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United States

Grants Accountability (US0106)



Action Plan: United States Action Plan 2019-2021

Action Plan Cycle: 2019

Status: Active


Lead Institution: NA

Support Institution(s): NA

Policy Areas


IRM Review

IRM Report: United States Design Report 2019-2021

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information , Technology

Potential Impact:

Implementation i

Completion: Pending IRM Review


Ensure Accountability for Grants
Every year, the Federal Government spends approximately $700 billion on grants and cooperative
agreements for approximately 1,800 different funding categories covered in the Assistance Listings.
The Office of Management and Budget estimates that more than 40,000 grant recipients receive
funding annually, including State and local governments, universities, non-profits, tribes and small
The Trump Administration will pursue Results-Orientated Accountability for Grants by improving the
transparency of the Federal grant-making process to the American public. The System for Award
Managements (SAM) will become the central repository for common government-wide certifications
and representations required of Federal grant recipients.
Under this commitment, Federal agencies will:
- Review data standards when they are published to ensure completeness and accuracy, and
inclusion of critical distinctions in types of grants and recipients;
- Align agency grant-related reform initiatives to the President’s Management Agenda;
- Modify existing, or design new, grant systems to use government-wide data standards.

IRM Midterm Status Summary

2. Ensure Accountability for Grants

Main Objective

“Pursue Results-Orientated Accountability for Grants by improving the transparency of the Federal grant-making process to the American public. The System for Award Managements [10] (SAM) will become the central repository for common government-wide certifications and representations required of Federal grant recipients.


“Review data standards when they are published to ensure completeness and accuracy, and inclusion of critical distinctions in types of grants and recipients.”

“Align agency grant-related reform initiatives to the President’s Management Agenda.”

“Modify existing, or design new, grant systems to use government-wide data standards.”

Editorial Note: For the complete text of this commitment, please see the United States’ action plan at:

IRM Design Report Assessment





Access to information; technology and innovation for transparency and accountability

Potential impact:


Commitment analysis
This commitment facilitates results-oriented accountability for federal grants by “improving the transparency of the federal grant-making process,” [11] specifically surrounding assistance listings, defined as “assistance to the American public in the form of projects, services, activities.” [12] The commitment will make the System for Award Management (SAM) [13] the “central repository for common government-wide certifications and representations required of Federal grant recipients,” [14] thereby enabling entities seeking federal assistance [15] to conduct a centralized search for assistance and submit required certifications and representations at a centralized repository. [16] “Representations and certifications” refer to information that is required when applying for federal assistance, and annually updated per the Federal Acquisition Regulation (FAR), which governs federal procurements. [17] The representations and certifications are comprehensive, covering issues from unpaid federal tax liability and criminal history to compliance with Equal Employment Opportunity regulations.

Under the government’s efforts to position SAM as the government repository for certifications and representations for assistance, the commitment envisions a range of activities for federal agencies: (1) reviewing assistance listings’ data standards at the time of publication to ensure completeness and accuracy, as well as to ensure the inclusion of distinctions in grant types and recipients; (2) aligning agency grant reforms to the President’s Management Agenda; and (3) modifying existing or designing new grant systems to use government-wide data standards. These activities are treated as milestones for the purpose of evaluating the commitment.

The three milestones are almost verbatim copies of actions mandated by a 2018 Office of Management and Budget (OMB) memorandum on “Strategies to Reduce Grant Recipient Reporting Burden.” [18] The majority of the commitment text is similarly copied.

Per the memo, the impetus for these milestones—and thus the commitment itself—derives from the Digital Accountability and Transparency Act (DATA) of 2014, which requires OMB to administer a grants pilot to identify new common data standards, to enable efficient reporting, and to provide new solutions that reduce administrative burden on awardees and the government workforce, and subsequently issue guidance to federal agencies on their implementation. [19] This memo fulfilled the ‘issue guidance’ requirement.

