Grants Workforce: Actions Needed to Ensure Staff Have Skills to Administer and Oversee Federal Grants

In fiscal year 2017, the federal government awarded approximately $675 billion in grants to state and local governments. GAO was asked to review the federal grants workforce training. GAO reviewed (1) OPM's, OMB's, and the CFOC's actions to address the grants workforce's training needs; (2) the extent to which grants workforce training at selected agencies is consistent with leading practices; and (3) how selected agencies monitor and oversee training of their grants workforce. GAO selected HHS, USDA, and Education and several of their sub-agencies based on their grants spending and numbers of grants management specialists. GAO reviewed OPM and OMB memorandums and guidance, compared selected agency training practices against leading training practices, and interviewed officials.

The Offices of Personnel Management (OPM) and Management and Budget (OMB) and the Chief Financial Officers Council (CFOC) have taken some steps to help ensure the federal grants workforce receives training. For example, OMB worked with the CFOC to issue five basic grants training modules and a “Career Roadmap” for grants managers; however, they did not widely publicize the resources. Many of the officials with whom GAO spoke at selected sub-agencies at the Departments of Health and Human Services (HHS), Agriculture (USDA), and Education (Education) were unfamiliar with the Career Roadmap and made limited use of the training resources. Further, OMB and CFOC do not collect detailed user data or feedback, limiting their abilities to determine the usefulness of these resources.

GAO found that sub-agencies at HHS, USDA, and Education vary in following leading training practices for planning, designing, implementing, and evaluating their grants training programs. Additionally, HHS, USDA, and Education could not readily identify grants management specialists—the 1109 job series—or employees in other job series working on grants without querying each sub-agency. These agencies cannot do so because their central offices do not have a reporting mechanism tracking their sub-agencies' grants workforce. Further, agency central offices do not evaluate sub-agency grants training efforts. Without sufficient monitoring and oversight, the agencies cannot have reasonable assurance that their sub-agencies are sufficiently training their grants workforce so they have the necessary knowledge, skills, and abilities to properly manage, administer, and monitor the billions of dollars that the federal government spends on grants annually.

GAO is making five recommendations including that OMB, working with the CFOC, should (1) publicize the Career Roadmap and (2) collect data metrics and user feedback on its use. HHS, USDA, and Education should establish processes to centrally monitor and evaluate their grants training, including identifying the grants workforce and ensuring consistency with leading practices. HHS and USDA concurred, Education generally concurred, and OMB partially concurred with our recommendations. OPM had no comments on the report.

In fiscal year 2017, the federal government awarded approximately $675  billion in grants to state and local governments for a wide variety of  purposes, including rural development programs such as housing  assistance and business development; health and social services, such  as the Children’s Health Insurance Program and mental health services;  and education, such as hiring and training teachers and increasing  student access to higher education. Federal grants play an important role  in achieving national objectives and have grown considerably in value  and complexity over the past three decades. Therefore, it is important  that the federal workforce that manages, administers, and monitors grants  has the necessary knowledge, skills, and abilities to perform these  functions effectively.

The important role that training plays in the effective management of  grants can be seen, for example, in the fact that in December 2017, the  Council of the Inspectors General on Integrity and Efficiency identified  “grants oversight” as one of six critical issues in the federal government.  The Council reported that grant subject matter experts “noted that the root  of many problems with grant awards was a lack of resources and training  on both sides of the grant process.”

You asked us to review the training provided for the grants workforce.  This report reviews (1) the actions the Office of Personnel Management  (OPM), the Office of Management and Budget (OMB), and the Chief  Financial Officers Council (CFOC) have taken to address the need for  federal grants management training; (2) the extent to which grants  workforce training at selected agencies is consistent with selected leading  training practices; and (3) how selected agencies monitor and oversee  training of their grants workforce. In addition, we provide information on  certification standards for the grants workforce, including a comparison to  the federal acquisition workforce, in appendix I.

To address the first objective, we reviewed OPM and OMB  memorandums and government-wide grants training resources. We also  interviewed OPM and OMB staff responsible for strategic workforce  planning and financial management, respectively, to obtain information on  their roles and responsibilities for federal grants management training,  among other topics. In addition, we used data from OPM’s Enterprise  Human Resource Integration (EHRI) system to report government-wide  data on the grants management specialist 1109 job series. The 1109 job  series is a classification for those federal employees whose job  responsibilities primarily involve management of grants. To determine the  reliability of the EHRI data, we reviewed EHRI documentation and  interviews from a previous GAO engagement completed in October 2016.  We found no significant changes to the EHRI data reporting process and  determined the EHRI data were sufficiently reliable for the purposes of  this review.

We identified training resources developed by the agencies and  requested “Grants Training 101” and “Career Roadmap” website metrics  from OMB on the total usage of these grants management resources.  “Grants Training 101” is an introductory online course designed by OMB  to provide a basic knowledge of grants and cooperative agreements and  the “Career Roadmap” is a resource for workforce development and  career progression of the federal financial assistance management  workforce. OMB provided (1) user and course completion data for Grants  Training 101 between December 2015 and November 2017 and (2) the  number of users and user sessions collected for the Career Roadmap  Report website between September 2017 and January 2018.

To select agencies for our review, we obtained and analyzed fiscal year  2016 spending data from USAspending.gov. We selected the  Departments of Health and Human Services (HHS), Agriculture (USDA),  and Education (Education) for review primarily because the total  combined federal grant awards for these three agencies was 79 percent  of all federal grant awards reported in fiscal year 2016. We also  considered the number of 1109 job series employees in our agency  selection. We selected HHS and USDA because they had the highest  number of 1109 job series employees and selected Education because,  while it was one of the largest grant-making agencies, it had no  employees classified in the Grants Management Specialist 1109 job  series.

We also selected a total of 11 sub-agencies from HHS, USDA, and  Education for our review primarily based on the size of their grant awards  and the number of grants workforce employees in the 1109 and non-1109  job series.

For HHS, we selected the Centers for Medicare and Medicaid  Services, Administration for Children and Families, National  Institutes of Health, and Health Resources and Services  Administration. When combined, these four sub-agencies  represented 97 percent of the total HHS fiscal year 2016 grant  award amounts. The combined grants workforce for selected sub- agencies also represented 76 percent of the total 1109 job series  and 61 percent of the total HHS grants workforce employees.

