Recovery Act:

Consistent Policies Needed to Ensure Equal Consideration of Grant Applications

GAO-09-590R: Published: Apr 29, 2009. Publicly Released: Apr 29, 2009.

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Stanley J. Czerwinski
(202) 512-6520


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(202) 512-4800 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. 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 Recovery and Reinvestment Act of 2009 (Recovery Act). 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. 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. 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. 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. Based on our ongoing work on, Congress 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.

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. 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. 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

  1. Status: Closed - Implemented

    Comments: During the peak application period (March through August 2009), a notice was posted prominently on which notified applicants that some agencies were accepting applications through alternate methods. This language of the notice was not targeted to applicants who could not register on, although all of those applicants may have seen it.

    Recommendation: To increase the likelihood that applicants can successfully apply for grants during the Recovery Act's peak application filing period, the Director of OMB should 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 applications.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  2. Status: Closed - Not Implemented

    Comments: The peak application lasted from March through August 2009. OMB confirmed that this recommendation has not yet been implemented. Since the recommendation expired after the peak application period, it is being closed without implementation.

    Recommendation: To increase the likelihood that applicants can successfully apply for grants during the Recovery Act's peak application filing period, the Director of OMB should implement and prominently post the following governmentwide policies, effective immediately, for all grant applications submitted during the peak filing period for Recovery Act grants: (1) To the extent permissible by law, applications received at any point on the stated grant opportunity closing date should be considered timely. (2) 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. (3) 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 (a) e-mail confirmation of receipt from the electronic system used to submit the application, (b) system time stamps from the electronic system used to submit the application, or (c) a dated postmark or receipt from the U.S. Postal Service or a commercial delivery service.

    Agency Affected: Executive Office of the President: Office of Management and Budget


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