The grants pilot was conducted by OMB in conjunction with the Department of Health and Human Services (HHS). [20] HHS was designated as the executing agent of a sub-DATA pilot focused on assistance listings due to its role as the largest grant-issuing entity and managing partner of [21] The assistance listings pilot was carried out from November 2014–May 2017. [22]

Conceptually, the goal of the DATA pilot program was to “identify common reporting elements” required of federal grantees, contractors, and other parties, “as well as [to identify] unnecessarily duplicative or burdensome financial reporting requirements for recipients of Federal awards.” [23] The pilot sought to develop a viable online tool that would “centralize collection of all reporting requirements under the Federal Acquisition Regulation (FAR), rather than require contractors to submit reports to multiple locations and in multiple formats,” and create government-wide data standards that would “increase opportunities for streamlined reporting,” covering data elements, conditions, attributes, and other information required of federal assistance seekers. [24]

OMB’s resulting Report to Congress: Data Act Pilot Program advised establishing a central, open repository for defining and collecting both assistance listings data, as well as the representations and certifications required of assistance seekers.

In the abovementioned memo, OMB gave deadlines for transitioning representations and certifications to SAM, and for using government-wide federal data standards for assistance listings, including: (1) 30 September 2018 for finalizing government-wide core grants management data standards; (2) 30 April 2019 for agencies to submit a plan to OMB that describes their strategy for integrating the new data standards into current and/or future grant systems; and (3) 1 January 2020 for SAM to become the central government-wide repository for representations and certifications. [25]

These activities closely resemble those described in the President’s Management Agenda (PMA) [26] as referenced in the commitment text. The PMA includes a Cross-Agency Priority (CAP) that focuses on “Results-Oriented Data for Grants,” and represents the broader framework for the commitment’s proposed activities. In line with the commitment’s objectives, the PMA will “rebalance compliance efforts,” “standardize grant reporting data and improve data collection in ways that will increase efficiency, promote evaluation, reduce reporting burden, and benefit the American taxpayer.”

Though the commitment describes activities that are largely internal to government functions, the IRM researcher assesses the commitment as relevant for the OGP value of access to information by nature of its efforts to streamline assistance seekers’ ability to access information on—and submit—the required representations and certifications. The commitment is further relevant to the OGP value of technology and innovation for access to information due to its use of SAM as a digital repository and interface for submission of representations and certifications.

As described in the commitment text and in the corresponding section of the 2018 PMA, the commitment’s activities are materially and substantively important given the $700 billion that the U.S. government spends on grants and cooperative agreements, covering roughly 40,000 grant recipients annually, ranging from state and local governments to universities and small businesses. [27] Funding assistance listings comprises roughly 20% of the entire federal budget. [28] Furthermore, federal and nongovernment grant managers spend roughly 40% of their time managing compliance with federal grant requirements, illustrating the burdensome compliance process that impedes grantees’ focus on delivering and measuring results obtained using federally-funded assistance. [29] Moreover, SAM (as of 2017) had roughly one million registered contractors, grantees, and federal officials, published 250,000 procurement opportunities, award notices, and engagement events on a daily basis, and used 200+ standard data elements across 2.2 million contracts awarded annually. [30] Though encompassing a broader range of contracts than assistance listings, this immense scope of SAM representation and certification activities highlights the potential for efficiency gains. Potential efficiency gains are particularly sizeable for assistance listings for states and universities, for whom “federal financial assistance accounts for approximately a quarter and a third of their state and university budgets respectively.” [31]

OMB’s Data Pilot Program report speaks further to the magnitude of the potential time saved by centralizing representation and certification requirements via SAM. A 2014 OMB review found that among 100 FAR reporting requirements, roughly 40% were required to be submitted to “multiple federal contracting officers across the Federal government, in multiple formats, and to multiple agencies.” [32] In a 2014 national open dialogue with 553 stakeholders, participants broadly supported federal efforts to streamline and centralize submission of certifications and representations. [33] A broader pool of 2,039 respondents was invited to vote on dialogue-generated ideas; 30% supported efforts to reduce federal reporting and compliance burdens, and “reduc[ing] duplication in reporting and data collection” received the largest number of votes. [34]

