GPD Part 1.01: General - Introduction

HHS Transmittal 97.01 (4/17/97)

Part 1 General

Section 01 Introduction

A. Principles of the Grants Policy Directive System

1. Purpose and Scope. The Grants Policy Directive System provides
   guidance on grants management issues to grants and affected
   program offices at all organizational levels within the Department. The
   cornerstones of this system are the Grants Policy Directives (GPDs)
   which are replacing the information currently found in the Departmental
   Grants Administration Manual (GAM).

   The formulation of the GPDs resulted from an extensive study of
   the Department's grants policy-making process conducted during 1992.
   Other recommendations from this study, such as expanded operational
   involvement in policy development, electronic availability of grants
   policies, and ongoing policy evaluation, were developed as necessary
   adjuncts to the GPDs. These changes ensure that Departmental grants
   policy remains current, as well as transmitted expeditiously to
   Departmental staff.

2. Grants Policy Directives. GPDs present Departmental grants
   policy in a succinct manner, with an emphasis on policy over procedure.
   GPDs are issued solely as an instrument of internal Department
   management and with the sole intention of directing Departmental
   staff to follow the policies, standards, and procedures set forth herein.
   These directives are the highest level of Departmental grants policy
   issuance within the Department.

   GPDs serve as the primary source of Departmental grants policies.
   OPDIVs, however, are instructed not to merely repeat the language
   in the GPDs or reissue the GPDs in their entirety when developing
   their own implementation manuals. Rather, HHS OPDIVs are required
   to develop more detailed grants administration manuals which reflect
   their implementation of the directives. In this way, Departmental
   grants policy documents can be compiled and displayed together and
   build upon the guidance from the next higher level. Policy statements
   are broad in scope thus allowing Departmental granting to components,
   wherever possible, flexibility in developing procedures necessary
   to implement and maintain Departmental policy issued herein.

   GPDs are a component of the Department Staff Manual System. Primary
   responsibility for the development of GPDs is assigned to the Office
   of Grants Management (OGM) within the Office of the Assistant
   Secretary for Management and Budget (ASMB).

3. Operational Involvement. Increased involvement in policy
   development by grants operational staff is achieved through a feedback
   mechanism. That is, proposed grants policies are developed in a concept
   paper format and are to be broadly disseminated to grants operational
   staff at all administrative levels within OPDIV grants offices for review
   and comment. Soliciting broad-based comments during the initial stages
   of grants policy development facilitates policy consensus, thus reducing
   time spent in conflict resolution.

   Moreover, the grants policy development process is also enhanced
   by the involvement of selected grants operational staff on grants
   policy advisory boards or committees such as the Executive Committee
   on Grants Administration Policy (ECGAP) and equivalent boards or
   committees at the OPDIV level.

4. Conflict Resolution. Conflicts which occur during the development
   of grants policy are typically resolved at the ECGAP level. Differences
   not resolved within ECGAP to the satisfaction of the OPDIVs will be
   submitted to the ASMB for final arbitration.

5. Training. As directives are issued, steps should be undertaken
   to ensure that appropriate training and guidance will be provided to
   grants operational and policy staff regarding the new policies. The
   OGM will review with OPDIVs the training required to implement policy
   issuances. In addition, Departmental and OPDIV training programs which
   address grants and other administrative policies should include reference
   to GPD policies as appropriate.

6. Evaluating Grants Policy. All policies contained in GPDs will
   be evaluated on an ongoing basis by the OGM to ensure that policies
   remain current. Individual directives will be evaluated every four years
   to ensure that there is still a need for the policy and that it remains
   practicable. The concept paper format will be used for distrubting the
   revised policy directives to grants operational staff for review and
   comment.

7. Approval of Grants Policy Directives. Final authority to approve
   and issue GPDs rests with the Assistant Secretary for Management and
   Budget.

1. Sequence of Directives. In general, GPDs follow the organization
   of OMB Common Grant Regulations and Circular A-110. Policy
   presented in this manner more closely mirrors the life cycle of the
   grants process and provides staff with improved continuity and
   consistency in the arrangement of grants policies. Specifically,
   GPDs are arranged in the following major divisions or Parts,
   with Sections also generally following OMB sequencing:

   (1) General
   (2) Pre-Award
   (3) Post-Award
   (4) After-The-Grant
   (5) Mandatory Grants

   OPDIVs are directed to structure their grants administration manuals
   in this format so that there will be uniformity in the location of
   policy within Departmental grants policy documents.

2. Numbering System. The design of the GPD numbering system is
   intended to provide more meaningful identifiers of individual
   Departmental grants policy issuances. Imbedded within a GPD
   number is the applicable Part and issuing level (i.e., OS, OPDIV/
   STAFFDIV). By encoding GPDs numbers with useful information,
   grants management professionals can easily locate both the policy
   issuance itself as well as its associated granting agency level. In
   this manner of numbering, policy can be traced back to the OS source.

3. Citation. The first two placements in a GPD citation denote
   policy issuance at the OS level. The first numeral is a single-digit,
   ranging from 1 to 5 that identifies the major Part under which the GPD
   is organized. Following a decimal point, a two-digit numeral ranging
   from 01 to 98 identifies the specific Section (under a Part) that is
   issued by the OS. The number 99 is reserved for OPDIV level policies
   that are not addressed at the OS level.

