This is simple to deal with. award no grant of over $100,000. IF a program requires $300,000, then write the grant into three $100,000 grants in which each pays for 1/3 of the project. IF some item is involved that is over $100K, then break it up into components. $100,000 building? Ok, $90,000 for the building, second grant of $10,000 for installation of a bathroom after the fact.
IN fact, this kind of thing has been done oodles of times to avoid difficult or cumbersome policies. On Fri, Apr 21, 2017 at 4:29 PM, David Duffy <ddu...@hawaii.edu> wrote: > > This new policy from the Secretary of the Interior may cause massive > disruption for projects across the country. I apologize for the terrible > cute and paste. --David Duffy > > > APR 12 *2017* > > > *To: Assistant Secretaries* > > *Heads of Bureaus and Office Directors* > > *From: Secretary* > > *Subject: *Managing Grants, Cooperative Agreements, and Other Significant > Decisions > > > > A hallmark of my management of the Department of the Interior (Department) > will be empowering local managers to make responsible decisions. Local > managers are closest to the public we serve and to the precious resources we > manage on their behalf. I also have a duty to learn about the > Department's operations as I take the helm of the ship. Only by > understanding the varied operations will I be able to lead this great > Department > in fulfilling its important mission on behalf of the American people. > > > > The Department annually distributes $5.5 billion in grants and > cooperative agreements to a variety of grantees and cooperators to > advance mission objectives. In order to help me to understand the immense > impact grants and cooperative agreements have on the mission delivery of > the Department, I am directing implementation of the following temporary > procedures for processing grants and cooperative agreements: > > > > Effective immediately, bureau heads and office directors will use the attached > template to report all planned Fiscal Year (FY) 2017 grants and > cooperative agreements of $100,000 or more *before* final award. The > reports should be submitted through the Assistant Secretaries to Mr. > James Cason, who has been delegated the authority of the Deputy Secretary. > The Office of Acquisition and Property Management will assist Mr. Cason in > reviewing these reports. No grants should be awarded until the review has > been completed. You will be notified about your clearance to proceed with > awards following this review. > > > > In addition, to better assess the overall functioning of the Department's > critical programs: > > > Each bureau head and office director shall ensure that their office > obtains proposed records of decisions (RODs) and uses the attached > template to report on proposed decisions prior to issuance. Proposed > decisions that are not termed "ROD" but have nationwide, regional, or > statewide impact shall also be reported using the template. All reports should > be submitted to Mr. Cason. A decision should not be issued until he has > reviewed the report and provided clearance. > > > > The above procedures are temporary and are being implemented to assist me > in understanding how we make important decisions to advance the mission > of the Department, assess how we are aligning our grants and cooperative > agreements to Department priorities, and to assure coordination with the > Office of Communications for significant announcements. The review and > processing of grants, cooperative agreements, and RODs will return to their > regular order as soon as possible. > > > > > > > > > > > -- > David Duffy > 戴大偉 (Dài Dàwěi) > Pacific Cooperative Studies Unit/Makamakaʻāinana > Botany > University of Hawaii/*Ke Kulanui o Hawaiʻi* > 3190 Maile Way > Honolulu Hawaii 96822 USA > 1-808-956-8218 > -- Malcolm L. 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