The commitment has a transformative potential impact given the magnitude of compliance burdens currently faced by federal assistance seekers and grantors; the magnitude of the funding and assistance listings affected by the commitment; and the commitment’s potential to substantially reduce compliance burdens by centralizing representations and certifications. The IRM researcher nevertheless notes that a transformative impact may be impeded by the lack of specificity in the commitments’ three activities. Specificity is needed regarding the scope—i.e., which agencies will be covered by these efforts, which grant-making systems will be subject to revised data standards, and which distinctions in types of grants and recipients are currently lacking under existing data standards. Specificity is also needed regarding the activities, such as which data standards are currently not subject to review at their time of publication, and what efforts agencies will take to align their grant reforms with the PMA. Despite these shortcomings, the IRM researcher nevertheless assesses the commitment as having a transformative potential impact based on the potential large-scale gains in compliance efficiency.

[10] SAM is officially defined as the “System for Award Management;” “managements” is an error in NAP4.
[11] Government of the United States, The Open Government Partnership: Fourth Open Government National Action Plan for the United States of America (OGP, Feb. 2019), 2,
[12] System for Award Management, “Learning Center: Assistance Listings” (accessed 8 Mar. 2020), Beyond grants, federal assistance also covers loans, scholarships, and insurance. Id.
[13] SAM is located at Assistance listings are currently housed in a beta version of SAM available at Prior to SAM’s creation in the fourth quarter of fiscal year 2017, federal domestic assistance listings were maintained via the Catalog of Federal Domestic Assistance (CFDA) ( As of 25 May 2018, the CFDA website was retired, renamed “Assistance Listings,” and officially moved to the SAM platform, which currently remains in beta mode. For additional details, see U.S. Dept. of Energy, “PF 2018-32 Catalog of Federal Domestic Assistance (” (18 Jun. 2018), See also System for Awards Management, “Catalog of Federal Domestic Assistance Transition Frequently Asked Questions” (GSA, May 2018),
[14] Government of the United States, Fourth Open Government National Action Plan at 2.
[15] “Entities” include state and local governments, universities, nonprofits, tribes, and small businesses. Office of Management and Budget, “Memorandum for Heads of Executive Departments and Agencies” M-18-24 (White House, 5 Sept. 2018),
[16] Id.
[17] System for Awards Management, System for Award Management Federal User Guide – v.2.5 (25 Jan. 2020), See also Federal Service Desk, “What are Representations and Certifications?” (12 Oct. 2013), See §14.2 for the full SAM representations and certifications questionnaire required of those seeking federal assistance. For the complete FAR, see, “Full FAR Download in Various Formats” (accessed 9 Mar. 2020),
[18] The OMB memo’s first three actions are:


  1. Federal Data Strategy

    US0105, 2019, E-Government

  2. Grants Accountability

    US0106, 2019, E-Government

  3. Public Access to Federally Funded Research

    US0107, 2019, Access to Information

  4. Workforce Data Standards

    US0108, 2019, E-Government

  5. Chief Data Officers

    US0109, 2019, Access to Information

  6. Open Data for Public Health

    US0110, 2019, Access to Information

  7. Enterprise Objective

    US0111, 2019, Capacity Building

  8. Developing Future Action Plans

    US0112, 2019, Public Participation

  9. Reconstitution of the

    US0053, 2015, E-Government

  10. Accessibility of Government Information Online

    US0054, 2015, Marginalized Communities

  11. Access to Educational Resources

    US0055, 2015, Access to Information

  12. Public Listing of Every Address in the US

    US0056, 2015, Access to Information

  13. Informed Decisions About Higher Education.

    US0057, 2015, Access to Information

  14. New Authentication Tools to Protect Individual Privacy and Ensure That Personal Records Go Only to the Intended Recipients.

