Statewide Implementation

GATA Administrative Rules have been published in the Illinois Register 10/6/2017. IDPH has also posted them on the IDPH GATA Website in the Resource Library (Click HERE to view). The following key points highlight the proposed Rules.

• The initial GATA Admin Rules communicated Illinois’ incorporation by reference to Federal Uniform Guidance (2 CFR 200), and other cited federal and state statutes. These rules were intended as a starting point for GATA policy.
• During state FY16, the Grant Accountability and Transparency Unit (GATU) designed various grant pre-award phase frameworks through engagement with more than 200 stakeholders – 40% from the grantee community and 60% from state agencies. During the GATA implementation phase, the frameworks were tested and modified as necessary. We wanted to be sure the frameworks were sound before putting the rules into policy.
• The pre-award frameworks GATU rolled out in 3/9/17 training applicable to FY18 are now being codified into rules. The 10/6/17 Illinois Register posting is policy to support the pre-award phase frameworks. The frameworks include federally mandated registration and pre-qualification, risk assessments and merit based review. The rules also address standard templates and practices Illinois is utilizing for the NOFO, budget, uniform grant agreement and NOSA.
• During FY18, we’re designing and piloting frameworks for the grant post-award phase. The post-award phase will include centralized audit report reviews, onsite financial monitoring, and periodic and year-end reporting, We’ll add post-award phase rules to the GATA Admin Rules after these frameworks have been tested and updated as needed.
• The Secretary of State Indexing Division recommended we repeal and replace the GATA Admin Rules. The SUBPART Section listing provides the content included in this filing. Compare to the list in the prior Admin Rules for areas of addition.

A public hearing to review the rules is scheduled for November 9, 2017, 9:30am – 11:00am at the following locations:

Springfield
Stratton Building, Room #349
401 S Spring St
Springfield, IL 62704

Chicago
James R. Thompson Center, Room #14-612
100 W Randolph St
Chicago, IL 60601

Implementation Phases

The GATA implementation structure involves GATA subcommittees which are made up of representatives of State agencies, grantees and subrecipients, and the Grant Accountability and Transparency Unit (GATU) at GOMB. Each subcommittee and its workgroups has a GATU representative and co-chairs, one representing State agencies and one representing grantees. The subcommittees will go through three phases of GATA implementation:

Phase 1 Rulemaking

• Review the Uniform Requirements; the rules can be more stringent, but not less stringent
• Determine if we need to add additional requirements for all awards
• Need to be flexible so that we can modify in the future, whenever necessary

Phase 2 Implementation

• Based on the rules, set forth uniform framework for Statewide policies and procedures
• Ensure that policies and procedures are flexible enough to add specific conditions for individual grant programs
• Ensure that the rules meet the objectives of GATA to lessen the administrative burden and remove duplication
• Ensure that the rules recognize the limitations of small providers and grant awards while helping to build capacity through training and technical assistance

Phase 3 Monitoring

There will be an ongoing process of review and continuous improvement after the initial implementation of GATA

Subcommittee Structure

The Illinois Single Audit Commission (ILSAC) is a bipartisan commission created by Public Act 98-047. The members include a representative from each of the four legislative caucuses, one representative from each of the thirteen largest grant-making agencies, and one representative of GOMB. ILSAC was originally charged with conducting research regarding the Federal government practices with respect to grants and whether Federal grant rules should be adopted for State grants. ILSAC’s final report summarized its recommendation that the State adopt uniform standards for the administration of grants in the State. This led to the adoption of the Grant Accountability and Transparency Act, 30 ILCS 708/1 et seq.

Currently, ILSAC serves in an advisory capacity for recommendations to the Joint Committee on Administrative Rules (JCAR) with respect to the rules necessary to implement GATA and provides advice and technical assistance to the ILSAC subcommittees and workgroups in their development of rules recommendations for submission to JCAR.

The GATA Steering Committee is made up of the GATU staff, and the co-chairs of the ILSAC subcommittees. The purpose of the GATA Steering Committee is to:

• Provide oversight and guidance to ILSAC and its subcommittees and workgroups
• Review and submit the ILSAC subcommittee recommendations to ILSAC
• Develop funding mechanisms for GATA implementation

ILSAC subcommittees and workgroups are critical to the success of GATA.

The subcommittees are responsible for making recommendations for rules in areas where the State and Federal regulations allow for flexibility. Each subcommittee is responsible for:

• Reviewing the State and Federal regulations that govern their topic in 2 CFR Part 200 and the Grant Accountability and Transparency Act in order to make informed recommendations to the GATA Steering Committee.
• Developing recommendations for performance metrics to measure the effectiveness of GATA.
• Developing recommendations for training programs to meet the needs of State agency and grantee staff.

Below is the subcommittee and workgroup flow chart

GATA 2016 Annual Report

The Governor’s Office of Management and Budget (GOMB) and the Illinois Single Audit Commission (ILSAC) is pleased to submit the 2016 Grant Accountability and Transparency Act (GATA) Annual Report. The annual report represents the culmination of two years of work by the Grant Accountability and Transparency Unit (GATU) and more than 200 volunteers representing State agencies and the grantee community. The accomplishments highlighted in the Executive Summary and expanded upon the report narrative emphasize Illinois’ approach to comply with federal Uniform Guidance and GATA requirements. This report provides insights into specific statewide implementation efforts which the Federal Office of Management and Budget has recognized as national promising practice.