Jean Feldman talked about how the SF-424 needs to change to help FFATA compliance. Jean leads the SF424 Forms Families & FFATA Implementation Subcommittee. More after the link…
The subcommittee has representation from across government, to ensure that all SF-424 variants were considered in the effort. The initial step was to review each of the data elements and identify the primary source of the data — the SF-424, the agency, or both. The major elements of the the proposed implementation strategy is as follows:
- Use of a consistent implementation strategy across the SF0424 form families for responding to FFATA data requirements.
- Therefore, a new form entitled Project/Performance Site Location(s) to be added to all SF0424 form families (with the exception of the R&R where this form already exists).
- The form should be developed in accordance with several concepts: 1) Mandated for use across all form families except Individual, for which it will be option; 2) The primary location site will be prepopulated from the applicant information off the applicable SF0424 Cover Page, but would be editable; 3) For the SF-424 (Individual), the attachment will prefill from the SF-424 (Individual) Cover Page, where feasible. The DUNS number also would need to be made optional for the SF0424 (Individual) sine most individual applicants will not have a DUNS number.
Jean took pains to note that Grants.gov has not committed to any technical solution for these recommendations. So they remain recommendations and not implementation plans, at this point.
The recommendations package was presented to the GPC on July 24th. This was approved for publication to the Federal Register (FR) for comment. Grants.gov PMO was assigned the responsibility of preparing the FR package, with assistant from the subcommittee. In discussions with Grants.gov about implementation, minor changes were made to the FR package, and changes were distributed to GPC members via e‑mail.
Jean noted that the SF-424 forms families are up for renewal with OMB relatively soon, and some other changes may be made at that time.
Q [Steve Dowdy]: When will work start on other issues, such as redrawing of Congressional Districts, etc.?
A [Jean Feldman]: Solutions on the Congressional District issue (e.g. the actual location of grant performance, as opposed to location of the awardee) have not been formulated yet.
(Steve suggested a problem: What if the research is done on a ship in the ocean? “I’ll be putting ‘Ocean Avenue’ on the form,” he said! He’s challenging Gil Tran’s humor-at-FDP supremacy…)
Q [Dick Sullivan?]: Please explain the relationship between the data elements on the cover page of the grant application and the requirement to report information on subawards and subcontracts.
A [Jean Feldman]: How we get subaward data is being decided. In the SF-424 (R+R), you’d supply subaward information that you know about at the time of application. The question that arises for FFATA is that this information can change upon award, and that the government doesn’t know about all of the subawards that may happen.
Q [Bob Beattie]: What forms will be updated to implement these answers, PureEdge or Adobe?
A [Jean Feldman]: That’s a technical decision to be made by Grants.gov. We just looked at the data collection requirements and the data elements to be collected on the form.