By now you have probably heard that on June 15, 2017, through Memorandum M-17-26, the Office of Management and Budget disbanded the Council on Financial Assistance Reform (“COFAR”).
Established in October 2011 by OMB Memorandum M-12-01, and comprised of senior policy officials from the largest grant-making agencies, the COFAR was to provide recommendations to OMB on grant and cooperative agreement matters and coordinate ideas and best practices among grant-making agencies.
According to OMB, the COFAR’s activities, to the extent they may continue, will be prospectively carried out by OMB’s Chief Financial Officers (“CFO”) Council. This is logical, as the CFO Council was created by the Chief Financial Officers Act of 1990 for the purpose of meeting periodically, under the leadership of the OMB’s Deputy Director for Management, to coordinate financial management matters across agencies and advise OMB on the same. See Pub. L. 101-576, Sec. 302 (Nov. 15, 1990). Whether the CFO Council will be as focused and responsive on matters relating to the Uniform Guidance remains to be seen.
As you are likely aware, the COFAR has issued Frequently Asked Questions (“FAQs”) with responses that interpret certain ambiguous provisions of the Uniform Guidance. Presently, the most recent (September 2015) FAQs remain available on the CFO Council’s website at https://cfo.gov/grants/grants-resources. However, as certain portions of the COFAR website appear to have been disabled, we recommend you take the time to download and save a copy of these FAQs in your files.
For questions about the COFAR, CFO Council or other grant management matters, you may contact FTLF’s Federal Grants Practice Group at (202) 466-8960.