For USDA, we selected the National Institute of Food and  Agriculture, Forest Service, Rural Development, and Food and  Nutrition Services. Collectively, these four sub-agencies  represented 97 percent of the total USDA fiscal year 2016 grant  award amounts. The combined grants workforce for selected  USDA sub-agencies also represented 77 percent of the total 1109  job series and 95 percent of the total USDA grants workforce  employees.

For Education, we selected the Office of Elementary and  Secondary Education, Office of Special Education and  Rehabilitative Services, and Office of Postsecondary Education.  Together these three sub-agencies represented 93 percent of the  total Education fiscal year 2016 grant award amounts. The  combined grant workforce for selected sub-agencies represented  74 percent of the total Education grants workforce employees.

To better understand federal grants workforce training at the selected  agencies and sub-agencies, we asked HHS, USDA, and Education  officials for internal data on all sub-agency grant awards and the number  of 1109 and non-1109 job series employees working on grants at each  sub-agency. We provided each of the selected agencies and sub- agencies with the specific definition for identifying the grants workforce  that was used in our 2013 report on grants management training.

Our second and third objectives compared agencies’ training practices  described in agency interviews and documents against selected leading  practices we identified in our prior work, including our online Best  Practices and Leading Practices in Human Capital Management, our  2004 Human Capital Guide on training, and Standards for Internal Control  in the Federal Government, for monitoring, evaluation, and oversight.  The Human Capital Guide is organized into four components of the  training and development process—planning, design/development,  implementation, and evaluation. We selected the practice from each  component that is most relevant to grants workforce training to compare  against current agency training practices. In developing the Human  Capital Guide, we noted that users of this guide should keep in mind that  the guide can and should be modified to fit the unique circumstances and  conditions relevant to each agency.

We conducted this performance audit from February 2017 to September  2018 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

Training Is Important for Effective Grants Management

In fiscal year 2017, the federal government awarded approximately $675  billion in grants to state and local governments. As shown in figure 1,  approximately 80 percent of the grant dollars awarded by the federal  government in fiscal year 2017 came from the three agencies we  reviewed for this report—HHS, USDA, and Education.

A range of skills are needed to manage the various tasks associated with  the grants lifecycle. For example, during the award phase, grant staff at  federal grant-making agencies are to send all grantees a grant award  notification that provides details about the grant, including the amount of  the award; and the general terms and conditions of the grant, including  statutory and regulatory requirements. Figure 2 below illustrates the four  distinct phases of the grants lifecycle.

Given the billions of dollars in federal grants funding that are awarded  every year, effective training could help provide grants managers with the  skills and competencies they need to better manage and oversee those  dollars. As one example of the importance of rigorous grants  management and training, in April 2017 we found that Education grants  staff inconsistently documented key required monitoring activities and, as  a result, about $21 million in discretionary grants lacked the correct  documentation of grantee performance. We recommended that  Education establish and implement detailed written supervisory review  procedures for official grant files to provide reasonable assurance that  grant staff perform and document key monitoring activities. Education officials agreed with the recommendation and said they would develop a  department-wide standard operating procedure (SOP) that will, among  other things, provide standards for timeliness of documenting key  monitoring and administrative activities and require the periodic review of  grant files. Officials expect to complete the SOP by September 30, 2018.

In 2011, OMB established the Council on Financial Assistance Reform  (COFAR), an interagency group of executive branch officials with the  stated aim of creating a more streamlined and accountable structure to  coordinate financial assistance, including grants. In 2012 and again in  fiscal years 2016 and 2017, COFAR identified the need to develop a  qualified and professional workforce as one of six priorities to guide its  work on grants management reform. According to OMB staff, they  disbanded COFAR on June 15, 2017 as part of OMB’s efforts to reduce  grants-related requirements once COFAR had recommended policies and  actions to effectively deliver financial assistance. COFAR’s  recommendations resulted in the Uniform Administrative Requirements,  Cost Principles, and Audit Requirements for Federal Awards, which is  intended to improve performance, transparency, and oversight for federal  awards.

Moving forward, the responsibility of coordinating financial assistance  priorities was given to the Chief Financial Officers Council (CFOC), a  group of 24 agency chief and deputy chief financial officers that work  together to improve financial management in the U.S. government.  According to OMB staff, the controller of OMB’s Office of Federal  Financial Management is the chair of the CFOC. In addition, OPM is  responsible for providing leadership and guidance over federal agency  training to ensure the effective promotion and coordination of federal  agency training programs and operations. Further, the President’s  Management Agenda established “results-oriented accountability for  grants” as a cross-agency priority goal to “maximize the value of grant  funding by applying a risk-based, data-driven framework that balances  compliance requirements with demonstrating successful results for the  American taxpayer.”

Certification Standards for the Grants Workforce

In 2013, we examined grant workforce and training issues and found  there were no specific government-wide training requirements for the  federal grants workforce. As of June 2018, this continued to be the  case. By contrast, there are government-wide training requirements for  the acquisitions workforce intended to help ensure its quality and  effectiveness. For example, OMB’s Office of Federal Procurement Policy  (OFPP) provides government-wide guidance on managing the  acquisitions workforce. The Federal Acquisition Institute, which  coordinates with the OFPP, promotes the development of the civilian  acquisitions workforce. Further, OFPP has developed Federal  Acquisition Certification requirements for acquisition professionals serving  as contracting staff, contracting officer’s representatives, and  program/project managers. Notably, in fiscal year 2017, the federal  government spent approximately $166 billion more on grants to state and  local governments than it did on federal acquisitions. OMB staff explained that the acquisitions workforce faces more requirements  because contracts have more uniform requirements and are specified in  law. They stated that grants, on the other hand, are diverse and are  established by individual statutes with varying conditions.

Our work in the acquisitions area identifies the importance of providing  reasonable assurance of an appropriately trained staff through  certification. Certification programs are designed to ensure that  individuals attain the knowledge and skills required to perform in a  particular occupation or role by establishing consistent standards. For  example, for the acquisition workforce, OFPP requires a minimum set of  career-specific courses, along with education and experience  requirements, to obtain certification. To ensure acquisition professionals  remain current on acquisition policies and practices, OFPP also requires  the acquisition workforce to meet continuing learning requirements. See  appendix I for a comparison of training for the federal acquisition  workforce versus the federal grants workforce.

