Federal Manager's Daily Report

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OMB has stressed requirements that it set in a recent memo on spending under the infrastructure law enacted late last year for agencies to cooperate with IG offices and the GAO as they oversee that spending.

In a blog posting, OMB noted it had earlier set a general policy of cooperation and that the most recent memo applies that policy specifically to the law, called the Bipartisan Infrastructure Law. The posting cited provisions in the more recent memo requiring agencies “to proactively engage with oversight entities” to “ensure that programs balance efficient results, equitable access, and program integrity, including minimal waste, fraud, and abuse.”

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“For new and expanded Bipartisan Infrastructure Law programs where significant program design is being implemented, agencies must engage with OMB and the agency’s IG for a dedicated joint review meeting to proactively discuss program design, risk mitigation strategies, financial controls, and data, tracking, and reporting. The “Gold Standard Meeting” process was developed by the White House American Rescue Plan Implementation Team and OMB, and these meetings have promoted proactive and transparent collaboration for new and expanded programs with tangible improvements,” it said.

Further, “Agencies are directed to use enterprise risk management practices and cooperation with their IGs to identify and mitigate risks during program design, including putting in place financial management controls to address payment integrity risks. The OMB guidance charges agency leadership to inform their IG when the agency is deciding to take on added risk, especially in new or changed programs, to expand access to the program, or when leveraging new technology or systems.”

The posting also called attention to other provisions of the recent memo including use of data and evidence, planning, documenting selection criteria and review processes, reporting on awards and sub-awards, and collaborating with other levels of government and local communities.

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