subject matter expertise. Since this 
was a Web-based survey, respondents entered their answers directly into 
the electronic questionnaire, eliminating the need to key data into a 
database, minimizing error. When the data were analyzed, a second 
independent data analyst checked all computer programs for accuracy. 
Because this was not a sample survey, it has no sampling errors. 
However, the practical difficulties of conducting any survey may 
introduce errors, commonly referred to as nonsampling errors. For 
example, difficulties in interpreting a particular question, sources of 
information available to respondents, or entering data into a database 
or analyzing them can introduce unwanted variability into the survey 
results. We took steps in developing the questionnaire, collecting the 
data, and analyzing them to minimize such nonsampling errors. It should 
be noted that some grantor agencies' policies on the allowable methods 
for submitting applications currently differ from their original survey 
responses because of OMB's memo of March 9, 2009, instructing agencies 
to identify alternatives to for accepting grant applications 
during the Recovery Act's peak filing period, estimated by OMB to be 
April through August 2009. 

[End of section] 

Appendix II: Comments from the Department of Health and Human Services: 

Department Of Health and Human Services: 
Office Of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

June 16, 2009: 

Stanley J. Czerwinski: 
Director, Strategic Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear. Mr. Czerwinski: 

Enclosed are the Department's comments on the U.S. Government 
Accountability Office's draft report entitled, "Grants Management: Has Systemic Weaknesses That Require Attention" (GAO-09-

The Department appreciates the opportunity to comment on this draft 
report before its publication. 


Signed by: 

Barbara Pisaro Clark: 
Acting Assistant Secretary for Legislation: 


[End of letter] 

Comments Of The U.S. Department Of Health And Human Services To The 
Government Accountability Office's (GAO) Draft Report Entitled. "Grants 
Management: Grants.Gov Has Systemic Weaknesses That Require Attention" 

HHS concurs with the overall findings and recommendations of the draft 
GAO Report. 

Update on Activities since April 2009: 

While the Report accurately reflects many of the performance problems 
faced by users of through early 2009, HHS has devoted 
tireless attention to the systemic weaknesses highlighted in the report 
to dramatic effect. Interim improvements to enhance system performance 
enabled to successfully handle the largest grant opportunity 
related to ARRA, NIH's Challenge Grant; receiving over 30,000 
applications in an 8-day period in April; including 8,400 applications 
on April 27-alone. Although the GAO report accurately notes there was a 
short two hour period at the end of the day in which applications could 
not be received by the system, the problem was quickly 
identified and corrected, and no grantee applications were excluded due 
to the system outage. Operations have been essentially normal since 
that time. HHS is currently beginning implementation of a 60-day 
"boost" initiative that will further stabilize the system 
and increase its reliability and ability to sustain expected grant 
activity into the future. 

Summary of Key Comments: 

Page 24 and Page 31, Item 1: HHS believes that systemic issues remain 
regarding standardization of grants application policy and procedures 
across the Federal government and the governance and funding 
model. HHS concurs with GAO that it is important to develop a standard 
protocol for Federal grantors "accepting" grantee applications, and 
recommends establishing a standard process and approach for submitting 
grant applications which takes advantage of current technology and 
minimizes the number of different forms required. The multiplicity of 
application forms contributes to difficulty in defining system 
requirements, optimizing the capacity of the system, and running an 
efficient operations and maintenance program. 

Page 32, Item 2a: Additionally, HHS observes that the system 
funding model, which requires devoting considerable resources 
throughout the entire fiscal year to collect annual funding 
contributions from 26 agencies, is institutionally biased against 
investing adequate resources in system improvements and could benefit 
from a review. One alternative could be a more established source of 
funding such as an annual appropriation in order to avoid the perpetual 
financial challenges associated with maintaining and upgrading this 
vital government-wide system. 

HHS offers the following specific comments and edits for your 
consideration: Registration is Complex and a Common Reason for Late 

Page 11, Table 2: Registration delays are acknowledged and are due to 
the current mandate from the Grants Executive Board (GEB) to have the system verify the responsibility and authority of the 
applicant to submit an application at the time an application is 
submitted rather than later in the process (the pre-award stage). In 
January 2009, the Program Management Office (PMO) 
recommended to the GEB an alternative process that would defer the 
applicant verification activities to the agency level versus the system level. The GEB elected to stay with the existing 
registration process. 

Reason for Late Submission: 

Page 12, Table 3: HHS recommends that GAO clarify that the reasons 
listed in Rows 4, 7, 10, 11, 12 and 14 on why prospective grantees 
submit late applications, are external to the PMO and the 
system and outside the scope of its control. 