   The third placement in the GPD citation identifies the OPDIV/STAFFDIV
   issuing the policy/procedural implementation. After the OS citation
   is a three-digit numeral, ranging from 101 to 699, which is preceded
   by a decimal point. In order to differentiate issuances among OPDIVs/
   STAFFDIVs and to allow for non-duplicative numbers, the 100 series is
   reserved for the various components operating under the PHS with the
   exception of the NIH. The 200 series is reserved for HCFA, followed by
   the 300 series for ASPE, 400 series for ACF, and the 500 series for AoA.
   The 600 series is reserved for NIH.

   Within each of these series, OPDIV/STAFFDIV issuances are
   sequentially numbered.

Citation Example:

i.      At the OS level, the citation for the definitions
        section under Part 1- General, would read:

                  1      .02
                  |       |
                Part     Sect.

ii.     The citation for the same section, but at the 
        OPDIV level (using HCFA as the example)
        would read:

                  1      .02        .202
                  |       |           |
                Part     Sect.      OPDIV

        To differentiate among PHS components using the 
        100 series, PHS operating components will use 
        their identifying name or acronym either before or
        after any numeric policy citation. 

Citation Example:

i.      Under Part 1 - General, FDA could identify its 
        implementation of the Introduction as;  

                  1      .01        .101 FDA

ii.     The same citation, however, for CDCP might be
        referenced as:

        CDCP      1      .01        .101

        To accommodate grants policy issues which are not 
        addressed at the OS level but which are necessary
        at the OPDIV level, the number 99 is reserved for 
        this purpose.  These policies, referred to as 
        supplements, will be arranged sequentially from
        01 to 98.

Citation Example:

i.     Under Part 2 - Pre-award, HCFA has several policy  
       issues which are applicable only to HCFA.  The
       citations for this section would read:


                  2      .99        .201
                  |       |           |
                Part   Reserved   Supplement #1

                  2      .99        .202
                  |       |           |
                Part   Reserved   Supplement #2

1. Effective Date. GPDs are effective immediately upon issuance
   by the ASMB. Initial notification to OPDIVs regarding policies contained
   in the GPDs will occur via the concept papers circulated to grants
   operational staff for comment. Additional advance notification to
   OPDIVs concerning impending policy directive issuances will be
   provided as necessary should the new policies require substantial
   preparation for effective implementation.

2. Internal Implementation of Grants Policy Directives. Upon
   issuance of GPDs, OPDIVs incorporate GPD policies in their own grants
   administration manuals. Any existing OPDIV manual chapters which
   conflict with GPDs are superseded. OPDIVs that previously used the
   Departmental GAM rather than creating their own policy manuals or
   issuances are required to develop grants administration manuals that
   address agency-specific procedures for implementing GPDs.

   Within six months of issuance of individual GPDs, OPDIVs are required
   to submit their implementation of the GPDs to the OGM for approval.
   These documents, whether newly created chapters or revisions to
   previously existing manual chapters, must adhere to the organizational
   arrangement and numbering system outlined above. Any other
   proposed internal OPDIV implementation of GPDs shall be
   submitted to the OGM for review and approval prior to publication.

   For PHS components following guidance contained in the Public Health
   Service Grants Administration Manual, an option will be provided to
   adopt a HHS generic Grants Administration Manual to be developed
   following the issuance of the first full complement of GPDs. This
   generic manual will enable operating components with limited staff
   resources the ability to implement GPD requirements with little or
   no extra effort.

3. External Implementation of Grants Policy Directives.Following
   the issuance of GPDs, OPDIVs will follow their own procedures to inform
   the public how the provisions of the directives will affect their respective
   agencies' grants. OPDIVs are required, however, to submit any external
   implementation of GPDs to the OGM for review and approval prior to
   publication.

4. Revisions of Grants Policy Directives. Revisions to GPDs,
   either as a result of the ongoing review process, or proposed legislation
   or executive mandate, will be disseminated to grants operational staff
   using the concept paper format. Once finalized, a revised policy directive
   will be issued superseding the previously issued directive. A transmittal
   memo under the signature of the ASMB will accompany the revised
   directive and the policy directive will be in effect as of the date signed
   by the ASMB.

5. Transition from the Grants Administration Manual to Grants Policy
   Directives. The replacement of the Departmental GAM with GPDs is
   being accomplished on a phased-basis over a period of time. As
   individual policy directives are issued, respective chapters in the
   GAM are superseded.

   During this transitional period, Departmental grants policies will
   be found in both the newly issued policy directives and those GAM
   chapters that have not been replaced. When all chapters in the GAM
   have been superseded by directives, notification of the complete
   replacement of the manual with GPDs will be transmitted to
   OPDIVs by the ASMB.

6. Distribution of Grants Policy Directives. GPDs and non-superseded
   chapters to the Departmental GAM are available through the
   Department's MS.HRFC- 125 mailkey. Also, upon issuance of
   individual GPDs, a single copy of the directive will be forwarded
   to OPDIV representatives serving on ECGAP.

   The GPDs with accompanying transmittals, as well as the superseded
   and non- superseded chapters of the GAM, are posted electronically
   on GrantsNet, the Department's on-line grants information service
   available through the Internet. GrantsNet can be located under the
   Department's Internet Home Page.

   Electronic versions of the GPDs and GAM will also be available under
   the Grants Document Library component of the Tracking Accountability
   in Government Grants System (TAGGS). TAGGS, which will provide
   Departmentwide access to HHS grants information, will be accessible
   via "intranet" technology.