By Maia Jachimowicz, Nichole Dunn, and Lisette Partelow
The federal government has recently revised its Uniform Grants Guidance to clarify how it will manage the $1.2 trillion in grants and financial assistance that it oversees, including those funded by the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA). The latest revisions make explicit that federal funds can be used for certain activities, in particular:
- Community Engagement: The new guidance requires federal agencies to encourage community engagement and clarifies that federal dollars can be used for these activities.
- Data and Evaluation activities: Clarifies that grantees are allowed to spend federal funds on data infrastructure, evidence-building, and evaluation, including staffing costs.
Community engagement is a crucial component of infrastructure projects, and a priority for the implementation of BIL. The Uniform Grants Guidance makes it easier for cities to implement strong community engagement provisions in BIL grants by clarifying that grantees can use federal funds to cover specific community engagement expenses, namely involving community members in program development and implementation. These costs may include stipends, per diems, or travel allowances to reduce financial barriers to community engagement, or the printing of materials in another language to make engagement efforts accessible to all residents.
The OMB Uniform Guidance also clarifies that federal funds can support staffing for data collection and analysis and for in-house or contract evaluations. Allowable evaluation activities include:
- evidence reviews
- evaluation planning and feasibility assessment
- conducting evaluations
- sharing evaluation results, and
- other personnel or materials costs related to the effective building and use of evidence and evaluation for program design, administration, or improvement.
Evaluation can also include an assessment specific to a given project or one that covers a larger scope of which a given project is a part. For example, a project on environmental resilience for a specific highway may participate in a larger evaluation that looks at resilience across various types of physical infrastructure.
The OMB Uniform Guidance also makes explicit that federal funds can be used for data costs, including but not limited to expenditures needed to gather, store, track, manage,
analyze, disaggregate, secure, share, publish, or otherwise use data to administer or improve the program, such as:
- data systems
- personnel
- data dashboards
- cybersecurity, and related items.
Federal funds can also be used for building integrated data systems, such as those that allow two agencies or local governments to share data.
In addition to making explicit that federal dollars can be used for evidence building through data and evaluation activities, the Uniform Grants Guidance also emphasizes the importance of evidence-based practices. In their implementation memo on the guidance, OMB instructed federal agencies to make an effort to prioritize evidence-based practices in competitive grant programs. Depending on the details of the NOFO, cities that incorporate evidence-based strategies for transportation or housing, for example, may be able to submit more competitive grant applications.
More information about the Uniform Grants Guidance can be found in RFA’s local practice guide, including best practices for data, evaluation, and community engagement readiness that will prepare applicants to be more competitive when seeking federal grant funding.