Accountability and Responsibility for Performance among the Governance Entities is Unclear: 

Page 17, 2nd paragraph: HHS recommends that GAO update its text to 
indicate that following a year long transition, in March 2009, the PMO decommissioned the system/servers using the original 
forms software, "PureEdge," therefore future issues of this nature are 

Section on "Coordination among Governance Entities" 

Page 20: While HHS believes that its current Capital Planning and 
Investment Control (CPIC) process is designed to ensure that 
is required to meet the same accountability and reporting requirements 
as enterprise HHS IT investments, HHS would agree that it is important 
to continue to enhance internal coordination within the Department. 

Recommendations for Executive Action: 

Page 31, Item 1: One additional suggestion would be that the Executive 
Branch should work with governance entities and policy 
makers to streamline/standardize grant application processes, reduce 
the number of electronic forms used by prospective grantees, and 
identify concrete, functional system requirements that reflect user 
needs and take advantage of current technological advances. 

Technical Comments Page 12, line 7: 

..."complete the application process" should be changed to "actually 
submit the application". For NIH, submission to does not 
complete the application process. 

Page 14, end of first paragraph: 

It is worth mentioning that the built the weekend after the 
April 27 deadline took care of the problem with slow application 
processing. NIH is receiving more applications per hour than ever 
before from 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Stanley J. Czerwinski (202) 512-6806 or 


In addition to the contact named above, Thomas James, Assistant 
Director; Jacqueline M. Nowicki, Assistant Director; and Jennifer 
Ashford managed this assignment. Carolyn Boyce, James J. Burns, David 
Fox, Carol Patey, and James R. Sweetman, Jr., made major contributions. 
Cynthia Grant and Luann Moy provided methodological assistance; Shirley 
Jones provided legal assistance; and Donna Miller developed the 
report's graphics. 

[End of section] 


[1] [hyperlink,]. 

[2] Pub. L. No. 111-5 (Feb. 17, 2009). Recovery Act funds are being 
distributed to states, localities, other entities, and individuals 
through a combination of formula and competitive grants and direct 
assistance. Nearly half of the approximately $580 billion associated 
with Recovery Act spending programs will flow to states and localities 
affecting about 50 state formula and discretionary grants as well as 
about 15 entitlement and other countercyclical programs. For Recovery 
Act grant opportunity postings, see [hyperlink,] (accessed as of July 6, 

[3] Office of Management and Budget, Recovery Act Implementation-- 
Improving and Other Critical Systems, M-09-14 (Washington, 
D.C.: Mar. 9, 2009). For other OMB guidance related to, see 
Office of Management and Budget, Improving, M-09-17 
(Washington, D.C.: Apr. 8, 2009). 

[4] Alternative methods for applying include agency-specific electronic 
systems (i.e., electronic systems run by a grantor 
agency), e-mail, fax, and mail. 

[5] GAO, Recovery Act: Consistent Policies Needed to Ensure Equal 
Consideration of Grant Applications, [hyperlink,] (Washington, D.C.: Apr. 29, 

[6] OMB estimated the peak filing period to be April to August 2009. 

[7] The PMO is in charge of the day-to-day management of HHS is the designated managing partner of and 
has lead responsibility for the initiative. The GEB consists of 
representatives from the 26 grant-making agencies and provides 
strategic leadership and resources to The Grants Policy 
Committee coordinates all federal grants policy recommendations to OMB. 
OMB provides oversight and guidance to and the other 23 E- 
Government initiatives. 

[8] We worked with officials from the 26 grant-making agencies to 
determine if policies on submitting and reviewing grant applications 
are centralized at the agency level or if they differ within an agency 
by subagency or program office. We then administered the survey at the 
level where policies are established in order to capture differences 
among and within the 26 grant-making agencies. We identified 80 
"grantor agencies" that have distinctive grant application policies. 

[9] The 74 responses we received were from all of the 26 grant-making 

[10] Pub. L. No. 106-107 (Nov. 20, 1999). Although we focus on grants 
and cooperative agreements in this report, the law covers all types of 
federal financial assistance. 

[11] GAO, Grants Management: Additional Actions Needed to Streamline 
and Simplify Processes, [hyperlink,] (Washington, D.C.: Apr. 18, 
2005) and GAO, Grants Management: Grantees' Concerns with Efforts to 
Streamline and Simplify Processes, [hyperlink,] (Washington, D.C.: July 28, 

[12] Office of Management and Budget, E-Government Strategy 
(Washington, D.C.: Feb. 27, 2002). 

[13] The five stages of the grant life cycle are: 1) announcement (pre- 
award), 2) application (pre-award), 3) award, 4) postaward, and 5) 

[14] OMB requires agencies to announce all discretionary grants 
opportunities on; although agencies may apply for waivers 
from OMB. OMB does not require agencies to accept applications through 

[15] Applications must be downloaded to the applicant's computer, 
completed, and uploaded to the system. Applicants are not 
required to be connected to the Internet when completing applications. 