    US0058, 2015,

  15. Transparency of Open311

    US0059, 2015, E-Government

  16. Support Medicine Research Throught Opening up Relevant Data of the Field

    US0060, 2015, Access to Information

  17. Access to Workforce Data

    US0061, 2015, Access to Information

  18. Using Evidence and Concrete Data to Improve Public Service Delivery

    US0062, 2015, Capacity Building

  19. Expand Use of the Federal Infrastructure Permitting Dashboard

    US0063, 2015,

  20. Consolidation of Import and Export Systems

    US0064, 2015, E-Government

  21. Improving Government Records

    US0065, 2015, Access to Information

  22. Starred commitment Ammendments to FOIA

    US0066, 2015, Access to Information

  23. Streamline the Declassification Process

    US0067, 2015, Capacity Building

  24. Implement the Controlled Unclassified Information Program

    US0068, 2015, Access to Information

  25. Transparency of Privacy Programs and Practices

    US0069, 2015, Capacity Building

  26. Transparency of Federal Use of Investigative Technologies

    US0070, 2015, E-Government

  27. Increase Transparency of the Intelligence Community

    US0071, 2015, Access to Information

  28. Starred commitment Open Science Through Open Data

    US0072, 2015, Access to Information

  29. Open Data Portal

    US0073, 2015, E-Government

  30. Increase Transparency of Trade Policy and Negotiations

    US0074, 2015, E-Government

  31. Develop a Machine Readable Government Organizational Chart

    US0075, 2015, Access to Information

  32. Improving Public Participation

    US0076, 2015, Public Participation

  33. Expand Public Participation in the Development of Regulations

    US0077, 2015, Public Participation

  34. Civic Engagement in Decision-Making Processes

    US0078, 2015, Public Participation

  35. Open Mapping

    US0079, 2015, Access to Information

  36. Tracking OGP Implementation

    US0080, 2015, Public Participation

  37. Strengthening Whistleblower Protection

    US0081, 2015, Anti-Corruption

  38. Transparency of Legal Entities

    US0082, 2015, Anti-Corruption

  39. Extractive Industries Transparency

    US0083, 2015, Anti-Corruption

  40. Spending Transparency

    US0084, 2015, Access to Information

  41. Enhance the Use of U.S. Foreign Assistance Information

    US0085, 2015, Aid

  42. Participatory Budgets and Responsive Spending

    US0086, 2015, Fiscal Openness

  43. Expand Access to Justice to Promote Federal Programs

    US0087, 2015, Access to Justice

  44. Starred commitment Build Safer Communities with Police Open Data

    US0088, 2015, Access to Information

  45. Open Federal Data to Benefit Local Communities

    US0089, 2015, Access to Information

  46. Support the Municipal Data Network

    US0090, 2015, Access to Information

  47. Foster Data Ecosystems

    US0091, 2015, Capacity Building

  48. Extend Digital, Data-Driven Government to Federal Government’S Support for Communities

    US0092, 2015, Capacity Building

  49. Promote Implementation of SDGs

    US0093, 2015, Access to Information

  50. Starred commitment Promote Open Climate Data

    US0094, 2015, Access to Information

  51. Air Quality Data Available

    US0095, 2015, Access to Information

  52. Promote Food Security and Data Sharing for Agriculture and Nutrition

    US0096, 2015, Access to Information

  53. Promote Data Sharing About Global Preparedness for Epidemic Threats

    US0097, 2015, Capacity Building

  54. Promote Global Interconnectivity

    US0098, 2015, Aid

  55. Open Contracting

    US0099, 2015, Access to Information

  56. Harness the Data Revolution for Sustainable Development

    US0100, 2015, Access to Information

  57. Open Government to Support Global Sustainable Development

    US0101, 2015, Anti-Corruption

  58. Open Collaboration Onf the Arctic

    US0102, 2015, Environment and Climate

  59. Support Capacity Building for Extractives Transparency

    US0103, 2015, Anti-Corruption

  60. Support Responsible Investment and Business Practices for Companies

    US0104, 2015, Private Sector

  61. Improve Public Participation in Government

    US0027, 2013, Capacity Building

  62. Modernize Management of Government Records

    US0028, 2013, Records Management

  63. Modernize the Freedom of Information Act

    US0029, 2013, Access to Information

  64. Transform the Security Classification System

    US0030, 2013, Records Management

