This is the accessible text file for GAO report number GAO-09-590R 
entitled 'Recovery Act: Consistent Policies Needed to Ensure Equal 
Consideration of Grant Applications' which was released on April 29, 

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United States Government Accountability Office: 
Washington, DC 20548: 

April 29, 2009: 

The Honorable George V. Voinovich:
Acting 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: 

Subject: Recovery Act: Consistent Policies Needed to Ensure Equal 
Consideration of Grant Applications: is the central grant identification and application portal 
for the more than 1,000 federal grants programs offered by 26 federal 
grant-making agencies and organizations.[Footnote 1] The Office of 
Management and Budget (OMB) created, to streamline 
administrative grant application requirements and reduce the burden on 
applicants, among other things. On March 6, 2009, began 
posting specific grant opportunities provided in the American 
Reinvestment and Recovery Act of 2009 (Recovery Act).[Footnote 2] As a 
result, submissions have escalated to an unprecedented level. During 
the first week in April, processed almost 11,500 
applications, or about three times the weekly average number of 
submissions in fiscal year 2008. One day that week accepted 
3,555 applications--the largest 1-day total to date. 

On March 9, 2009, OMB notified federal agencies that over the past 
several months had experienced increased activity beyond 
what was originally anticipated by the system, which had at times 
resulted in noticeably degraded performance. OMB further noted that 
given the expected increase in application volume because of the 
Recovery Act, the system was at significant risk of failure, thus 
potentially hampering Recovery Act implementation.[Footnote 3] To 
reduce demand on the system and to assist applicants in the 
short term, OMB instructed federal grant-making agencies to identify 
alternate methods for accepting grant applications during the peak 
period of the Recovery Act, with a focus on minimizing any disruption 
to the grants application processes. OMB and agencies estimate that 
this peak period will last from April through about August 2009. 
Alternate methods for applying include agency-specific electronic 
systems (i.e., electronic systems run by a grantor 
agency), e-mail, fax, and mail.[Footnote 4] 

On April 8, 2009, OMB issued another memorandum stating that the 
existing infrastructure will not be able to handle the 
influx of applications expected as key Recovery Act deadlines approach. 
[Footnote 5] OMB said that the Department of Health and Human Services 
(HHS), the federal agency that operates and maintains, and 
the General Services Administration (GSA), which serves as the 
facilitator of governmentwide solutions, are working together to 
initiate urgent improvements to the system, and that each grant-making 
agency is being asked to cover a proportionate share of these 
improvements.[Footnote 6] 

Based on our ongoing work for you on, you asked us to issue 
two reports: one immediately on our initial observations on improving 
grant submission policies that could help minimize disruptions to the 
grants application process during the Recovery Act's peak filing 
period, and the second in June 2009 addressing in more detail systemic 
issues with and implications of varying agency policies for 
processing application submissions. 

Our initial observations are based on our review of policies and 
procedures related to grant applications submissions from the Program Management Office (PMO) and federal grant-making 
agencies. We also examined documentation from HHS, the Grants Executive 
Board (GEB), and OMB.[Footnote 7] As part of the audit work for our 
June 2009 report, we also conducted a Web-based survey in December 2008 
and January 2009 of 80 agency officials representing the 26 federal 
grant-making agencies and organizations within those agencies that have 
distinctive grant application submission and processing policies. 
Throughout this report, we call these organizations grantor agencies. 
We received responses from 74 grantor agencies for a response rate of 
92.5 percent.[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 
that have had problems while using To construct the 
questionnaire, we interviewed agency grant officials and pretested it 
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. In addition, to encourage them to respond, we sent 
three follow-up e-mails. For those that did not respond, we made phone 
calls to encourage respondents to complete the questionnaire. We also 
conducted interviews with officials from the PMO, HHS, GEB, 
and OMB. To obtain more information from the grantee perspective on 
using and other application submission methods, we also 
reviewed documents from associations representing grant applicants and 
conducted interviews with officials from these organizations. 

We conducted the performance audit for our ongoing work on 
from May 2008 to April 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. 


OMB created (initially known as e-Grants) in response to the 
Federal Financial Assistance Management Improvement Act of 1999, 
commonly referred to by the grants community and OMB as Public Law 106- 
107.[Footnote 9] 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. 
[Footnote 10] 

In order to log in and submit an application, first-time applicants 
must register with complex process meant to ensure that 
only authorized applicants can apply on behalf of an organization. 
[Footnote 11] According to, the registration process for an 
organization should take from 3 to 5 business days; however, for some 
applicants, this process can take 2 weeks or more.[Footnote 12] Table 1 
highlights key steps in the registration process and typical 
difficulties that can result in delay. In addition to registration 
difficulties, which may or may not be caused by system 
issues, applicants commonly encounter technical issues with, 
such as system slowness and unresponsiveness, which also delay 
applicants' ability to log in and submit applications in a timely 

To submit an application, an applicant logs in and uploads a completed 
application to 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 by screening for technical errors, such as computer 
viruses. The validation checks are typically completed within 48 hours. 
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 13] 
Grantor agencies retrieve the validated applications from 
and review them and make determinations about grant awards. If a 
grantor agency determines that an application is late, the applicant 
can often appeal this determination. There is no standard set of 
criteria that agencies use to determine whether they will consider an 

Table 1: Key Steps and Time Frames in the Organization 
Registration Process: 

Step: 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 

Step: GSA's 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]. 

