First, standards will be developed and then agencies will have a year to apply them.
The Grant Reporting Efficiency and Agreements Transparency, or GREAT, Act was signed into law as 2019 sunset. This is a good thing: It will connect currently siloed reporting of incompatible grant data into compatible, open and transparent data that can be understood based on consistently defined data elements. According to the forthcoming 2019 Annual Grants Management Survey, grant managers have sought such data standards more so than any other grant management improvement.
If you aren’t familiar with it, the GREAT Act:
- Establishes governmentwide data standards that define how grantees report progress and cost information back to the agencies.
- Directs federal agencies to apply these standards to their grant reporting systems.
- Requires publication of grantee-reported data to a single governmentwide website.
Implementing the GREAT Act
The law mandates the Office of Management and Budget and the standard-setting agency (the department that awards the largest number of grants in a fiscal year, presumably the Health and Human Services Department), two years to establish a common taxonomy or standard for grants data. A large portion of this work is already well underway through the Grants Management Standards in the Federal Integrated Business Framework, through HHS’ Common Data Element Repository (CDER) Library, created under Cross Agency Priority Goal 8 in the President’s Management Agenda and rolled out through OMB Memo 18-24 in September 2018.
OMB and the standard-setting agency will publish guidance for federal agencies to apply these standards to their grants systems and reporting mechanisms. Agencies will then have a year to apply these standards while issuing awards and collecting reports from their grantees.
There are specific steps that agencies should take to implement the GREAT Act.
- Assemble: List all systems used across the grants lifecycle. Include any paper processes in the digitization plan.
- Analyze and assess: Identify points of data input, definitions, and potential duplication. (Check with grantees.) Plan to consolidate grants systems, and potentially rely on shared services. Plan implementation with specific tactics for each impacted system.
- Adapt: Update data input sources and grant systems using the published grants taxonomy. Plan and change business processes to streamline award issuance and reporting activities for grantees and the agency.
- Articulate: Craft audience-specific communications about upcoming changes—to grantees, system users and stakeholders, before, during and after rolling out changes. Provide timelines, changes to actions needed, and beneficial purpose/impact of changes.
How Agencies and Programs will Benefit from being “GREAT”
Agencies may see the GREAT Act as a challenge and a burden. (The Annual Grants Management Survey we complete annually together with George Washington University and the National Grants Management Association provides a picture of grantee burden, which has been increasing.) However, agencies can plan the implementation of the act in ways that maximize their ability to capture benefits like these:
- Efficiency: Grants management efficiency will be measurable and subject to benchmarking; thus, easier to manage. Just as many donors care that their preferred charity spends less than 10% of donations on fundraising and administration, federal stakeholders want to minimize money spent administering grants and maximize the proportion that goes to the program purpose.
- Return on investment: Data standards initiated by the GREAT Act will enable more rigorous comparisons of the performance of programs funded by grants in relation to dollars granted. The GREAT Act enables this ROI calculation and analysis in a credible way, by setting standards for defining, classifying and recording uses of grant program funding.
- Ability to detect waste, fraud and abuse: Grant managers will be able to identify trends, and find outliers to those trends. Over time, comparisons and trends will allow artificial intelligence (and humans) to recognize where a grant program has veered away from an established trend, and investigate why.
Is GREATness Risky?
There are three significant risks to avoid or manage as agencies implement the GREAT Act:
- Burden: Grant recipients and agency staff will be challenged by requirements to change definitions, data gathered, and systems they use. Agencies can reduce this challenge by communicating motives for the change and expected benefits, managing change by involving grantees and agency staff, and planning changes to processes and systems to accommodate the new data standards.
- Mis-matched program and financial data: Most of the GREAT Act’s data standardization relates to financial data. Agencies will need to consider current uses of their data, and determine whether to revise definitions, formats and sources of program data as well, to ensure that combinations of data (such as cost per unit of output) continue to be well-founded.
- Publicized data may create perverse motives: As financial grant data is publicized under the GREAT Act, other types of data (e.g., quality of outcomes, grantee/beneficiary satisfaction) may receive less attention. The result may be that officials work hard to improve the financial picture, but may do so at the cost of quality, outcome or satisfaction.
Congress and the President have done a great thing by enacting the GREAT Act. We are optimistic that it will improve government’s ability to deliver critical programs at levels that are closest to customers while drawing funding from efficient federal tax/revenue collection.
Jeff Myers is a senior director at REI Systems.
Rujuta Waknis is a program manager at REI Systems.
Jason McGill is a director at REI Systems and former director of strategic partnerships and business initiatives for GrantSolutions, a shared service program of the Health and Human Services Department.