  65. Implement the Controlled Unclassified Information Program

    US0031, 2013, Security & Public Safety

  66. Increase Transparency of Foreign Intelligence Surveillance Activities

    US0032, 2013, Data Stewardship and Privacy

  67. Make Privacy Compliance Information More Accessible

    US0033, 2013, E-Government

  68. Support and Improve Agency Implementation of Open Government Plans

    US0034, 2013,

  69. Strengthen and Expand Whistleblower Protections for Government Personnel

    US0035, 2013, Anti-Corruption

  70. Increase Transparency of Legal Entities Formed in the United States

    US0036, 2013, Fiscal Openness

  71. Starred commitment Implement the Extractive Industries Transparency Initiative

    US0037, 2013, Access to Information

  72. Make Fossil Fuel Subsidies More Transparent

    US0038, 2013, Anti-Corruption

  73. Starred commitment Increase Transparency in Spending

    US0039, 2013, Access to Information

  74. Increase Transparency of Foreign Assistance

    US0040, 2013, Aid

  75. Continue to Improve Performance.Gov

    US0041, 2013, E-Government

  76. Consolidate Import and Export Systems to Curb Corruption

    US0042, 2013, Private Sector

  77. Promote Public Participation in Community Spending Decisions

    US0043, 2013, Fiscal Openness

  78. Expand Visa Sanctions to Combat Corruption

    US0044, 2013, Anti-Corruption

  79. Further Expand Public Participation in the Development of Regulations

    US0045, 2013, Capacity Building

  80. Open Data to the Public

    US0046, 2013, Access to Information

  81. Continue to Pilot Expert Networking Platforms

    US0047, 2013, Public Participation

  82. Reform Government Websites

    US0048, 2013, E-Government

  83. Promote Innovation Through Collaboration and Harness the Ingenuity of the American Public

    US0049, 2013, Capacity Building

  84. Promote Open Education to Increase Awareness and Engagement

    US0050, 2013, E-Government

  85. Deliver Government Services More Effectively Through Information Technology

    US0051, 2013, E-Government

  86. Increase Transparency in Spending

    US0052, 2013, Access to Information

  87. Reform Records Management

    US0001, 2011, Public Participation

  88. Lead a Multi-Agency Effort

    US0002, 2011, Capacity Building

  89. Monitor Agency Implementation of Plans

    US0003, 2011, Public Participation

  90. Provide Enforcement and Compliance Data Online

    US0004, 2011, Access to Information

  91. Advocate for Legislation Requiring Meaningful Disclosure

    US0005, 2011, Legislation & Regulation

  92. Apply Lessons from Recovery Act to Increate Spending Transparency

    US0006, 2011, Fiscal Openness

  93. Government-Wide Reporting Requirements for Foreign Aid

    US0007, 2011, Access to Information

  94. Use Performanc.Gov to Improve Government Performance and Accountability

    US0008, 2011, Public Participation

  95. Overhaul the Public Participation Interface on Regulations.Gov

    US0009, 2011, Legislation & Regulation

  96. Launch Expertnet

    US0010, 2011, E-Government

  97. Launch International Space Apps Competition

    US0011, 2011, E-Government

  98. Launch “We the People”

    US0012, 2011, E-petitions

  99. Open Source “We the People”

    US0013, 2011, E-petitions

  100. Develop Best Practices and Metrics for Public Participation

    US0014, 2011, Capacity Building

  101. Professionalize the FOIA Administration

    US0015, 2011, Access to Information

  102. Harness the Power of Technology

    US0016, 2011, Access to Information

  103. Advocate for Legislation on Whistleblower Protection

    US0017, 2011, Anti-Corruption

  104. Explore Executive Authority to Protect Whistleblowers

    US0018, 2011, Anti-Corruption

  105. Implement the EITI

    US0019, 2011, Anti-Corruption

  106. Partnership to Build on Recent Progress

    US0020, 2011, Anti-Corruption

  107. Promote Data.Gov to Spur Innovation Through Open Sourcing

    US0021, 2011, Access to Information

  108. Data.Gov: Foster Communities on Data.Gov

    US0022, 2011, Access to Information

  109. Begin Online National Dialogue with the American Public

    US0023, 2011, Public Participation

  110. Update Government-Wide Policies for Websites

    US0024, 2011, Public Participation

  111. Promote Smart Disclosure to Ensure Timely Release of Information

    US0025, 2011, Access to Information

  112. Publish Guidelines on Scientific Data

    US0026, 2011, Access to Information

Open Government Partnership