Interior guidance for fiscal 2018 grants

The Interior Department has new guidelines for how employees can issue grants and says they must align more closely with the Trump administration’s priorities.

United States Department of the Interior

OFFICE OF THE SECRETARY
Washington, DC 20240

Memorandum DEC 28 2017

To: Assistant Secretaries
Heads of Bureaus and Of?ces

From: Scott Cameron
Principal Deputy Se etary for Policy, anagement and Budget

Exercising the Authority of the Assistant Secretary for Policy, Management
and Budget

Subject: Guidance for Financial Assistance Actions Effective in Fiscal Year 2018

This memorandum requests your assistance to ensure that discretionary grants and cooperative
agreements awarded by the Department of the Interior beginning in FY 2018, better align with
the Secretary?s priorities (Attachment A). The following outlines actions needed to ensure
appropriate review and oversight of the Department?s ?nancial assistance programs.

1. Within two weeks of the date of this memo, bureaus must submit the attached template
(Attachment B) to the Of?ce of Acquisition and Property Management (PAM) listing all
?nancial assistance programs, indicating which are non-discretionary and which are
discretionary. A program is considered non-discretionary if the bureau does not have
legal authority to direct funds for particular purposes or to particular recipients.
Examples of non-discretionary programs are self-determination contracts authorized
under the Indian Self?Determination and Education Assistance Act or the Fish and
Wildlife Service?s Wallop-Breaux and Pittman-Robertson grants to states.

Programs are considered discretionary if the bureau can direct ?Jnds to particular projects
0r purposes, if the bureau can set criteria for evaluating responses to Funding Opportunity
Announcements in order to fund some proposals but not others, and can determine award
recipients. The guidance in the balance of this memo applies to ?nancial assistance in
this discretionary category.

PAM will interact with the bureaus to resolve any uncertainties as to whether a program
should be considered discretionary in the context of this guidance memo.

2. Effective the date of this memo, bureaus must ensure that each discretionary ?nancial
assistance program, to the extent allowed by its authorizing statute, will promote the
priorities listed in Attachment A. To accomplish this goal, assistant secretaries and
bureau directors, in conjunction with Mr. Steven Howke, Senior Adviser to the Assistant
Secretary for Policy, Management and Budget must work with each discretionary
program to set expectations and to develop a plan for program execution. The plan

should include the speci?c language that the program intends to include in its
announcements, including eligibility requirements, merit review factors, and rating
systems. -

3. The Department has a new process for approving discretionary grants and cooperative
agreements.

a.

Grants and cooperative agreements with an individual or aggregate award of
$50,000 to a non-pro?t organization that can legally engage in advocacy that
is an entity organized under sections 501(c)(3), 501(c)(4), 501(c)(5), or 501(c)(6)
of the Internal Revenue Code) must be reviewed by the Senior Adviser to the
Assistant Secretary for Policy, Management and Budget, with a completed
standard form Attachment C-l.
Grants and cooperative agreements with an individual or aggregate award of
$50,000 to an institution of higher education must be reviewed by the Senior
Adviser to the Assistant Secretary for Policy, Management and Budget, with a
completed standard form Attachment C-l.
Grants and cooperative agreements with an award ceiling of $50,000 or more that
are to be used to acquire land, or interest in land, must be reviewed by the Senior
Adviser to the Assistant Secretary for Policy, Management and Budget, with a
completed standard form Attachment
For all other grants and cooperative agreements not covered by paragraphs a, b, or
0 above:
i. Those with a ceiling of less than $100,000 must be reviewed and may be
approved by bureau directors.
ii. Those with an award ceiling above $100,000 but less than $250,000 must
be reviewed and may be approved by the appropriate assistant secretary.
Those with an award ceiling of $250,000 or more must be reviewed and
may be approved by the Senior Adviser to the Assistant Secretary for
Policy, Management and Budget, with standard form Attachment C-2.
Grants and cooperative agreements of any type in any amount may be subject to
an after-the-fact review process to ascertain whether the funds were appropriately
expended and whether the anticipated bene?ts were produced. The Of?ce of
Policy, Management, and Budget (PMB) will review internal control procedures
established by each Bureau and of?ce. These internal control procedures will be
periodically tested to ensure consistent application and adherence.
Instances circumventing the Secretarial priorities or the review process will
cause greater scrutiny and will result in slowing down the approval process for
all awards.

4. The Department?s Of?ce of Communications will develop a process with bureaus and
of?ces to determine which approved grants and cooperative agreements should be
publicized.

5. PMB plans to update Departmental ?nancial assistance policies early in calendar 2018,
and in that process will consult with bureaus and of?ces to ensure that revised policies
enable the Department to consistently better manage the risks associated with awards
provided to third parties.

6. The Senior Adviser and the Assistant Secretaries may work together to make subsequent
modi?cations to the review process described here, with respect to the programs of
individual bureaus.

If you have any questions regarding this memo, please contact Steve Howke, Senior Adviser to
the Assistant Secretary, Policy, Management, and Budget, at 202-208-2883 or
steven

Attachments