OMB Issues Guidance for Agencies on Implementing Coronavirus Stimulus Packages

The Office of Management and Budget released guidance Friday to assist federal agencies in implementing a series of legislative items relating to the coronavirus pandemic response. The guidance is intended to facilitate a rapid delivery of services and funds to the American people while ensuring transparent spending of taxpayer funds.

The guidance, signed by OMB Acting Director Russell Vought, directs agencies to “leverage and continue to employ “existing financial transparency and accountability mechanisms wherever possible.” The guidance also establishes three core principles agencies can consider when attempting to balance speed with transparency. The three principles are:

•   Mission achievement - Federal managers and recipients at all levels should use data and evidence to achieve program objectives;

•   Expediency - Agencies should rapidly issue awards and fund programs to meet crucial needs; and

•   Transparency and accountability - Agencies must report information on awards to provide the public with information in a clear, accurate, and timely manner.

The guidance continues by explaining and expanding upon each principle.

Under “Mission Achievement” the guidance instructs agencies to work with their Resource Management Offices (RMOs) to identify key program design questions that must be resolved in order to execute spending plans.

“Agencies need to manage these new funds and awards consistent with their respective mission performance objectives and plans. Agencies also must incorporate reporting of performance on COVID-19 relief funding into their established mission performance plans and reports, and must review progress as part of their performance, evidence-building and enterprise risk management routines to the maximum extent possible, consistent with guidance included in OMB Circulars A-11 and A-123,” the guidance explains. “Specifically, agency Deputy Secretaries or Chief Operating Officers must review at least quarterly the progress made on program performance under theCOVID-19 relief legislation.”

The mission achievement sections reminds agencies of other additional reporting requirements and OMB’s ability to request more frequent reporting as needed.

Under “Expediency,” agencies are directed to prioritize the following considerations during the implementation of the COVID-19 response:

•   Ensuring that qualified, skilled, and appropriately trained personnel are overseeing awards made under the new relief legislation;

•   Streamlining regulations and internal processes, including issuing waivers and delegating decision-making where appropriate to empower managed risk-taking and innovative thinking;

•   Balancing the need for competition with timely execution of funding;

•   Balancing the need for expediency with steps to mitigate risk of fraud, waste, abuse, and improper payments;

•   Ensuring that resources go to evidence-based programs whenever possible; and

•   Regularly communicating with and encouraging coordination among state and local governments, tribes, and nonprofit entities for financial assistance, which OMB can facilitate.

Finally, to ensure “Transparency and Accountability,” the guidance instructs agencies to apply “sound data management principles to make evidence based decisions.” The guidance also instructs award descriptions to be written in plain language for greater public understanding.

The guidance also reminds Offices of Inspectors General that they should be developing plans to leverage their new resources funded through the COVID-19 response legislation to detect and prevent waste, fraud, and abuse.

“The OIG community and the newly created Pandemic Response Accountability Committee (PRAC) should also work closely with OMB and the agencies to coordinate COVID-19-related oversight efforts, leverage available technology to minimize burden and duplicate efforts, and re-prioritize lower priority audit work to allow agencies and OIGs to better support higher priority COVID-19 work,” the guidance explains.

The 9-page guidance also includes adjustments to current agency reporting deadlines and instructions for various types of agency reporting mechanisms.