Recommendations and Actions
Eliminate Needless Paperwork by Simplifying the Compliance Certification Process
States and localities are required to provide assurance of compliance with 18 cross-cutting federal requirements contained in the SF-424, "Application for Federal Assistance," every single time a grant application is submitted to an individual federal agency. In addition, there are other cross-cutting assurances not contained in the Standard Form. These assurances, which consist of two pages in the standard federal grant application for state and local governments, stipulate that the applicant will comply with statutes such as the Civil Rights Act of 1964, the Hatch Act and the Davis-Bacon Act (see Appendix C). States and localities submit thousands of grant applications each year and are currently required to recertify each time.
Thousands of pages of duplicative certifications are being needlessly prepared, processed, and stored every year.
Simplify grant compliance certifications by modifying OMB's requirements. (2)
OMB should modify Circular A-102, "Grants and Cooperative Agreements to State and Local Governments," to require that the common grants management rule provide that all cross-cutting certifications may be submitted by incorporating them by reference into grant applications. Further, OMB should modify the SF-424 to eliminate the assurances and to add the following statement: "By virtue of this signature, the applicant certifies that it: 1) incorporates into the application by reference the cross-cutting assurances contained in the common rule; and 2) will comply with the assurances."
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