[16] The validation process is not designed to verify any 
agency-specific or grant-specific requirements; as such, an application 
that was validated by could be forwarded to the agency and 
still fail to meet criteria specified in a grant's application 

[17] Projects on OMB's IT High Risk List are not necessarily at risk of 
failure; rather, because they meet certain criteria specified by OMB, 
they are to receive special attention from oversight authorities and 
the highest levels of agency management. "Program or program management 
office activities supporting governmentwide common solutions" is one 
criterion, as is "major systems formally designated as an E-Government 
or Line of Business shared service provider." 

[18] In addition, four other portfolios were designated: government-to- 
citizen, government-to-business, internal efficiency and effectiveness, 
and cross-cutting. Each portfolio had a manager and each of the 
initiatives was included under one of the five portfolios. 

[19] GAO, Electronic Government: Funding of the Office of Management 
and Budget's Initiatives, GAO-05-420 (Washington, D.C.: Apr. 25, 2005). 

[20] Some agencies use agency-specific grant application forms; the PMO 
is not responsible for managing the process to update these forms. 

[21] The CFO Council--the CFOs and Deputy CFOs (DCFO) of the largest 
federal agencies and senior officials of the Office of Management and 
Budget and the Department of the Treasury--work collaboratively to 
improve financial management in the U.S. Government. 

[22] See [hyperlink,] (accessed July 
6, 2009). 

[23] Pub. L. No. 107-347, Dec. 17, 2002, codified at 44 U.S.C. §§ 

[24] Pub. L. No. 104-106, Division E, Feb. 10, 1996, codified at 40 
U.S.C. §§ 11101-11704. 

[25] 40 U.S.C. §§ 11312 - 11313. 

[26] 40 U.S.C. §§ 11302 - 11303. 

[27] This policy is set forth in OMB Circular A-11 (section 300) and in 
OMB's Capital Programming Guide (supplement to Part 7 of Circular A- 

[28] processed 180,861 submissions in fiscal year 2007 and 
202,366 submissions in fiscal year 2008. 

[29] On March 9, 2009, OMB instructed federal grant-making agencies to 
identify alternate methods for accepting grant applications during the 
Recovery Act peak filing period, which is estimated to last from April 
through August 2009. 

[30] Applicants applying as individuals (not as part of an 
organization) must also register with before applying for 
grants but follow different procedures to register and then can only 
apply for grants open to individuals. In our survey, 32 percent (24) of 
the 74 respondents stated that they offer grants to individuals. 

[31] See [hyperlink,], p. 19-21. 
This report discusses grantee difficulties with multiple Data Universal 
Numbering System (DUNS) numbers, the Central Contractor Registration 
process, and the time it takes to complete the registration process. 

[32] In our survey, 20 of 74 grantor agencies (27 percent) reported 
that they always allow paper applications and 32 of 74 grantor agencies 
(43 percent) have accepted e-mailed applications. 

[33] The submission process differs from web-based 
applications, which are completed and saved while the applicant is 
connected to the Internet and do not have to be uploaded. 

[34] reports that on April 27th it processed 8,392 
applications. At that time, this was the largest one day submission 
total for the system, surpassing the April 24th record high of 5,973. 

[35] The PMO runs a blog that reports at least daily on 
system performance. See [hyperlink,] 
(accessed as of July 6, 2009.) 

[36] On April 27, 2009, at 10:55 p.m. on the blog, the PMO 
reported, "at approximately 7:45pm, April 27th, the portion of the 
Grants.Gov system that manages the intake of new applications suffered 
technical difficulties due to the unprecedented number of new 
applications received today. The immediate result was that users could 
not submit grant applications through for about a two-hour 
period from 7:45 pm to 9:45 pm EST (Eastern Standard Time). Grant 
opportunity search capability, and processing of applications that had 
already been submitted before the failure, continued to function 

[37] Although sends e-mail communications to applicants 
notifying them when their application is "validated" and transmitted to 
the grantor agency, applicants have no way of knowing the contents or 
condition of the documents received by the agency. 

[38] When an applicant calls the contact center, the customer service 
representative assigns a case number and attempts to resolve callers' 
issues. A grantor agency can use the case number to obtain the case 
notes from the PMO. 

[39] During that time frame, the contact center's service level ranged 
between 26 and 72 percent (the target level is 85 percent or higher). 
The abandon rate ranged between 6 and 29 percent (the target level is 
less than 5 percent). 

[40] The overall satisfaction rate in May 2009 was 92 percent, the 
service level was 88 percent, and the abandon rate was 2 percent. 

