If this grant continues work from a previous grant, how do current results compare to prior years? Please attach any relevant supporting documentation.
This is a confusing/unnecessary question as we always say our grants do not connect with other grants. All are separate entities with their own grant numbers. Sure, some work builds off of previous studies but bringing these up just confuses the reader. They wonder what grant program funded it, etc. Too confusing to use.
Appreciate the comment. Thank you for reviewing the proposed work and your comment will definitely be considered during the review process.
Best Regards,
Ryan
Anonymous
Jan 09, 2017
I concur with the previous respondent - this question would appear to require much more work on the part of the agency official than is justified by the small amount of insight provided.
Thank you for taking the time to review and comment. Your comment has been noted and will be considered during the review process.
Best Regards,
Ryan
Anonymous
Jan 10, 2017
This question is relevant to the past requirement of submitting a 5 year overview/evaluation of a grant that was a continuous project. I recall it was required back in the grant/grant agreement process.....usually addressing research grants.
Anonymous
Jan 11, 2017
I agree with the above comments, when I submit a grant that is a new segment of an existing grant, I set up objectives that are specific to that segment. If I deviate from my stated objectives during that segment I will explain why.
What purpose does this serve? I don't really see the need for this question. I understand wanting to show that this is a continuing grant but don't see the need to compare results.
Thanks for your thoughts. We will definitely include your comments, along with the others, and give it serious thought.
Best Regards,
Ryan
Anonymous
Jan 13, 2017
I would suggest revising our language in training questions and materials to reflect what is used in 2 CFR 200, as far as using award and recipient in place of grant and grantee. It is confusing when we use terms that are different from those in other authorities.
I concur with the previous comments. I often work with phased acquisition grants, which build landscapes over years. Each grant is treated as a standalone phase and is reported accordingly, otherwise, it gets confusing and you run the risk of unintentionally double-counting or overreporting. The acquisition results are cumulative but I don't see the value in comparing grant activities. Maybe this makes more sense in phased restoration projects? Just a thought, but I don't know that to be true since I work primarily with acquisitions.
We agree with reviewers who would like this question removed. To answer this in an accurate way (to compare past results to current results) is actually it's own separate project. Answering in a meaningful way would be time consuming and difficult. Similar to our comments on question 3 - in some cases this may actually be part of the grant, and in those cases this question would be answered under question 1.
Thanks for commenting. All comments will be given serious consideration.
Anonymous
Jan 19, 2017
How extension of a response are you looking for? This could be a whole document itself depending on what kind of grant this was. Also, is this mandated?
Tammy Snyder, NE Game and Parks
Anonymous
Jan 19, 2017
Based on other reviewers comments this question obviously raises concerns and I'd agree with most of those. I do, however, see how this could be a useful question for routine ongoing grant work, such as fish culture, deer harvest data collection, annual wildlife or fish surveys etc. it would simply be an opportunity to indicate that the grant work was for ongoing activities with a brief explanation. I suppose it comes down to how this question is interpreted and WSFR expectations.
Randy Curtis, NH Fish and Game Dept.
Anonymous
Jan 19, 2017
The majority of our grants are continuations, and a good chunk are O&M - ongoing fish and wildlife management. What is the purpose of this question - is it intended to be an evaluation / statement of the merits of continuing the grant? If so, based on the life cycle of continuing grants, this report would not generally be submitted to WSFR for 3 months after the segment has closed. At that point, the new segment is up and running, probably submitted 4-6 months ago. (Therefore, this information would be too late to influence WSFR's approval decision.) While the question itself sounds daunting, the hatchery report example did not seem like a robust answer that would serve either the purpose of evaluating the merits of continuing, or contribute significantly to a roll-up presentation of results. Again, I'm afraid this could also be interpreted as federal over-reach, as states generally have the autonomy to decide which projects to fund, within the confines of regulation. Maybe it would be different for a competitive program, but this should not be required for formula grants.
Anonymous
Jan 19, 2017
Andrea Crews, Oklahoma Department of Wildlife Conservation
This would require a major change in our programs. We detail discussions in management and technical reports but these do not come out yearly and they are completed well after the grant reporting cycle. We do not believe this is required by CFR and is getting into the realm of reporting after the grant period that has been discussed as being optional.