Step: 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. 

Step: 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. 


See [hyperlink,] 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 in an organization who can apply for 
grants on its behalf through 

[End of table] 

Applicants Lack a Central Source of Information on Recovery Act 
Alternatives to 

Federal agencies must post all discretionary grant opportunities on; many also require applicants to apply for most or all grant 
applications through Given the growing pressure on caused by increased volume from the Recovery Act, OMB 
required grantor agencies to identify by March 13, 2009, alternate ways 
for applicants to submit grant applications during the Recovery Act 
peak filing period and submit them to OMB for review and approval. 
These alternatives include electronic systems run by a grantor agency, 
e-mail, fax, and mail., the Web site established to 
provide information on the Recovery Act,[Footnote 14] directs people to 
use to search for federal grant opportunities but, as of 
April 28, 2009, lacked information on the alternate submission methods 
agencies have identified. On April 22, 2009, prominently 
posted an announcement stating that all opportunities announced on will include specific application instructions, as 
appropriate, for submitting applications.[Footnote 15] The notice 
directs applicants to carefully read the instructions for all grant 
opportunities--even if they have applied before--to ensure that they 
are following proper submission procedures for the programs. 

As noted in the April 22 announcement, at least 10 agencies 
will accept some or all applications outside of during the 
Recovery Act peak filing period. For example, the National Science 
Foundation and National Aeronautics and Space Administration are only 
accepting applications through their own existing electronic systems 
for some grants, and two Department of Justice program offices are 
requiring applicants to use an internal electronic system to apply for 
grants for the remainder of fiscal year 2009. Many agencies lack 
alternate electronic systems and instead plan to rely on alternatives 
such as e-mail, fax, or mail.[Footnote 16] For example, as stated in 
the Environmental Protection Agency's (EPA) Recovery Act Request for 
Applications Under the Clean Diesel Emerging Technologies Program 
(released March 19, 2009), EPA will generally provide applicants the 
option of submitting application materials by hard copy or through e- 
mail.[Footnote 17] 

On the other hand, the National Institutes of Health (NIH), which will 
be competing at least an additional $400 million of Recovery Act 
grants,[Footnote 18] has no viable alternative to While it 
is the largest federal grant-making entity, with over 90 percent of its 
applications (101,000 submissions) coming in through in 
fiscal year 2008, NIH does not have its own electronic system for 
receiving applications. NIH officials told us that given the size and 
structure of NIH applications, printing and mailing hard copies or 
receiving applications via e-mail is "incredibly impractical" for both 
applicants and NIH. These officials said that applicants will continue 
to apply through but that NIH will accept late applications 
in the event of system problems as it has done in the past. 
[Footnote 19] These officials also said that they believe this work-
around will address most issues, but that since Recovery Act grants 
have shorter time frames than most other NIH grants, decisions about 
grant awards could be adversely affected by a lengthy system 
problem or outage. 

Disparate Agency Policies for Processing Grant Applications Could 
Result in Different Treatment for Applications Submitted Electronically 
versus through Other Means: 

Agencies have disparate policies on several important aspects of 
processing applications, specifically, (1) closing times for submitting 
an application, (2) how to determine whether an application was 
submitted timely, (3) when and whether to notify applicants that an 
application has been successfully submitted, and (4) criteria for 
considering an appeal when an application has been deemed late. 

* accepts applications after the closing time of some grant 
opportunities. accepts applications until midnight eastern 
time on a grant's closing date, but about one-third of the responding 
grantor agencies we surveyed had application deadlines before midnight-
-sometimes as early as noon eastern time.[Footnote 20] NIH, the largest 
grantor agency, has a 5:00 p.m. local time deadline 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) to help resolve 
ongoing system overload issues.[Footnote 21] 

* Agencies have different policies for determining the timeliness of applications as well as for submissions through other 
methods. 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 
22] However, validation can take up to 48 hours after a grant is 
successfully submitted; this has resulted in late submissions.[Footnote 
23] In contrast, applications submitted by e-mail or mailed in hard 
copy--two of the options agencies have made available as alternate 
means of submitting applications during the Recovery Act peak filing 
period--are not subject to validation. Instead, agencies use 
other means to establish the timeliness of these submissions. For 
example, the postmark[Footnote 24] or the arrival date is often used to 
determine the timeliness of paper applications. 

