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OCA Testifies on the Government Grant Administration Amendment Act of 2015

Tuesday, April 28, 2015
Bill 21-24 Seeks Greater Transparency and Fairness in Grant Making Process


Public Hearing on Bill 21-24,    
the Government Grant Administration Amendment Act of 2015
Testimony of
Christopher Shorter
Director of Agency Operations
Office of the City Administrator

Before the
Committee of the Whole
Council of the District of Columbia
The Honorable Phil Mendelson, Chairperson

Room 123
John A. Wilson Building
1350 Pennsylvania Avenue, NW
Washington, DC 20004
April 28, 2015
12:00 noon

Good afternoon, Chairman Mendelson and members of the Council.  For the record, my name is Chris Shorter, and I serve as the Director of Agency Operations within the Office of the City Administrator.  In this role, which was established at the start of the Bowser Administration, I provide strategic support and leadership on citywide performance management, accountability, and continuous quality improvement activities. The agency operations team also supports multi-agency and cross-cluster projects and initiatives. The team also provides assistance on agency by agency audit compliance, labor relations and collective bargaining issues.  I am pleased to testify before you today on Bill 21-24, the Government Grant Administration Amendment Act of 2015.

The Bowser Administration supports the overarching goals of Bill 21-24.  This legislation seeks to inject greater transparency and fairness into the grant making process by establishing a set of targeted administrative procedures that all grant programs established by District statute would be required to follow.  Specifically, we agree that: most grants should be awarded through a competitive process; the public should be provided ample notice of grant funding availability; accepting and rejecting grant applications should be done in a timely manner; and grant record-keeping and reporting requirements should be robust.

In fact, the Office of the City Administrator, through my office, has initiated a broad initiative to review the current grant-making process to ensure that the grants process is fair, open, timely, and appropriately administered.  That review will include an analysis of the Citywide Grants Manual, current laws and regulations, practices in other jurisdictions, and the information technology systems we have available to assist in the tracking of, and reporting on, grant awards.

Keeping that in mind, frontline agencies have expressed some concerns with a few of the provisions within this legislation.  One general concern we have is with the one-size-fits-all approach.  The standards and requirements of the bill would apply to any grants issued under District law, no matter the subject matter of the grant, the purpose of the grant funds, or the specific needs addressed by the grant.  Although it is often important to have consistent standards for grants administration, it is also important for there to be a process to waive those standards and for there to be an opportunity for alternative procedures to be followed.  We believe this bill should reflect that need.

Similarly, we believe it is important for the District’s grant administration standards to be aligned as much as possible with the federal grant administration standards.  It would be inefficient to require agencies to comply with two separate administrative systems for similar grants, where the only difference between the two grants is the source of funds.  This is also particularly important for grantees, who are often small providers for whom different reporting and application systems could be a substantial burden.  By standardizing the District’s grant administration process as much as possible with the federal process, we can better achieve our ultimate goal—having grantees focus their time and resources on providing high-quality services to District residents.

We also believe some of the specific elements of the bill could be challenging.  For example, section 1015a of the bill would require that all applicants for a grant be notified of the acceptance or rejection of their grant applications within 30 days.  We believe this timeline in many cases will be too short, given the extensive due diligence that agencies must perform before issuing a grant.  We agree that it is in the District’s interest to promptly review applications and issue awards, but this timeline will often be unrealistic and may in fact lead to grants being issued without the appropriate level of agency review.

We also believe it is important to more closely review the record-keeping and reporting requirements of the bill.  Although such requirements are important to maintain a fair and transparent process, it is also important to ensure that the requirements will not overly burden agency resources and can be implemented in practice.  We believe that some adjustments to the record-keeping and reporting requirements may be needed in order to ensure that these dual goals are achieved.

In addition, section 1015 of the bill may benefit from an amendment.  This section of the bill would prohibit the issuance of any non-competitive grant of over $50,000.  Again, we strongly support the principle embodied in section 1015—that District grants should be issued through a fair and open process.  However, in some circumstances it may be appropriate to issue non-competitive grants, particularly where only one organization is able to provide the needed services or the need is particularly acute.  Such awards can still be made through a transparent process, but it would be appropriate for the prohibition on non-competitive grants to include a waiver provision.

Chairman Mendelson, the Bowser Administration is committed to ensuring an open, fair, and transparent process on all matters related to government and agency operations.  In fact, as I described earlier in my testimony, we are in the beginning stage of our own initiative to review agency grant-making procedures to help ensure this goal is met.  We look forward to working with the Council to continue to address this important issue.

Thank you for the opportunity to testify today.  I am available to answer any questions you may have.