Following up Friday’s OMB e‑mail that requires agencies to designate a GMLOB consortia lead by December 31, the Grants Executive Board today held a meeting that offered a few more details about the policy, exceptions, and other matters. The following notes are based on my understanding of what was discussed at that meeting. 

It’s clear that OMB wants agencies to choose one of the existing providers. OMB will not name additional consortia leads at this time, for four main reasons: 

1. OMB believes that there has not been enough movement within the grants community toward the existing three consortia providers already approved.
2. OMB wants to see successes with the three consortia providers before choosing any additional consortia providers.
3. OMB is not convinced that current demand cannot be supplied by the existing consortia providers.
4. The implementation of FFATA will be simplified and the three consortia provider’s systems have the necessary data elements for FFATA.

If an agency believes that their system requirements cannot be met by any of the existing consortia leads, they must prove that to OMB and be granted an “exception.” (There is an implicit assumption here that all agencies already have clear system requirements available to compare to the three providers systems.) 

Exceptions will be provided only in response to a formal gap/fit analysis that is conducted between the agency and one or more of the consortia providers. 

If a system is not a fit, the agency must explain why, what is unique about their grantee population, what specifically is missing from the consortia’s solution, etc. 

The timeline is as follows: 

• End of Sept 2007: The GMLOB PMO will provide agencies with further guidance and templates (see below).
• Q1 FY 2008: By the end of Q1, OMB is requiring agencies to have completed a gap/fit analysis with at least one of the consortia providers. After the analysis is completed, agencies will be asked to either: 1) Ask for an exception because the system will not meet the agency’s requirements, or 2) Complete an MOU with a consortia provider for services.
• Q2 FY 2008: By the end of Q2, OMB is requiring agencies that have an MOU in place to submit a migration plan. If an agency was granted an exception, the timeline is TBD in terms of the next steps required and the potential for new consortia leads being approved.

To assist agencies in meeting these new requirements, the GMLOB PMO will be providing: 

1. A Template for the gap/fit analysis. The template will be used by agencies to submit their system requirements to one or more of the consortia service providers.
2. A template for the exceptions process.
3. A template for the MOU between agencies for service.

There was some discussion about agencies requiring enough detailed information from the existing providers to make a determination about best fit and suitability. Apparently GEB members are asked to contact the GMLOB co-chairs with details on the information needed and they will coordinate its provision with the consortia leads. 

The issue of cost was raised — the cost of doing the gap/fit analysis and other efforts associated with meeting this mandate. OMB considers this activity to be within normal operating procedures and costs, so no additional money is likely to be made available for it. 

There is also a concern that the providers will be able to review agency requests quickly. It’s unclear whether they are staffed and prepared for that. 

It may be that OMB and the GMLOB PMO is hoping that the exception process will highlight those agencies that have already been reaching out to partner with other non-consortia providers. If those agencies can demonstrate that the approved systems do not meet their requirements, then OMB may allow other partnerships. If agencies have been partnering, then the exception process will probably give those agencies an opportunity to provide OMB with data on any gap analysis conducted, migration plans, and timelines for the new system partnership. These partnerships may turn into new consortia leads. (Note that this is largely speculation because OMB has clearly stated that no more leads will be named at this time. Whether any others will ever be named is an open question.)