* Agencies differ in notifying applicants when and whether applications 
have been successfully submitted. There are no common requirements for 
notifying applicants of the status of their applications; as such, 
these policies vary across grant-making agencies. More than half of the 
agencies responding to our survey (39 respondents) said that they 
notify an applicant "immediately or almost immediately" when an 
application is late and will not be forwarded for content review. In 
contrast, 13 respondents said that they either wait until the time that 
the grant is awarded to notify applicants or do not notify applicants 
at all.[Footnote 25] Further, an applicant's ability to determine the 
status of an application varies depending on how the application was 
submitted. For example, applicants that mail hard copies of 
applications can choose to track their applications through the U.S. 
Postal Service or commercial delivery service; applicants that 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. Lack of notice, or 
untimely notice, can eliminate an applicant's chance to appeal a late 

* Agencies have different criteria for considering appeals when an 
application is late and do not always consider the most common reasons 
for late submissions. If a grantor agency determines that an 
application is late, 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 that provided data about appeals based on 
registration difficulties said that appeals on this basis were more 
likely to be denied than approved. Registering with in a 
timely manner--which should take from 3 to 5 business days but can take 
2 weeks or more if applicants encounter problems--may be even more 
difficult during the Recovery Act period given the number of applicants 
trying to register. 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. To provide 
evidence of technical issues, agencies may ask applicants to provide 
case numbers from the contact center so the agencies can 
obtain the details of the cases and confirm the technical problems. 
[Footnote 26] However, applicants report that obtaining a case number 
from the contact center in a timely fashion has become more challenging 
in recent months. officials and applicants have reported 
long wait times--sometimes 30 minutes or more--when calling the contact 
center, because of the large numbers of applicants seeking assistance. 
These delays could hamper an applicant's ability to obtain the 
necessary data to support a request for an appeal. 


OMB has acknowledged the importance of in successfully 
implementing the Recovery Act. By working with agencies to initiate 
immediate improvements to and requiring agencies to identify 
alternate methods for accepting grant applications, OMB has played a 
critical role in minimizing disruptions to the grants application 
process. OMB and the staff have worked quickly to mitigate 
an impending system failure and protect the flow of Recovery Act grant 
funds to struggling communities around the country. 

However, applicants lack a centralized source of information on how and 
when to use these alternatives, rendering them less effective than they 
otherwise might be in reducing the strain on a system already suffering 
from seriously degraded performance. Moreover, inconsistent agency 
policies for grant closing times, what constitutes a timely 
application, when and whether applicants are notified of the status of 
their applications, and the basis on which applicants can appeal a late 
application create confusion and uncertainty for applicants and could 
result in an application being treated differently depending on how it 
is submitted--results that are contrary to OMB's stated purposes for 
recent efforts to improve and to the streamlining goals of 
Public Law 106-107 in general. 

Recommendations for Executive Action: 

We are making the following two recommendations to the Director of OMB 
to increase the likelihood that applicants can successfully apply for 
grants during the Recovery Act's peak application filing period. 

We recommend that the Director of OMB ensure that an announcement 
discussing agency alternate submission methods similar to that recently 
posted on is posted in a prominent location on 
and on all federal Web sites or in all documents where instructions for 
applying to Recovery Act grants are presented. Such announcements, 
including the one on, should also include guidance for 
applicants that try to submit through but cannot 
successfully register and are therefore unable to submit timely 

We recommend that the Director of OMB implement and prominently post 
the following governmentwide policies, effective immediately, for all 
grant applications submitted during the peak filing period for Recovery 
Act grants: 

* To the extent permissible by law, applications received at any point 
on the stated grant opportunity closing date should be considered 

* Agencies must notify an applicant when an application submission has 
been received and if the application has been deemed late. An applicant 
that submits electronically (including by e-mail or fax) should receive 
automatic confirmation, including a date and time stamp. 

* Applicants whose applications have been deemed late should be given 
an opportunity to provide supporting documentation to demonstrate that 
they attempted to submit an application on time. Proof of timely 
submission could include (1) e-mail confirmation of receipt from the 
electronic system used to submit the application, (2) system time 
stamps from the electronic system used to submit the application, or 
(3) a dated postmark or receipt from the U.S. Postal Service or a 
commercial delivery service. 

Agency Comments: 

In commenting on a draft of this report, OMB concurred with our 
findings and the overall objectives of our recommendations. OMB staff 
also provided technical comments, which we have incorporated as 
appropriate. OMB said that it plans to work with the Grants Policy 
Committee and with other stakeholders as appropriate to define the best 
path forward in addressing our recommendations. HHS provided technical 
comments which have been incorporated as appropriate. 