Alaska Department of Fish and Game
Anonymous
Jan 20, 2017
Although actions to carry out work may remain consistent, actual objectives may change between grants. Therefore, no real comparison of results can be made. Emphasis should be on obtaining the expected results and benefits as outlined in the approved project statement, not previous grants.
The purpose of a performance report is to report on a current grant – not past grants that have closed – even if a grant is a recurring annual grant. There is no regulatory authority to require a comparison to past grants that have closed.
2 CFR 200.328(b)(2)(i) states that performance reports will include “a comparison of actual accomplishments to the objectives of the Federal award established for the period.” The CFR continues by stating “Where performance trend data and analysis would be informative to the Federal awarding agency…should include this as a performance reporting requirement,” but this would only apply if the “trend data and analysis” occurred within the grant period that was being reported on. In effect, this question may be relevant to a multi-year grant, but not to a single year grant.
This question appears to be an attempt to gather data for the 5-year report. If WSFR wants to consider the trends in a given State’s performance reports, they already have all the required data to do so from previously submitted performance reports. Requesting a State resubmit performance reports from previous years would be a duplication of effort and not required by CFR.
Anonymous
Jan 20, 2017
We have some grants that go back decades, each in a separate segment. How far back are we to document ‘prior years’ comparisons? What is defined as a ‘grant’? Would we be comparing one segment to another? Or does this include an entirely different grant with different objectives? If the latter, would be challenging to compare on set of grant objectives to another. I think it would be helpful to clarify what is expected for this item.
Seems to be an unreasonable burden to answer this question, especially to provide documentation. Prior grant performance documentation should already have been submitted to FWS.
A general question on how grant work have changed from prior years may be easy to ask IF staff have not changed. However, there are times when new managers may not fully understand prior conditions to compare/contrast.
Further, “continues work” could be misinterpreted. In WSFR grants, may programs continue in similar fashion from year to year. What about a development-type project where the first grant is focused on planning and designing and the second grant is implementation? You really can’t compare the two because they have different objectives.
Anonymous
Jan 27, 2017
While I do see relevance to an extent, I do see confusion with this one. I suggest removing. Thanks.
25 Comments
Anonymous
Jan 04, 2017This is a confusing/unnecessary question as we always say our grants do not connect with other grants. All are separate entities with their own grant numbers. Sure, some work builds off of previous studies but bringing these up just confuses the reader. They wonder what grant program funded it, etc. Too confusing to use.
Ryan Oster
Jan 06, 2017Appreciate the comment. Thank you for reviewing the proposed work and your comment will definitely be considered during the review process.
Best Regards,
Ryan
Anonymous
Jan 09, 2017I concur with the previous respondent - this question would appear to require much more work on the part of the agency official than is justified by the small amount of insight provided.
Ryan Oster
Jan 10, 2017Thank you for taking the time to review and comment. Your comment has been noted and will be considered during the review process.
Best Regards,
Ryan
Anonymous
Jan 10, 2017This question is relevant to the past requirement of submitting a 5 year overview/evaluation of a grant that was a continuous project. I recall it was required back in the grant/grant agreement process.....usually addressing research grants.
Anonymous
Jan 11, 2017I agree with the above comments, when I submit a grant that is a new segment of an existing grant, I set up objectives that are specific to that segment. If I deviate from my stated objectives during that segment I will explain why.
Ryan Oster
Jan 12, 2017Thanks for taking the time to review and comment. WSFR will consider your comment as we move towards a finished product.
Best Regards,
Ryan Oster
Tammy Brooks
Jan 12, 2017What purpose does this serve? I don't really see the need for this question. I understand wanting to show that this is a continuing grant but don't see the need to compare results.
Ryan Oster
Jan 12, 2017Tammy,
Thanks for your thoughts. We will definitely include your comments, along with the others, and give it serious thought.
Best Regards,
Ryan
Anonymous
Jan 13, 2017I would suggest revising our language in training questions and materials to reflect what is used in 2 CFR 200, as far as using award and recipient in place of grant and grantee. It is confusing when we use terms that are different from those in other authorities.
Phil King
Jan 13, 2017Agree...good comment!
