BFS Learning Blog

OMB Update M-22-02:
New Financial
Assistance Transparency
Reporting Requirements.

Cindy Watson

On October 26, 2021, the U.S. Office of Management and Budget published OMB Memorandum M-22-02,  New Financial Assistance Transparency Reporting Requirements.   

The memorandum primarily addresses two items:

1.     It concludes and formally rescinds OMB Memorandum M-21-03, Improvements in Federal Spending Transparency for Financial Assistance.  The M-21-03 Memorandum directed the development and use of data standards in accordance with the Grant Reporting Efficiency and Agreements Transparency (GREAT) Act, Pub. L. No. 116-103. Memorandum M-22-02 concluded the working group review required by Memorandum M-21-03 and rescinded the memorandum.

2.     It issues additional guidance to agencies on the financial assistance data to be reported to and displayed on USAspending.gov.  This reporting requirement is mandated under the Federal Funding Accountability and Transparency Act (FFATA), is amended by the Digital Accountability and Transparency Act (DATA Act), and requires the Federal Government to increase the availability, accuracy, and usefulness of online information regarding Federal spending.

Consistent with the Grants Management Business Standards, M-22-02 sets a series of mandatory and optional reporting deadlines for grants, cooperative agreements, and new financial assistance awards.  In addition, the memorandum requires reporting if the period of performance end date of a grant and a cooperative agreement is revised regardless of reason.

Agencies must report the following information to USAspending.gov, as indicated in the reporting instructions available in the DATA Act Information Model Schema (DAIMS):

        Effective October 1, 2023 (with optional reporting October 1, 2021), for competitive discretionary grants and cooperative agreements, agencies must report the data element Funding Opportunity Number.

        Effective October 1, 2023 (with optional reporting October 1, 2021), for competitive discretionary grants and cooperative agreements, agencies must report the data element Funding Opportunity Goals Text.

        Effective April 4, 2022 (with optional reporting October 1, 2021), for grants and cooperative agreements, agencies must report the data element GRM  Indirect Cost Federal Share Amount.   

        Effective October 1, 2021, for all new financial assistance awards, agencies must report all Assistance Listings and the associated funding for each Federal financial assistance award reported to USAspending.gov.

        Effective October 1, 2021, if the Period of Performance End Date for grants and cooperative agreements is revised for any reason (e.g., due to an extension, termination, lack of available funds, etc.), agencies are required report the updated Period of Performance End Date to USAspending.gov.  

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