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GPD
Part 1.04: General - HHS Responsibilities
HHS
Transmittal 99.03 (3/30/99)
Part 1 GENERAL
Section 04 HHS Responsibilities
A.
Principles
- Purpose.
This Grants Policy Directive (GPD) outlines the primary responsibilities
of grants management staff [grants management officers (GMOs) and grants
management specialists] and program officials/project officers in the
award and management of HHS grants and grant programs. It also delineates
the qualifications and authorities of individuals serving in those capacities.
- Scope.
This GPD applies to all HHS discretionary grants and cooperative
agreements and all HHS grant programs. For grants management staff involved
in discretionary grant programs, this GPD serves to highlight significant
general responsibilities; however, additional and more specific responsibilities
may be addressed in other GPDs, as appropriate. Paragraph D.2. specifies
the minimum requirements for GMOs responsible for mandatory grants.
More detailed information on mandatory grants will be included in GPD
5.01.
- Policy.
Each OPDIV is responsible for (1) ensuring the integrity of
its grants management operations by establishing and maintaining organizational
arrangements that do not compromise or have the potential to compromise
the independence of the GMO, (2) developing and implementing a Grants
Management Professional Certification Program and providing the necessary
resources and opportunities for training of grants management and program
staff, and (3) periodically assessing the efficiency and effectiveness
of the grants management function.1
The
Office of Grants Management, Office of Grants and Acquisition Management
(OGM/OGAM), is responsible for overseeing OPDIV implementation of
this policy.
B.
HHS Grants Management Professional Certification Program
OPDIVs are responsible for establishing, in writing, and maintaining an
OPDIV implementation of the HHS Grants Management Professional Certification
Program.
C.
Authorities and Responsibilities
- Organizational
Placement of Grants< Management Function.
Grants
management staff are primarily responsible for the business and other
non-programmatic areas of grant award and administration. They are
responsible for ensuring that, for grants under their cognizance,
both federal staff and grantees fulfill applicable statutory, regulatory,
and administrative policy requirements.
1
The process and requirements of the HHS Grants Management Balanced Scorecard
are currently under development.
As
a result, GMOs must be independent of program management offices.
A GMO may not report to an official who exercises program management
authorities unless that official is the head of the OPDIV or the arrangement
has been authorized by the OPDIV's Chief GMO and approved by OGM/OGAM.
- Grants
Management Officers.
- Chief
Grants Management Officer. Each OPDIV that accomplishes any
part of its mission through the use of grants and cooperative agreements
must appoint a Chief GMO. The OPDIV head is responsible for appointing
the Chief GMO in accordance with the following and any OPDIV requirements.
The Chief Grants Management Officer will be the appointing authority
for any additional OPDIV GMOs.
- Appointing
Grants Management Officers.
(1)
As a prerequisite to appointing an individual as a GMO, including the
Chief GMO, the appointing official must determine that the individual
has the requisite grants and business management background and experience
to perform fundamental business management functions. This will be demonstrated,
in part, through satisfaction of the prerequisites of the HHS Grants
Management Professional Certification program (see paragraph B. above).
(2) An individual may sign Notices of Grant Award (NGAs) and amendments
thereto and exercise other GMO responsibilities only if formally delegated
such authorities by the Chief GMO. However, OPDIV Heads and regional
Office Heads may exercise GMO authorities as a result of their organizational
delegations of authority.
-
Grants Management Specialists. Grants management specialists
are individuals that work under the general direction of a GMO.
-
Other Non-Program Staff. OPDIVs may use other staff, including
grants policy staff and audit resolution staff, in support of their
grants management functions. OPDIVs must specify the necessary qualifications
for these positions. If such individuals need to act as GMOs to carry
out any part of their responsibilities, they must satisfy the qualification
and appointment requirements for GMOs specified in paragraph C.2.
- Program
Officials
Program
staff designated as program officials/project officers (hereafter,
project officer) are responsible for the programmatic, scientific,
and/or technical aspects of grants. A project officer must be appointed
for each grant award, but an individual may serve in that capacity
for multiple awards.
In
selecting program officials to serve as project officers, OPDIVs should
take into consideration such factors as training and experience; knowledge
of applicable laws, regulations, and policies; and knowledge of awarding
office goals and priorities.
Individuals
appointed as project officers should meet within 12 months of their
appointment training requirements established by the Deputy Assistant
Secretary for Grants and Acquisition Management and may be certified
under an OPDIV's certification program.
D.
Significant Responsibilities
-
The following list of activities highlights those that form the essence
of the separation of responsibilities of the grants management and program
management functions. The list is not intended to be all-inclusive.
As
used in this paragraph, GMO means the individual with delegated authority
or, for activities comprised of multiple procedures that may be performed
at a lower level, the GMO or grants management staff acting on his
or her behalf.
