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MITRE's Response to the OMB RFI on Guidance for Grants and Agreements

MITRE’s data-driven responses to an Office of Management and Budget inquiry requesting input on updating Guidance for Grants and Agreements. 

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What’s the issue? The Office of Management and Budget (OMB) is proposing to revise sections of its Guidance for Grants and Agreements, including both clarifications and to reflect recent OMB priorities on federal financial assistance.

What did we do? The Center for Data-Driven Policy led a cross-MITRE analysis of OMB’s posed questions, seeking to uncover data and evidence from our work in the public interest that would help them understand opportunities and develop plans that are evidence-based, actionable, and effective.

What did we find? The business processes and information required to execute loans and benefits are significantly different from grants and agreements. Expanding the 2 CFR rules to additional types of financial assistance without clearly indicating which subsections apply to all, some, or specific types of financial assistance will increase burden and create inconsistencies when agencies and grant recipients attempt to determine on their own which 2 CFR subsections are applicable (or not applicable) to each type of financial assistance.

MITRE recommends deferring such action until: (1) a lifecycle analysis of the functions and activities for loans management and benefits management is completed, and (2) the specific 2 CFR subsections applicable to each loans management and/ or benefits management activity have been identified and validated with a cross-agency work group.