Anonymous
Jan 18, 2017I concur with the previous comments. I often work with phased acquisition grants, which build landscapes over years. Each grant is treated as a standalone phase and is reported accordingly, otherwise, it gets confusing and you run the risk of unintentionally double-counting or overreporting. The acquisition results are cumulative but I don't see the value in comparing grant activities. Maybe this makes more sense in phased restoration projects? Just a thought, but I don't know that to be true since I work primarily with acquisitions.
DeAnn Johnigk, WA Dept of Fish & Wildlife, deann.johnigk@dfw.wa.gov
Heather Kieweg
Jan 18, 2017We agree with reviewers who would like this question removed. To answer this in an accurate way (to compare past results to current results) is actually it's own separate project. Answering in a meaningful way would be time consuming and difficult. Similar to our comments on question 3 - in some cases this may actually be part of the grant, and in those cases this question would be answered under question 1.
-Heather Kieweg MN Dept. of Natural Resources
Phil King
Jan 19, 2017Thanks for commenting. All comments will be given serious consideration.
Anonymous
Jan 19, 2017How extension of a response are you looking for? This could be a whole document itself depending on what kind of grant this was. Also, is this mandated?
Tammy Snyder, NE Game and Parks
Anonymous
Jan 19, 2017Based on other reviewers comments this question obviously raises concerns and I'd agree with most of those. I do, however, see how this could be a useful question for routine ongoing grant work, such as fish culture, deer harvest data collection, annual wildlife or fish surveys etc. it would simply be an opportunity to indicate that the grant work was for ongoing activities with a brief explanation. I suppose it comes down to how this question is interpreted and WSFR expectations.
Randy Curtis, NH Fish and Game Dept.
Anonymous
Jan 19, 2017The majority of our grants are continuations, and a good chunk are O&M - ongoing fish and wildlife management. What is the purpose of this question - is it intended to be an evaluation / statement of the merits of continuing the grant? If so, based on the life cycle of continuing grants, this report would not generally be submitted to WSFR for 3 months after the segment has closed. At that point, the new segment is up and running, probably submitted 4-6 months ago. (Therefore, this information would be too late to influence WSFR's approval decision.) While the question itself sounds daunting, the hatchery report example did not seem like a robust answer that would serve either the purpose of evaluating the merits of continuing, or contribute significantly to a roll-up presentation of results. Again, I'm afraid this could also be interpreted as federal over-reach, as states generally have the autonomy to decide which projects to fund, within the confines of regulation. Maybe it would be different for a competitive program, but this should not be required for formula grants.
Anonymous
Jan 19, 2017Andrea Crews, Oklahoma Department of Wildlife Conservation
Sheila Cameron
Jan 19, 2017This would require a major change in our programs. We detail discussions in management and technical reports but these do not come out yearly and they are completed well after the grant reporting cycle. We do not believe this is required by CFR and is getting into the realm of reporting after the grant period that has been discussed as being optional.
Alaska Department of Fish and Game
Anonymous
Jan 20, 2017Although actions to carry out work may remain consistent, actual objectives may change between grants. Therefore, no real comparison of results can be made. Emphasis should be on obtaining the expected results and benefits as outlined in the approved project statement, not previous grants.
We suggest this question be removed.
NYSDEC, Division of Fish & Wildlife
Michael Sawyers
Jan 20, 2017Anonymous
Jan 20, 2017We have some grants that go back decades, each in a separate segment. How far back are we to document ‘prior years’ comparisons? What is defined as a ‘grant’? Would we be comparing one segment to another? Or does this include an entirely different grant with different objectives? If the latter, would be challenging to compare on set of grant objectives to another. I think it would be helpful to clarify what is expected for this item.
NE Game & Parks
Julie Kempf
Jan 20, 2017Seems to be an unreasonable burden to answer this question, especially to provide documentation. Prior grant performance documentation should already have been submitted to FWS.
A general question on how grant work have changed from prior years may be easy to ask IF staff have not changed. However, there are times when new managers may not fully understand prior conditions to compare/contrast.
Further, “continues work” could be misinterpreted. In WSFR grants, may programs continue in similar fashion from year to year. What about a development-type project where the first grant is focused on planning and designing and the second grant is implementation? You really can’t compare the two because they have different objectives.
Anonymous
Jan 27, 2017While I do see relevance to an extent, I do see confusion with this one. I suggest removing. Thanks.
Anonymous
Feb 23, 2017Agree with Sawyers comments above.