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Signature Authority. Grant awards and amendments are not binding
on the Federal Government unless signed by the cognizant GMO, OPDIV
head, or regional office head.
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Choice of Instrument. Program officials are responsible for
indicating in preaward documentation, including any program announcement,
whether a program or project should be implemented through a grant(s)
or cooperative agreement(s). If the use of a cooperative agreement(s)
is indicated, program officials are required to establish the nature
of the Federal Government's involvement in the activity during project
performance.
GMOs
are responsible for determining the appropriate award instrument
consistent with GPD 2.02.
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Program Announcements. Program officials are responsible
for developing program announcements as early as possible in a fiscal
year to allow sufficient time for applicants to prepare applications
and awarding offices to make resulting awards.
GMOs
may assist in the development of program announcements. GMOs are
required to review and clear these documents for publication prior
to their issuance. If a GMO has concerns with a program announcement
that cause him/her not to provide the required clearance, it may
not be issued unless the OPDIV head overrides the GMO's concerns.
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Competitive Review Process. Program officials are responsible
for overseeing the selection of qualified independent review panels
and providing them with the necessary information and material to
conduct their evaluations.
GMOs
are responsible for reviewing and approving the instructions provided
to independent review panels prior to their being convened; advising
panels, as necessary; and signing or countersigning the ranking
of applications by these panels.
The
above responsibilities do not apply to OPDIVs/programs in which
the independent review process is managed by an office other than
the cognizant program office.
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Preapplication and Application Review. Primary responsibility
for performing budget and costs analyses to determine the necessity,
reasonableness, and allocability of costs in application budgets rests
with GMOs. The program official, in coordination with the GMO, is
responsible for ensuring that application budgets meet project needs
and program requirements, and supplying to the GMO, as necessary,
programmatic or technical information to use in negotiating grant
budgets.
If
a program or support mechanism requires preapplication submission,
program officials are required to evaluate the submissions for relevance
to solicitation topics or stated needs and to determine their conformance
with program requirements and guidelines.
Program
officials are responsible for debriefing unsuccessful applicants
regarding programmatic deficiencies in their applications.
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Business Management and Prior Approvals. Following award,
GMOs are responsible for reviewing and signing all subsequent business-related
correspondence concerning grants. Although not required, program officials/project
officers may countersign notices of grant award and other business-related
correspondence sent to grantees
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Mandatory Receipt and Control Points. GMOs serve as official
receipt and control points for grant applications unless this responsibility
has been assigned to a servicing office other than the cognizant grants
management/program office under the authority of an individual not
in the line of program authority.
GMOs
serve as the official receipt and control points for all required
grantee reports, other than reports required by the paying office,
invention reports, and any other class of reports received by a
designated central non-program office, and all formal communications
or contacts that, if approved, would result in changes to an award,
including its terms and conditions.
- Official
Grant Files. GMOs are responsible for maintaining the official
grant files for individual grant awards. Program officials will supply
such material as necessary to ensure that the official grant files
are complete.
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Reports and Closeout. In addition to being the mandatory
receipt point for required reports, GMOs are responsible for monitoring
the receipt of all required reports and taking appropriate follow-up
action, as necessary, to obtain delinquent reports. GMOs must also
review and ensure all necessary adjustments to financial reports are
made prior to grant closeout.
Project
officers are responsible for reviewing and preparing programmatic
evaluations on all performance reports required to be submitted
under grants. Following the completion of all required work under
grants by grantees and the performance of all pre-closeout administrative
actions by OPDIVs, GMOs are responsible for closing out grant awards/files.
In doing so, they must ensure that grant files contain all pertinent
documents, including required reports, and evidence that appropriate
grants management and program office reviews and evaluations have
been conducted.
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Audit Resolution. GMOs are responsible for resolving or participating
in the resolution of audit findings involving grant programs. When
audit resolution is handled by other designated staff, the cognizant
GMO must be afforded the opportunity to review and comment on the
OPDIV position prior to notifying the grantee.
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Minimum Grants Management Officer Responsibilities for Mandatory Grants
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GMOs for mandatory grant programs must be independent of program management
offices. GMOs for mandatory grant programs will not report to an official
who exercises program management authorities (including approval of
grant applications/plans) unless that official is the OPDIV head.
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GMOs for mandatory grant programs are required to sign or countersign
NGAs.
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GMOs for mandatory grant programs are responsible for maintaining
the official grant files for individual grant awards.
-
GMOs for mandatory grant programs are responsible for monitoring the
receipt of any required financial status, expenditure, and estimate
reports.
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GMOs for mandatory grant programs must participate in the resolution
of audit findings, including concurring with or approving audit resolution
actions.
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