We are sending copies of this report to the Director of OMB, 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 

Should you wish to discuss these matters, please contact me at (202) 
512-6806 or 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 were Thomas 
James, Assistant Director; Jacqueline M. Nowicki, Assistant Director; 
Jennifer Ashford; Carolyn Boyce; James J. Burns; David Fox; and James 
R. Sweetman, Jr. Cynthia Grant, Chelsa Gurkin, Luann Moy, and Carol 
Patey also made key contributions. 

Sincerely Yours, 

Signed by: 

Stanley J. Czerwinski:
Strategic Issues: 

[End of section] 


[1] All federal discretionary grant opportunities are required to be 
posted on the site, and many "grantor agencies" require applicants to 
submit most or all grant applications using the "apply" 
mechanism. We use the term grantor agencies throughout this report to 
mean the 26 grant-making agencies and their subcomponents that have 
distinctive application policies. For example, the Department of Health 
and Human Services is made up of agencies, each of which has its own 
policies on grant applications. We consider each operating division a 
grantor agency. In a survey we conducted of 80 grantor agencies, we 
found that 64 percent (47) of the 74 respondents required the use of for most to all of their grants. 

[2] Pub. L. No. 111-5 (Feb. 17, 2009). For grant opportunity postings, 
see [hyperlink,] (as of 
Apr. 28, 2009). 

[3] Office of Management and Budget, Recovery Act Implementation-- 
Improving and Other Critical Systems, M-09-14 (Washington, 
D.C.: Mar. 9, 2009). 

[4] OMB instructed agencies that applicants be provided an electronic 
alternative to; a paper-only alternative was not an approved 

[5] Office of Management and Budget, Improving, M-09-17 
(Washington, D.C.: Apr. 8, 2009). 

[6] Like many e-Government initiatives, is funded by 
voluntary agency contributions. OMB instructed the 26 grant-making 
agencies that together finance to immediately submit any 
fiscal year 2009 unpaid contributions to HHS and to provide the 
additional funding requested for Recovery Act-related improvements to See Office of Management and Budget, Improving 

[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 OMB provides 
oversight and guidance to the 24 e-Government initiatives of which is one. 

[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 
between and within the 26 grant-making agencies. We identified 80 
grantor agencies that have distinctive grant application policies. The 
74 responses we received were from all of the 26 grant-making agencies. 

[9] 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. 

[10] OMB requires agencies to announce all discretionary grants 
opportunities on; it does not require agencies to accept 
applications through 

[11] Applicants applying as individuals (not as part of an 
organization) must also register with before applying for 
grants; however, individuals are only able to apply for grant 
opportunities that are open to individuals. In our survey, only 32 
percent (24) of the 74 respondents stated that they offer grants to 

[12] As shown in table 1, obtaining an employer identification number 
from the Internal Revenue Service may take 2 weeks or more. 

[13] 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 

[14] Pub. L. No. 111-5, div. A, title XV, § 1526. 

[15] See [hyperlink,] (as 
of Apr. 28, 2009). 

[16] In some cases, agencies already allowed applicants to submit using 
these alternative methods. 

[17] The other 6 agencies are: Corporation for National and Community 
Service, and the Departments of Defense, Education, Energy, Housing and 
Urban Development, and Transportation. 

[18] NIH plans to compete approximately $9.9 billion in Recovery Act 
grants and Recovery Act contracts. At the time of our review, NIH 
officials estimated that of the $9.9 billion, a minimum of $400 million 
would be awarded through grants. The Web portal for all federal 
government contracting opportunities is [hyperlink,]. 

[19] Even before the Recovery Act became law, some agencies recognized 
the need to amend their application submission policies to better meet 
applicants' needs. For example, NIH reported that it has changed its 
policies to accommodate applicants that encounter technical problems 
with or NIH systems, and that it works with applicants in 
need of assistance even if it means granting an extension beyond the 
grant closing date. 

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

[21] For example, on April 6, 2009, the day received its 
largest numbers of submissions to date, almost one-third of the 3,555 
applications received were submitted from 3:00 p.m. through 6:00 p.m. 
eastern time. 

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

[23] 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. 

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

[25] Of the remaining responses, 12 answered "other," and 10 did not 
respond or answered "no response." 

[26] The contact center is a help desk that applicants can 
call or e-mail when they need assistance. The contact center assigns 
case numbers and attempts to resolve callers' issues. The grantor 
agency can contact the call center and use the case number to obtain 
the case notes. Grantor agencies may also allow the applicants to 
provide additional evidence. 

[End of section] 

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