[41] The customer satisfaction score averaged around 55 out of 100 from 
April 2008 to January 2009, but has been between 50 and 53 since then. 
The score does not represent the percentage of Web site visitors who 
were satisfied; rather, it is an index that is derived from multi-item 
satisfaction questions and weightings that are designed to maximize 
causation between the drivers of satisfaction and satisfaction 

[42] By April, the PMO received a sufficient amount of agency 
contributions to renew the licenses. 

[43] Office of Management and Budget, Improving M-09-17 
(Apr. 8, 2009). 

[44] For example, since Fiscal Year 2006 agencies may not make funds 
available for OMB's E-Government initiatives until 15 days after OMB 
submits an E-Government funding report to the House and Senate 
appropriations committees and until the committees approve the 
availability of these funds. OMB officials told us that they generally 
submit this report to Congress after the first quarter of each fiscal 
year. Also, at least one agency has, in some years, not paid its contributions because its appropriations subcommittee 
directed it not to. 

[45] OMB Circular A-11, Part 7. 

[46] "Cloud computing" refers to an arrangement in which an 
organization pays a service provider to deliver IT applications, 
computing power, and storage via the Internet. For, a change 
to "cloud computing" means outsourcing its IT system, including 
hardware and related software, and having its IT services managed and 
delivered from a Web-based platform rather than owning them and having 
them managed by an in-house contractor as it currently does. Cloud 
computing would still require the PMO to manage the system 
through a contractor and applicants would still upload submissions to 
the system. 

[47] See National Grants Partnership, Presidential Transition Report 
(Washington, D.C.: November 2008). The NGP was established in 2004 to 
bring together government and non-government individuals with an 
interest in improving the grants process in the United States. 

[48] OMB also noted that GSA, through the Integrated Acquisition 
Environment has been working steadily with the PMO to ensure 
that the system includes the current and correct information from the 
Catalog of Federal Domestic Assistance. GSA manages this catalog for 

[49] In a comment on the blog one user suggested the use of a change 
control board composed of key stakeholders in agencies and grantee 
organizations as a structured way to provide input to 

[50] [hyperlink,]. 

[51] See [hyperlink,] (accessed 
July 6, 2009). AAU is a nonprofit organization of 62 leading public and 
private research universities in the U.S. and Canada; COGR is an 
association of more than 175 U.S. research universities and their 
affiliated academic medical centers and research institutes. 

[52] The NGP also noted the lack of non-federal representation on the 
Policy Committee. See NGP, Presidential Transition Report. 

[53] The program manager at the time told us that there were 
plans in the works to create a team consisting of 10 representatives 
reflective of the end user community, including states, not-for- 
profits, research entities, housing entities, tribal organizations, 
educational entities, local government, and large, medium, and small 
federal agencies. The group was meant to address the issues we raised 
in our 2006 report on grants streamlining, specifically, to solicit the 
assistance of the grant community and to build in end user acceptance 
of system changes. 

[54] FACA, 5 U.S.C. Appx §§ 1-15, imposes a number of requirements on 
committees or similar groups of nonfederal employees that are 
established or utilized by the President or federal agencies in the 
interest of obtaining advice or recommendations, such as: filing a 
charter, advance notice of public meetings, keeping meeting minutes, 
and public availability of records. 

[55] FDP is an association of federal agencies, academic research 
institutions with administrative, faculty and technical representation, 
and research policy organizations that work to streamline the 
administration of federally sponsored research. 

[56] GAO, Federal Advisory Committee Act: Issues Related to the 
Independence and Balance of Advisory Committees, [hyperlink,] (Washington, D.C.: Apr. 2, 

[57] 41 C.F.R. §102-3.40. 

[58] officials told us that in rare cases application 
deadline times are written into a grant's authorizing legislation. 

[59] For example, on April 6, 2009, a day on which received 
an exceptionally large number of submissions, almost one-third of the 
3,555 applications received were submitted between 3:00 p.m. and 6:00 
p.m. eastern time. 

[60] Six respondents said that they used another indicator to determine 
timeliness, and nine did not answer the question. 

[61] For example, before a large closing day in late April 2009 
validations were taking up to 5 days. 

[62] Although it was beyond the scope of our work to fully examine 
other agency-specific electronic systems, we found evidence that some 
of those systems have a registration process similar to the 
registration process; we could not determine if any had a similar 
validation process. 

[63] Agencies may specify the requirement of a U.S. Postal Service 
postmark or a dated receipt from a commercial carrier in their 
application instructions. 

[64] The remaining responses for these questions were "other" or "no 

[65] In other cases, the grantor agency would accept the application 
but it would receive a lower overall score during the review process. 

[66] On March 9, 2009, OMB required agencies to provide applicants an 
alternative to for submitting applications during the 
Recovery Act peak filing period, which is estimated to last from April 
through August 2009. 

[67] However, applicants who did not complete the registration process 
will not be considered. 

[End of section] 

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