Education, HHS, and USDA delegate the decision to their various sub- agencies of whether grants employees should obtain professional grants  certifications. Of the 11 sub-agencies we reviewed, 3 at HHS—the  Centers for Medicare and Medicaid Services Discretionary Grants Office,  the Health Resources and Services Administration, and the National  Institutes of Health—and 2 at Education—the Office of Special Education  and Rehabilitative Services and the Office of Post-Secondary  Education—required certification of some of their grants employees.  Officials at the remaining 6 sub-agencies offered certification to their  grants employees on an optional basis. USDA sub-agency officials said  they often recommend the certificate program to their grants employees,  and Education’s sub-agency officials at the Office of Elementary and  Secondary Education said they nominate staff to take the grants  certificate program whom they believe would benefit the office most by  receiving the training.

While COFAR officials explored the possibility of establishing certification  standards for the grants workforce by September 2015, OMB staff said  they determined that certification was not the most appropriate course of  action for the grants workforce for several reasons including risk  management and internal control concerns and the need for a variety of  skills for the grants workforce. As previously mentioned, OMB disbanded  COFAR in June 2017, and CFOC took over COFAR’s responsibilities.  When we spoke with OMB staff in the fall of 2017, they said their focus  had shifted from establishing certification standards for the grants  workforce to providing guidance on needed competencies and enabling  the grants workforce to obtain them.

OPM, OMB, and CFOC Have Taken Some Steps to Help Provide Grants Training but Have Opportunities for Further Improvements

OPM, OMB, and CFOC Developed a Grants Competency Model Among Other Steps

OPM, in consultation with OMB and the CFOC, took several steps to  ensure the federal grants management workforce has access to grants  management competencies and training. For example, OPM identified  grants management competencies that could be used in agency efforts  for workforce planning, training and development, performance  management, recruitment, and selection. After establishing grants  management competencies, OPM officials told us they established the  1109 job series partly because OMB and CFOC staff requested a new  grants management job series in response to the increased grant awards  and staffing needs created because of the 2009 American Recovery  Act. Figure 3 illustrates the timeline of the main steps taken by OPM,  OMB, and CFOC over the last decade.

In 2008, OPM initiated a government-wide study to identify critical  competencies for grants management work. After the government-wide  study was completed, OPM issued a memorandum to all federal agencies  announcing a grants management competency model that included  general competencies such as accountability, writing, and computer  skills. OPM also included technical competencies such as grants  management, financial analysis, and compliance. In our prior work, we  found that grants management competency models can be used to  establish an overall framework to guide agencies’ training efforts.

Before OPM established the 1109 job series in 2010, no other agency- specific job classification series existed for the many federal employees  responsible for carrying out managerial and administrative tasks related  to grants, including ensuring compliance with OMB and agency policies  and procedures. In the absence of a specific job classification, we  reported in 2013 that officials at selected agencies told us they had  classified these employees under a variety of other job series that did not  focus on grants, such as general, administrative, and subject-matter job  titles.

According to OPM officials, the agency’s development of the “Position  Classification Flysheet for the Grants Management Series (1109)”  leveraged the competencies and tasks from the Competency Model for  Grants Management and input from federal agencies’ subject matter  experts on grants management work.The Flysheet includes a job series  definition, a basic job title, general occupational information, and a link to  the position classification standard. The 1109 job series manage,  supervise, lead, or perform administrative business, policy, and analytical  work involving the: (1) management, award, or obligation of funds for  grants; (2) competitive or non-competitive evaluation of grants proposals;  and/or (3) administration or termination, and/or closeout of grants and/or  grants assistance and agreement awards. The work requires knowledge  of laws, regulations, rules, policies, procedures, and financial methods to  help ensure accountability of the grant funds.

As of fiscal year 2016, grant-making agencies reported 2,035 federal  employees in the 1109 job series, and HHS reported 38 percent of those  employees (see figure 4). We used fiscal year 2016 data to determine the  agency-wide numbers of 1109 job series employees because this was the  most recent set of full year data available at the time of our analysis.

The federal grants workforce also includes a wide range of employees in  other non-1109 job series positions. OPM does not collect data on grants  workforce employees in these other job series positions as they span a  large number of different job series that can vary by agency. Non-1109  employees working on grants typically possess expert knowledge in the  specific area necessary to meet a grant’s goals (e.g., announcing the  terms and conditions of a grant, recommending potential grantees, and  monitoring grantees’ progress in achieving the grants goals). Reflecting  the wide variety of federal programs that grants support, these individuals  typically possess expertise in a specialized program or subject.

A number of factors affect usage of the 1109 job series within agencies.  According to OMB staff, various agency employees have told them that  many agency employees would rather be classified as a subject matter  specialist, such as a scientist, rather than a grants management specialist  whose primary tasks are grants management under the 1109 job series.  In addition, OMB staff said that some agencies preferred recruiting staff  using a more general non-1109 job series classification. OMB staff also  said that some agencies indicated their grants workforce employees do  not want to be classified as grants specialists because the other job  series are more general and are a better fit in terms of the needed subject  matter expert skills and duties.

We found that one of our selected agencies, Education, does not use the  1109 job series at all because, according to Education sub-agency  officials, they require grants employees to have specialized grant program  content knowledge in the field of their grant program focus, such as  rehabilitation, special education, behavior science, and other areas (e.g.,  standards and assessments, state accountability systems). The sub- agency officials said that 1109 grants management specialists would not  have the specific content knowledge and experience associated with the  specific educational grant programs that Education requires. We also  found that over 61 percent of HHS grants workforce employees and over  90 percent of the USDA grants workforce was not part of the 1109 job  series.

OPM officials told us that, in April 2017, they started a government-wide  Grants Management Post Classification Implementation Study that may  change the Grants Management Classification Flysheet and revalidate  the Competency Model for Grants Management Work. OPM officials  developed the study after meeting with grant-making agency HHS and  will include a survey of the grants management workforce government- wide. OPM officials also stated they are in the final stages of developing  and clearing the government-wide survey and anticipate issuing it in the  fall of 2018. They said the study will take several additional months to  complete because the team must review the results of the government- wide survey and update competencies, job classifications, and  compliance policy/requirements.

