GATA 101 for LEA$

Introduction to GATA

School administrators were under a lot of pressure as they managed increased funding during the height of the COVID-19 pandemic. Both state and federal agencies allocated billions of dollars in grant funds to assist Local Education Agencies (LEAs) in navigating competing priorities for health, safety and education services. It is essential to apply a risk-based, data-driven approach that balances an increase in reporting and accountability to maximize the value of state and federal funds. The Illinois State Board of Education (ISBE), which acts as a steward of those funds, prioritizes proactive communication and supportive services to our network of grantees. We hope to expand those services by discussing the Grant Accountability and Transparency Act (GATA).

It is essential to apply a risk-based, data-driven approach that balances an increase in reporting and accountability to maximize the value of state and federal funds.

GATA (30 ILCS 708) became effective on July 16, 2014. The Act charged the Illinois Governor’s Office of Management and Budget with the development and implementation of a coordinated, non-redundant process for the provision of effective and efficient selection and monitoring of grant recipients’ oversight, thereby ensuring quality programs and limiting fraud, waste and abuse. Grant-making agencies developed uniform processes for administering different grant programs throughout the state. These processes can be segregated into two main features: 1) prequalification steps that are completed prior to the application for a grant and 2) post-award steps that are completed after a grant has been awarded.

Prequalification

An entity must be “prequalified” before it can receive a grant award. Grant applicants must complete a Fiscal and Administrative Risk Assessment, known as the Internal Control Questionnaire, which is available through the GATA Grantee Portal. Grant applicants, at the discretion of the awarding agency, must also complete a second programspecific risk assessment. The ISBE program-specific risk assessment is completed in the ISBE Web Application

Security (IWAS) system. Additionally, five qualification checks are used to determine good standing for grantees:

1) Sam.gov/Unique Entity Identifier (UEI) for account verification, 2) Federal Employer Identification Number (FEIN) or permanent tax ID number), 3) Illinois Secretary of State registration, 4) Illinois Stop Payment List, and 5) Illinois Department of Human Services Sanctions List. Grant recipients must complete these verification steps, which are electronically tracked in the GATA Grantee Portal.

SAM.gov discontinued the use of Dun & Bradstreet’s Data Universal Numbering System (DUNS) to identify businesses in April 2022. It was replaced by UEI codes, which are automatically assigned to entities upon registration. The U.S. General Services Administration, who oversees SAM.gov, provided a webinar for LEAs and local governments on December 6, 2022, to assist entities that were troubleshooting the registration and renewal process. The webinar was recorded and an FAQ was released the following week.

ARTICLE By Kristopher R. Pickford DIRECTOR OF GATA ILLINOIS STATE BOARD OF EDUCATION

Post-award

Section 7000.440 of GATA requires an awardee to complete a grant closeout, which includes final expenditure and performance reports. ISBE modified the performance submission rules in fiscal year 2023 from biannual to annual, which is the minimum required by legislation in order to reduce administrative burden for grant recipients. Single audits are also required for grantees that expended $750,000 in federal funds. The increase in federal grant dollars related to COVID-19 funding meant hundreds of LEAs would eclipse the $750,000 threshold and receive a single audit for the first time. This was evidenced by the 79.83% increase in Illinois single audit submissions since 2018. See Figure 1. Fortunately, the U.S. Office of Management and Budget extended the FY 2021 due date for all single audits nationwide per M-20-21, allowing grant recipients more time to fulfill this requirement. FY 2022 did not have an extension.

Award Count

Conclusion

GATA applied Federal Uniform Guidance to state awards per 30 ILCS 708/5 (b). The adoption of GATA was not a “new” requirement, but rather a new uniform procedure. The School Code already mandates Generally Accepted Government Auditing Standards audits and Federal Uniform Guidance had already mandated performance/ expenditure reports and single audits. The newly implemented uniform processes included the creation of the Catalog of State Financial Assistance (for state awards), Uniform Grant Agreement (for all awards), GATA portal registration, uniform prequalification steps and merit-based review (for competitive awards). Grant accountability will continue to evolve in an effort to streamline the grant processes and ISBE will continue to support our education partners during these changes.

$Grant accountability will continue to evolve in an effort to streamline the grant processes and ISBE will continue to support our education partners during these changes.

ISBE administers approximately one-third of Illinois’ 42,000 grant awards and strives to assist in the Board’s mission of providing each and every child with safe and healthy learning conditions, great educators and equitable opportunities by practicing data-informed stewardship of resources and policy development, all done in partnership with educators, families and stakeholders.

Please contact the ISBE GATA team at gata@isbe.net if you have grant-related regulatory concerns.

Resources:

GATA Grantee Portal: grants.illinois.gov/portal/

ISBE Web Application Security: apps.isbe.net/iwas/asp/login.asp?js=true

ISBE GATA webpage: www.isbe.net/Pages/Grant-Accountability-and-Transparency-Act.aspx

GSA SAM.gov Stakeholder Forum: sam.gov/content/entity-registration

UEI codes: sam.gov/content/duns-uei

Webinar for LEAs and local governments: buy.gsa.gov/interact/community/47/activity-feed/post/d78da4a7-4aaf-4714bfc4-44c2d3c01076/Stakeholder_Forum_Recap_State_and_Local_Governments_Seeking_Federal_Assistance_ Learn_about_Registering_in_SAM_gov

Section 7000.440 of GATA: www.ilga.gov/commission/jcar/admincode/044/044070000E04400R.html

Legislation: www.ecfr.gov/current/title-34/subtitle-A/part-76/subpart-G/subject-group-ECFR54971d4c79871f9/ section-76.720

M-20-21: www.whitehouse.gov/wp-content/uploads/2020/04/Implementation-Guidance-for-Supplemental-FundingProvided-in-Response.pdf

Federal Uniform Guidance: www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1

Catalog of State Financial Assistance: govappsqa.illinois.gov/gata/csfa/Default.aspx