Vicky:  Not much that you can do now, it seems to me, in that the Sub-
award pilot has not yet started.  Is that what you are considering?
After the pilot, we will all know better what we will have to do.

EVERYONE:  In the meantime, Tuesday, August 5 is the last day to make
comments on the request from OMB for comments on the Guidance they
published.  If anyone has yet to send info, I offer the text below.

There are  a couple of items that I hope people will address in their
comments.  If  you have not already sent anything, you can send to
the email address  noted below.  I think this works better than using
the web site
http://www.regulations.gov/search/index.jsp
If you use the web site, enter "transparency act " in the box in the
middle section.

The text of the Guidance is here
http://www.cfoc.gov/documents/E8-12558.pdf

Electronic mail comments may be submitted to: Marguerite Pridgen at
xxxxxx@omb.eop.gov.
Please include ‘‘Transparency Act Guidance’’ in the subject line and
the full body of your comments in the text of the electronic message
and not as an attachment.
Please include your name, title, organization, postal address,
telephone number, and e-mail address in the text of the message.

May I suggest the most important comment to make on the Guidance is
to eliminate any use of the Central Contract Registry (CCR) for the
sub-award purposes.  To require thousands of small entities around
the country to register with CCR seems to serve no useful purpose
that getting a DUNS number does not resolve.  This mass registration
will strain the capacity of CCR.  Much unnecessary but confidential
data about organizations will end up on-line.  Sub-award grantors
will need to spend much time checking on the registration status of
the sub-awardees.  DUNS numbers, and the full address data required
by the law are quite sufficient to identify all sub-award receiving
organizations.  Please at least send this comment to OMB.  There is
no need to require organizations receiving sub-awards to register
with CCR.

There are a couple of other issues you might want to mention as
well.  There now seems to be an IT solution for sub-award grantors to
report their sub-award data for the pilot.  In the final version,
however, there MUST be just one IT solution for reporting data on sub-
awards from both Grants and Contracts.  We cannot be expected to use
two different reporting mechanisms.  In addition, that final IT
mechanism must allow for both single, one-at-a-time entry, and for
bulk, uploading of data by large organizations.  This topic is not
discussed much in the Guidance but OMB must be told of these needs,
now, so they can include this in the next Guidance.

Lastly, I urge folks to mention something else not covered in the
Guidance.  This topic is how we are "to allocate reasonable costs for
the collection and reporting of sub award data as indirect costs."
These are the exact words of the original legislation.  Again, this
problem needs to be mentioned so that it is not overlooked in the
next Guidance.   OMB must come up with a solution to allow us
allocate costs even if we are above the administrative cost cap.

I hope readers will take a few minutes to make a comment to OMB on at
least the first issue, if not all three.  Thanks.

Bob
------------------------------
Robert Beattie
Division of Research Development and Administration
University of Michigan
xxxxxx@umich.edu   (734) 936-1283

On Aug 1, 2008, at 11:27 AM, Ratcliffe, Victoria wrote:

Good Morning,

I have been tasked with creating a plan/procedures for implementation of
the Federal Accountability and Transparency Act.  Has anyone starting
planning for the implementation?  I am interested to see how other
universities will be handling this.

Sincerely,

Vicky Ratcliffe, MBA

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================