OMB and CFOC Have Provided Some Grants Training and Guidance, but Use Has Been Limited Among Selected Agencies

OMB’s role with the grants management workforce includes issuing  government-wide guidance and providing a framework that enables  agencies to take actions to align their grants training with OMB’s internal  control standards. In this role, OMB has taken some actions to provide  grants guidance for federal agencies that include the Career Roadmap  Report, Career Roadmap Builder, and Grants Training 101. However, we  found that almost all of the officials we interviewed at the 11 selected sub- agencies were not familiar with the Career Roadmap Report and Career  Roadmap Builder. Additionally, almost all of them did not mention using  Grants Training 101 as part of their grants workforce training.

OMB, in collaboration with the CFOC, COFAR, and federal awarding  agencies, developed the Financial Assistance Career Roadmap Report in  June 2017. OMB staff said that the Career Roadmap Report is one  vehicle used to address grants training for the federal agency grants  workforce. It is a tool for federal agencies to identify and document the  competencies needed for successful job performance of federal financial  assistance management professionals. According to the CFOC, the  competencies and related elements outlined in the Career Roadmap  Report are to be used to identify and prioritize training needs for the  federal financial assistance management workforce. This is an optional  tool for the federal grants workforce and may be customized to reflect an  organization’s unique requirements and specifications. That workforce  includes the grants management 1109 job series employees, as well as  employees performing grants responsibilities as program, finance, and  audit experts who are classified under other job series.

During the initial development of the Career Roadmap Report, a team  consisting of OMB staff and industrial and organizational psychologists  collected financial assistance research and documentation from OMB,  federal awarding agencies, and OPM. The team analyzed this information  to identify foundational competencies and create a draft competency  model which OMB reviewed. The team also facilitated two workshops  with specialists on financial assistance management to gather feedback  on the Career Roadmap Report. Figure 5 below shows the 14 different  competencies from the Career Roadmap Report that are divided into two  types of competencies: functional and leadership.

After the report’s release, CFOC developed and released an interactive  version called the Career Roadmap Builder available to the public  online. This version allows users to build their own customized financial  assistance management Career Roadmap based on their specific mission  and needs. To obtain a custom Career Roadmap Report, users complete  several steps in the Career Roadmap Builder involving selection of one or more of nine functional competencies; one or more of three job levels (foundational, practitioner, or one of three proficiency levels for each functional competency  (basic, intermediate, or advanced); an option to include a leadership competency; and one of three different leadership levels (entry, mid, or senior) and  a leadership proficiency rating (basic, intermediate, or advanced).

The user then receives a customized report with relevant competencies,  career levels, a sample of the associated developmental experiences and  recommended training courses.

Department-level officials we spoke with at HHS, USDA, and Education  were familiar with the Career Roadmap Report. However, almost all of the  officials we interviewed at the 11 selected sub-agencies were not aware  the Career Roadmap Report was available to them.

All but one of the officials we spoke with at four HHS sub-agencies  said they were unaware of the Career Roadmap Report and grants  management competencies.

While USDA’s agency-wide Federal Financial Assistance Committee  received a copy of the Career Roadmap Report in August 2017 and  discussed it at their monthly meetings, almost all of the officials at the  four USDA sub-agencies we reviewed said they had not received it.  However, three sub-agency officials were familiar with the report  because they had been involved with agency-wide efforts to provide  grants management competency support and information. All other  USDA sub-agency officials with whom we spoke were unfamiliar with  the Career Roadmap Report or the grants workforce competencies.

Almost all of the officials we interviewed at three Education sub- agencies were unaware of the Career Roadmap Report. However,  one official from one sub-agency was familiar with the Career  Roadmap Report as he had been part of the Career Roadmap Report  development process.

OMB staff stated they publicized the report by sending a “Controller Alert”  on July 3, 2017 to agency chief financial officers and to members of the  Financial Assistance Committee for E-Government notifying them of its  availability and OMB’s future plans to map it to existing training  resources, place it on OPM’s website, and develop an online interactive  tool including position competencies. However, we found it difficult to  locate the “Controller Alert” on the COFC website as it is not located on  the same tab where the Career Roadmap Report is published but instead  in a news section that users may not know to search. Further, OMB’s  “Controller Alert” states that it “does not constitute official guidance or  prescribe specific tasks for agencies beyond consideration of appropriate  steps to address the issue.” OMB did not issue any official government- wide memorandums to explain that it supported the Career Roadmap  Report, or that the report included updated competencies for both the  1109 and non-1109 job series workforce.

Our internal control standards state that management should internally  communicate the necessary quality information to achieve the entity’s  objectives. However, if all levels of an agency are not aware of  government grants workforce competencies and guidance, the agency  may not be able to ensure that grants workforce employees have the  training resources needed to develop and maintain skills to achieve the  objectives of grant awards.

OMB also worked with federal grant-making agencies, COFAR, and the  CFOC to establish Grants Training 101, a set of five online training  modules designed to provide federal officials a basic knowledge of grants  and cooperative agreements. According to OMB staff, the Grants Training 101 webpage states that the training is not designed to provide detailed  administrative, accounting, and audit requirements specific to statutory  provisions, agency regulation, and guidance because agencies need to  have flexibility in designing grants training programs to meet those grant- specific statutory requirements. OMB staff said they designed the training  modules in response to a request from the federal grants community for a  government-wide grants management training resource to ensure some  level of consistent training among grant-awarding agencies. In addition,  OMB staff said it was optional for agencies to incorporate Grants Training  101 into established grants training and that each agency is responsible  for the means by which they conduct grants management training.

Only one of the agencies we reviewed had plans to include OMB’s Grants  Training 101 as part of its grant-training program. HHS officials said they  are developing an internal online grants 101 course and plan to  incorporate parts of OMB’s Grants Training 101. However, most agency  and sub-agency officials we spoke with did not use OMB’s Grants  Management 101 as part of their grants workforce training. OMB staff  said that Grants Management 101 modules cover the grant lifecycle and  the requirements of the Uniform Guidance, and are intended to  complement other trainings that agencies provide to their grants  managers. OMB staff said that agencies make the decision whether to  use the Grants Training 101 modules and can integrate parts of the  training modules into their agency- specific training requirements. For  example, officials at one of the agencies—Education—stated they cover  many of OMB’s Grants Training 101 learning objectives through their  cross-cutting grant training program courses as well as sub-agency  specific training. Furthermore, OMB staff said that each agency would  have to internally monitor grants employees’ completion of the grants  training modules.

