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The Administration supports the general objectives and intent of H.R. 409,
particularly as they relate to improving the effectiveness and performance
of Federal financial assistance programs by simplifying the Federal grant
application and reporting processes. However, the Administration has
serious concerns about the bill which imposes requirements that are unduly
burdensome, inconsistent with existing statute, or duplicative of efforts
already underway within Federal agencies.
The bill would require that all Federal agencies, with certain limited
exceptions, strive to develop and use a common application for all grant
programs. Because of the widely varying statutory and programmatic
requirements of different grant programs, a one-size-fits-all application
will add unnecessary costs and administrative burdens to agencies and OMB
during a period of limited Federal resources. The Congressional Budget
Office estimated last year that a similar bill would cost $10 million. The
legislation includes no authorization for additional funding to fulfill
these requirements. Furthermore, many of the objectives of the bill can be
accomplished under current statutes and are already being furthered within
the current framework of OMB coordination and technical assistance to
Federal agencies.
Finally, in order to meet the goal of a common application form, many grant
programs would be required to go through extensive public comment periods,
regulatory changes, and potential statutory changes to comply with a fixed
set of criteria. Since the bill is fundamentally in conflict with current
law and regulation, the bill is essentially unworkable in its current form
to the extent that it purports to require a single, common application form
for all the many different Federal grant programs. We look forward to
working with Congress to seek further changes.
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