OMB and CFOC Do Not Collect Detailed User Data or Feedback to Determine Usefulness of Grants Training and Guidance

OMB staff told us that OPM initially had the responsibility of hosting the  first two modules of Grants Training 101 on the OPM website while the  remaining three modules were under development. After these remaining  modules were completed, all five of the modules were moved to the  CFOC webpage. In addition, OPM was responsible for collecting the  Grants Training 101 user and completion data. OMB provided us the  Grants Training 101 data which totaled 1,277 users registered between  December 2015 and November 2017; however, we found that the data  were incomplete due to missing data fields.

OMB staff stated that the Grants 101 training website was moved to the  CFOC webpage so the general public can access it. The CFOC will not  collect data on the access dates, the agency names, or the number of  Grants Training 101 users; however, the CFOC will collect data on the  number of visitors that go to the Grants Training 101 website. OMB staff  also said that agencies can decide to track Grants Training 101 users  internally because OMB and the CFOC will not collect specific data on  users. In addition, OMB staff said OMB and CFOC have not collected any  formal Grants Training 101 feedback from users and have no plans to do  so. OMB reported that a total of 175 visitors went on the Career Roadmap  Report website between September 2017 and January 2018.

Our Standards for Internal Control in the Federal Government advise  management to process data into quality information that is appropriate,  current, complete, accurate, accessible, and provided on a timely basis.  It further states that management should also evaluate the processed  information and revise when necessary so that it can be used to make  informed decisions. In addition, our 2004 Human Capital Guide states  that it is increasingly important for agencies to be able to evaluate their  training and development programs to demonstrate how these efforts  help develop employees and improve the agencies’ performance. As  part of this approach, the Human Capital Guide also states that assessing  training and development efforts should consider feedback from  employees.

OMB, CFOC, and COFAR devoted time and multiple resources to  developing the Career Roadmap Report to identify and document the  competencies needed for successful job performance of federal financial  assistance management professionals. Obtaining more detailed user  information and regular feedback from federal agencies on the usefulness  of the Career Roadmap Report and the online Career Roadmap Builder  could help OMB and CFOC to evaluate the effectiveness of these grant  training tools. In addition, obtaining user information and feedback from  federal agencies on the usefulness of Grants Training 101 can also help  OMB and CFOC evaluate its effectiveness.

HHS, USDA, and Education Vary in Following Selected Leading Training Practices

In 2004, we issued a framework of principles and key questions that  federal agencies can use to ensure that their training and development  investments are targeted strategically and are not wasted on efforts that  are irrelevant, duplicative, or ineffective. Our framework identifies four  components of the training and development process: (1) Planning, (2)  Design and Development, (3) Implementation, and (4) Evaluation. Within  each component, the guide identifies leading practices and questions for  agencies to consider when assessing each of these four components. We  compared current grants training practices at the selected agencies and  sub-agencies with selected leading training practices from the guide. We  found variation among sub-agencies in following those selected training  practices.

Planning: skills and competencies assessment. In our guide, we  stated that effective workforce planning and training begins with a skills  and competency assessment. A leading practice under this component is  that agencies use an organization-wide knowledge and skills inventory  and industry benchmarks to help identify performance problems in their  workforces. We stated that workforce planning should entail the  collection of valid and reliable data on such indicators as distribution of  employees’ skills and competencies.

Officials we interviewed at all the selected sub-agencies explained that  grants training needs are primarily identified by grants management  supervisors or self-identified by grants workforce employees. The training  needs are identified on an ad hoc basis during (1) manager evaluations or  observations of employee performance, (2) annual and semiannual  performance assessments, and (3) employee career individual  development plans.

When it came to implementing a more rigorous process involving a  knowledge and skills inventory or the collection of valid and reliable data,  we found varied use among the 3 agencies and 11 sub-agencies with  only some employing such a method.

The four HHS sub-agencies we reviewed assess new grants  workforce employees’ knowledge, skills, and abilities by identifying  skills gaps when onboarding new grants workforce employees,  through supervisor observation of employee performance, or  employee feedback.

In fiscal year 2015, USDA’s Food and Nutrition Service (FNS)  sub-agency started holding monthly meetings with its Regional  Grants Management Division Directors to identify national training  needs for its grants management staff. In fiscal year 2017, FNS  also conducted a nationwide qualitative survey of its grants  employees to identify training gaps and needs. The remaining  three sub-agencies we reviewed informally identify skills gaps and  training needs through ongoing discussions between supervisors  and grants employees and during annual performance  evaluations.

Officials from Education’s central Learning and Development  office stated they issue a department-wide competency  assessment and training needs assessment to the various  department sub-agencies annually or bi-annually. Officials from  Education’s Office of Elementary and Secondary Education sub- agency told us they also conduct their own grants workforce  learning needs assessment examining grants tasks, content  knowledge, and general skills. Officials at the other two Education  sub-agencies told us they assess skills gaps and training needs  through ongoing discussions between supervisors and grants  employees, supervisor observation of employee performance, and  also during annual performance evaluations.

Without a formal knowledge and skills inventory or collection of valid and  reliable data on the grants workforce’s skills and competencies, some  sub-agencies may be limited in identifying performance problems,  competency gaps, and training needs in their grants workforce.

Design and development: using a mix of approaches, sources, and  delivery. Design and Development involves identifying specific training  and development initiatives that the agency will use, along with other  strategies, to improve individual and agency performance. One of the  leading practices under this component is choosing the most appropriate  mix of centralized and decentralized management of training programs;  internal and external training sources; and training delivery mechanisms  (e.g., classroom, computer-based, on the job, etc.). All three agencies  provide the majority of their grants training at the sub-agency level. In  most cases, the sub-agencies use a mix of training sources and delivery  methods in developing and implementing their grants training programs,  including identifying training needs and training content, as detailed in  appendix III.

HHS and USDA primarily use decentralized approaches to grants training  while Education uses a hybrid approach of centralized and decentralized  grants training.

Although there is no overarching grants training program across  HHS, the department’s central offices provide topic-specific  training to Chief Grants Management Officers (CGMO) within  each sub-agency on an ad hoc basis as new grant policies or  requirements are developed. CGMOs then decide how to  disseminate this information within their respective sub-agencies  (e.g., through webinars, teleconferences, or ad hoc trainings). An  HHS council comprised of CGMOs also meets on a quarterly or  biannual basis to discuss new grants policy and requirements.  Further, HHS’s central grants offices are developing a  foundational “Grants 101” course to help standardize a baseline of  grants knowledge across all of HHS’s sub-agencies, which they  expect to complete by November 2018. Currently, the sub- agencies provide the majority of grants-specific training, which  focuses on grants topics and mission requirements relevant to  their specific areas.

USDA’s Office of Chief Financial Officer (OCFO) provides some  required training courses across the agency such as suspension  and debarment and federal appropriations law training; however,  these trainings are not specific to just the grants workforce  employees. The sub-agencies provide all grants-specific training.

Of the three selected agencies, Education provides the most  central office training. For example, Education’s OCFO provides  agency-wide training on discretionary and formula grants financial  and budgetary courses; Learning and Development provides  introductory grant courses; and Risk Management Services  provides risk-based grants training covering topics including cost  analysis, budgetary review, monitoring grants, and uniform  guidance. Additionally, Education’s sub-agencies provide mission-  and program-specific grants training to augment the centrally  provided trainings.

Centralized and decentralized training approaches may present different  advantages for agencies and sub-agencies. On the one hand, efficiencies  may be achieved by centralizing the design and delivery of some grants  training that has widespread applicability throughout the agency.  Additionally, if each sub-agency is responsible for implementing its own  grants training program, the potential exists for inconsistent grants  workforce training across the agency. On the other hand, each sub- agency is able to tailor the training to its own needs when it manages and  provides the training itself. In making this decision, it is important for  agencies to carefully analyze and consider trade-offs.

Implementation: establishing agency-level accountability.  Implementation involves ensuring effective and efficient delivery of  training and development opportunities in an environment that supports  learning. One of the leading training practices under this component is an  agency organization that is held accountable, along with the line  executives, for the maximum performance of the workforce. According to  our Human Capital Guide, there are different ways of ensuring  accountability, including establishing clear lines of authority in agency  policies, issuing agency-wide guidance to ensure consistency, and  establishing a central oversight office, among others.

We found variation among the three selected agencies in following this  leading training practice with HHS and Education having some agency  level of accountability but USDA having less.

HHS’ central Office of Grants Policy, Oversight, and Evaluation  assigns desk officers to work with sub-agency CGMOs in helping  them understand available training resources and needs. HHS  also has an Executive Committee for Grants Administration Policy  Council that meets quarterly to discuss regulations, policies, and  grants administrative requirements. This committee is made up of  CGMOs from each HHS sub-agency. HHS describes the roles of  officials involved in overseeing grants management in an agency- wide grants policy manual.

USDA has not defined roles for central offices to hold them  accountable for grants training. While its central OCFO provides  some guidance on federal financial assistance policies and grants  terms and conditions, and ensures department-wide training  requirements are met, USDA has no agency-wide grants training  guidance, no agency-wide grants manual, or a central office that  oversees grants training at the component level.

Education officials stated that the agency has two agency-wide  grants policy manuals and some Education offices have roles in  overseeing grants training. For example, the central Learning and  Development office provides some oversight of employee  development, training programs, and providers. Further,  Education officials stated that Risk Management Services  oversees Education’s licensure training program across the sub- agencies, and OCFO provides agency-wide training on financial  management of grants.

Holding a central office accountable for grants training can provide  agencies with reasonable assurance that training is being delivered  efficiently and effectively and that grant staff have sufficient  developmental opportunities. In this way, agencies can better ensure the  maximum performance of the grants workforce.

Evaluation: using data to assess training results. Evaluation involves  assessing the extent to which training and development efforts contribute  to improved performance and results. A selected leading training practice  under this component is the use of performance data (both qualitative and  quantitative measures) to assess the results achieved through training  and development efforts.

The three agencies we reviewed primarily conduct evaluation at the sub- agency level. The sub-agencies vary as to how they carry out their  evaluations and few use any quantitative performance measures to  determine if training was successful.

HHS officials stated the central offices do not measure the  effectiveness of training, nor is there centralized information  sharing on how well training works. Officials at the HHS sub- agencies we reviewed told us they primarily use informal feedback  such as ongoing conversations between employees and  supervisors after training completion and supervisor observations  of employee performance to determine if grants training is  successful. Officials at HHS’ Health Resources and Services  Administration also said they receive data regarding employee  scores on required grants training courses. Some HHS sub- agencies use an external vendor for some grants training and  employees complete a survey at the end of each of these courses,  but HHS officials do not see those results. HHS officials rely on  employee feedback after training completion to determine if  external vendor training is effective.

Officials at the USDA sub-agencies we reviewed told us they  primarily use informal feedback through supervisory review of  employee performance and employee individual development  training plans; internal local level reviews and audits of grant  processes; and some course completion surveys.

Officials at Education’s central Learning and Development office  told us they conduct electronic course evaluation surveys. Officials  at the Education sub-agencies we reviewed told us they primarily  use informal feedback from employees, supervisor observation of  an employee’s progress after training, and some course  evaluations.

While informal, qualitative feedback from employees taking grants training  is useful, it is not quantifiable or measurable. Using a balanced approach  that reflects feedback from employees as well as organizational results is  more effective in terms of evaluating the usefulness of grants training  efforts.

Many of the issues discussed above regarding following leading training  practices stem from limited oversight of the sub-agencies, which we  describe in the next section.

Selected Agencies Provide Limited Monitoring and Oversight of Sub- agencies’ Grants Training Efforts Selected Agencies Cannot Readily Identify All Employees Working on Grants and Provide Limited Oversight of Sub- Agencies’ Grants Training Efforts

As previously mentioned, the federal grants workforce consists of  employees in the OPM Grants Management Specialist 1109 job series as  well as employees in various other OPM job series (referred to as non- 1109s in this report). HHS and USDA both employ 1109s as well as non- 1109s in their respective grants workforces while Education only employs  non-1109s. According to HHS, USDA, and Education officials, each sub- agency is responsible for identifying its grants workforce employees and  ensuring they receive needed grants training. However, the central offices  do not have a reporting mechanism tracking sub-agencies’ grants  workforce. After querying each sub-agency, at our request, officials from  the three agencies provided us with data on 1109 and non-1109 grants  personnel. As figure 6 shows, the majority of grants personnel at the  three agencies we reviewed are non-1109 employees.

Standards for Internal Control in the Federal Government state that,  “Management should demonstrate commitment to recruit, develop, and  retain competent individuals.” Furthermore, internal controls state that  “management evaluates competence of personnel across the entity in  relation to established policies.” Since the agencies we reviewed cannot  readily identify their total grants workforce, they have limited ability to  evaluate the competence of grants personnel across the entity to ensure  they are receiving needed training.

Since the three agencies we reviewed do not centrally monitor their sub- agencies’ identification of grants employees, they cannot readily identify  the agency’s total grants workforce. Consequently, the selected agencies  do not have reasonable assurance that all employees working on grants  across their agency are receiving needed grants training and have the  necessary knowledge, skills, and abilities to properly manage, administer,  and monitor grants.

Central offices at HHS, USDA, and Education provide limited oversight of  the types of training sub-agencies provide to their grants workforce. Our  Human Capital Guide identifies having an agency organization that is  held accountable, along with the line executives, for the maximum  performance of the workforce as a leading practice. Further, the guide  states that the agency’s training organization and line executives should  work together to establish control mechanisms to ensure that agency  employees successfully complete required and assigned training and  development. Additionally, the guide states that agencies must assign  authority and delegate responsibility to the proper personnel and  establish clear accountability for maximizing workforce performance.

However, as mentioned earlier, there is no overarching office responsible  at the selected agencies for overseeing the types of grants training sub- agencies provide. Additionally, the central offices at the selected agencies  do not evaluate sub-agency grants training efforts. We found variation  among the 11 sub-agencies’ grants training programs (as shown in  appendix III), which highlights the importance of central office oversight  for making sure the training variation is appropriate. As a result of these  issues, the selected agencies do not have assurance that grants training  provided across the various sub-agencies is sufficient in meeting the  needs of the various employees working on grants.

Since there is no overarching central office at any of the three agencies  we reviewed actively being held accountable for sub-agency grants  training programs, HHS, USDA, and Education cannot ensure that all of  the sub-agencies working on grants are sufficiently training their grants  employees. Without central agency oversight and accountability across  sub-agency grants training programs, not all grants employees may be  sufficiently trained on grants processes and procedures, which could  affect grant oversight in terms of grants employees monitoring grants  properly.

Given the importance of grants as a tool to achieve federal objectives and  the large outlays the federal government makes to fund them each year, it  is critical that the people who manage these grants—the federal grants  workforce—be well-trained to handle their responsibilities. To help  provide training to this workforce, OPM, OMB, and CFOC created grants  management competencies, a grants job series, some grants training,  and a career roadmap. However, they have not widely publicized the  roadmap and some sub-agencies we reviewed were unaware of it.  Moreover, OMB and the CFOC are not collecting detailed data on users  or feedback, which limits their ability to determine how useful these  resources are to the federal grants workforce.

The selected agencies varied in following selected leading training  practices and they provided limited monitoring and oversight of their sub- agencies’ grants training efforts. Without sufficient monitoring and  oversight, the agencies cannot have reasonable assurance that their sub- agencies are sufficiently training their grants workforce so they have the  necessary knowledge, skills, and abilities to properly manage, administer,  and monitor the billions of dollars that the federal government spends on  grants annually.

We are making a total of five recommendations, including two to OMB  and one to each of the selected agencies in our review. Specifically:  OMB’s Office of Federal Financial Management’s Controller (the CFOC  chair) should ensure CFOC formally publicizes the Career Roadmap  guidance among the 24 CFO agencies through memorandums, briefings,  trainings, regular CFOC meetings, or technical assistance and clearly  posts its “Controller Alert” on the CFOC website with the Career  Roadmap Report. (Recommendation 1)

The Director of OMB, working with CFOC, should (1) collect data metrics  regularly on the Career Roadmap Builder online tool and Grants Training  101 to determine how widely the resources are being used, and (2) obtain  periodic feedback from federal agencies on the usefulness of these tools  and any needed improvements. (Recommendation 2)

The Secretary of HHS should establish a process to monitor and evaluate  HHS’s grants training at the central office level. This process should  include (1) a method for identifying all employees working on grants  across the agency, and (2) oversight procedures to evaluate the  sufficiency of sub-agencies’ grants training efforts including the  incorporation of leading practices related to assessing competencies,  training approaches, accountability, and training results.  (Recommendation 3)

The Secretary of USDA should establish a process to monitor and  evaluate USDA’s grants training at the central office level. This process  should include (1) a method for identifying all employees working on  grants across the agency, and (2) oversight procedures to evaluate the  sufficiency of sub-agencies’ grant-training efforts including the  incorporation of leading practices related to assessing competencies,  training approaches, accountability, and training results.  (Recommendation 4)

The Secretary of Education should establish a process to monitor and  evaluate Education’s grants training at the central office level. This  process should include (1) a method for identifying all employees working  on grants across the agency, and (2) oversight procedures to evaluate  the sufficiency of sub-agencies’ grants training efforts including the  incorporation of leading practices related to assessing competencies,  training approaches, accountability, and training results.  (Recommendation 5)

We provided a draft of this product to Education, HHS, OMB, OPM, and  USDA for review and comment. In written comments reproduced in  appendixes IV and V respectively, HHS concurred and Education  generally concurred with our findings and recommendations directed at  them. Both agencies described the steps they were taking to implement  our recommendations. In an email, the Chief Learning Officer said that  USDA concurred with our findings and recommendation. In an email, a  Management Analyst said that OPM had no comments on the draft  report.

OMB staff provided us with oral comments stating that the agency  partially concurred with our first two recommendations. Specifically, for  our first recommendation, OMB generally agreed with our finding that the  Career Roadmap guidance should be better publicized. However, OMB  believes this is not its responsibility but rather the responsibility of federal  agencies. OMB stated that federal agencies could incorporate a method  into their improvement plans to ensure that sub-agencies are made aware  of the Career Roadmap Guidance. We believe that, as the federal  government’s central management agency and developer of the Career  Roadmap, OMB has a responsibility for ensuring that federal agencies  are aware of the Career Roadmap guidance by formally publicizing it  through memorandums, briefings, trainings, regular CFOC meetings, or  technical assistance.

For the portion of our first recommendation that discusses clearly posting  the “Controller Alert,” OMB stated it will look at the alert’s placement on  the CFOC website to see if the agency can make it more prominent. We  continue to believe that the “Controller Alert” should be easily accessible  to anyone visiting the website and should be located on the same page  as the Career Roadmap, where it would have greater visibility.

For our second recommendation, OMB agreed that user feedback data  regarding the Career Roadmap Builder and Grants Training 101 is useful.  However, OMB stated that while it will continue to collect data on the  number of users, it believes that federal agencies should be responsible  for collecting specific, detailed user data if they are using those  resources. We continue to believe that OMB and CFOC would benefit  from collecting specific, detailed user data on these tools, which they  devoted time and multiple resources to developing. Collecting detailed  data metrics that go beyond the number of users can help OMB and  CFOC to better evaluate the effectiveness of these grants training tools.  Additionally, OMB stated the agency is committed to working with CFOC  to review the Grants Training 101 module to determine how useful it is  and if any improvements or adjustments are needed.

All five agencies provided technical comments on the report draft, which  we incorporated where appropriate.

We are sending copies of this report to the Secretaries of Education,  HHS, and USDA and to the Directors of OMB and OPM. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov. If you or your staff have any questions about this  report, please contact me at (202) 512-2757 or goldenkoffr@gao.gov.  Contact points for our offices of Congressional Relations and Public  Affairs may be found on the last page of this report. GAO staff who made  key contributions to this report are listed in appendix VI.

Appendix I: Comparison of Federal Acquisition Training and Grants Workforce Training

Appendix II: Grants Workforce by Job Series for Health and Human Services, Agriculture, and Education as of March 2018

Appendix III: Grants Training Programs at the Departments of Health and Human Services, Agriculture, and Education

The Department of Health and Human Services (HHS). HHS is a large  agency with 11 sub-agencies administering a wide variety of health and  human services that takes a decentralized approach to training its grants  workforce. While HHS’ central Assistant Secretary for Financial  Resources (ASFR) office provides grant policy and regulatory guidance  updates to HHS sub-agencies, ASFR officials said they leave the decision  on how to implement grants training to each of those sub-agencies. The  selected sub-agencies we reviewed—the Administration for Children and  Families, Centers for Medicare and Medicaid Services, Health Resources  and Services Administration, and National Institutes of Health—all  implement their own grants training programs and procedures.

The four sub-agencies at HHS that we reviewed take different  approaches in how they implement their respective grants training  programs. For example, some sub-agencies require that grant personnel  take required courses while others make them optional; some provide  internal grants training while others also use the services of an external  training vendor; and some require certification while others make it  optional. Table 3 highlights some of the grants training programs’  characteristics at the four HHS sub-agencies we reviewed.

The Department of Agriculture (USDA). USDA is made up of 29  agencies and offices at more than 4,500 locations across the country and  abroad. While its central Office of the Chief Financial Officer (OCFO)  provides some guidance on federal financial assistance policies and  grants terms and conditions, and ensures department-wide training  requirements are met, it, like HHS, leaves the decision on how to  implement grants training to each of its sub-agencies. The selected sub- agencies we reviewed—the Food and Nutrition Service, Forest Service,  National Institute of Food and Agriculture, and Rural Development—all  implemented their own respective grants training programs and  procedures. Table 4 highlights some of the grants training programs’  characteristics at the four USDA sub-agencies we reviewed.

The Department of Education (Education). Education approaches  grants training by combining both centralized and decentralized  approaches for its eight principal offices that conduct grant work.  Education’s central OCFO offers broad financial grants training such as  Oversight of Financial Management of Ed Formula/Discretionary Grants  and Discretionary Grant Budget Reviews. Education’s central Learning  and Development office offers broad introductory grants training such as  Introduction to Grants and Cooperative Agreements, Uniform  Administrative Guidance, and Cost Principals. According to Education  officials, Education’s Risk Management Services (RMS) offers risk  management-based grants training including Discretionary Grants  Overview, Conducting a Cost Analysis and Budget Review, Monitoring  Grants, Suspension and Debarment, and Risk Assessment and Risk  Mitigation. RMS also manages Education’s licensing program and  oversees training for new license holders geared towards grants  administration.

In addition to these central office trainings, each Education sub-agency  also provides specific training tailored for its mission as verified by the  three Education sub-agencies we reviewed—the Office of Special  Education and Rehabilitative Services (OSERS), the Office of Elementary  and Secondary Education (OESE), and the Office of Post-Secondary  Education. For example, according to Education officials, OSERS trains  grant staff on the Individuals with Disabilities Education Act grant  application review process, and OESE recently identified a need for and  developed and taught a course on improving the grantee communication  process. Table 5 highlights some of the grants training programs’  characteristics at the three Education sub-agencies we reviewed.

Appendix IV: Comments from the Department of Health and Human Services

Appendix V: Comments from the Department of Education

Appendix VI: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Tom James (Assistant Director),  Jyoti Gupta (Analyst-in-Charge), Benjamin Adrian, Dawn Bidne, Jeff  DeMarco, Karin Fangman, Joseph Fread, Robert Gebhart, Shirley  Hwang, Serena Lo, Sharon Miller, Meredith Moles, Steven Putansu,  Kayla Robinson, Robert Robinson, Cynthia Saunders, Stewart Small, and  Dan Webb made key contributions to this report.

The federal government awards billions of dollars in grants to state and local governments each year for everything from children's health insurance to higher education.

We looked at the training federal grants managers receive at selected agencies. We found that while agencies provided some training and the Office of Management and Budget developed some career assistance resources, none had evaluated the effectiveness of their efforts.

We made 5 recommendations, including that:

OMB better publicize and evaluate available career resources

Health and Human Services, USDA, and Education take steps to better evaluate their grants training