Research Administration Office

University of California

Memo Operating Guidance

No. 87-25

August 6, 1987

Subject: National Endowment for the Humanities Application Face Page - Applicant's Federal Loan Status

Over a year ago, the National Endowment for the Humanities (NEH) added a question to its application face page concerning the student loan status of "the individual applicant or project director." After NEH received protests from various universities, including UC and the Council on Governmental Relations (COGR) concerning the inability of the authorizing institutional official to certify the student loan status of the individual project director, NEH proposed a change to certify the "applicant's", referring to either the individual's or institution's, federal loan status. Again, universities and COGR pointed out to NEH as well as to OMB, that the "applicant" is the institution and the institution can only certify its own federal loan status, not the individual or project director's status.

Finally, NEH has decided to issue a face page for signature according to whether the award is to an individual or an institution. As NEH General Counsel Brent Hatch explains in the enclosed letter (Enclosure 1) to OMB Deputy Administrator James MacRae, when the application is from an institution, the authorized official will be required to certify the debt status of the institution only, and not. that of the individual project director.

The Office of the President Contracts and Grants Office has discussed this new NEH certification requirement with Corporate Accounting in order to determine if authorized campus officials can sign this statement. As Donald Alter, Director of Corporate Accounting, has indicated in the attached letter (Enclosure 2), the University "is not delinquent on repayment of any federal debt." Therefore, authorized campus officials may sign these NEH application face pages with this statement when the University is the applicant to NEH.

Refer: Samuela A. Evans

ATSS 8-582-1654

(415) 642-1654

Subject Index: 02

Organization Index: F-705

Acting University Contracts and Grants Coordinator

Enclosures


ENCLOSURE 1 TO C& G MEMO 87-25

EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF MANAGEMENT AND BUDGET

JUL 1 1987

Ms. Kate Phillips

Council on Governmental Relations

One Dupont Circle, N.W.

Suite 670

Washington, D.C. 20036

Dear Kate

As I discussed with you, I am enclosing a copy of a recent exchange of correspondence between the Office of Management and Budget and the National Endowment for the Humanities regarding certifications to be collected on the Federal debt delinquency status of individuals and institutions.

Sincerely, Joseph F. Lackey -

Desk Officer

Office of Information

and Regulatory Affairs

Enclosure


EXECUTIVE OFFICE OF THE PRESIDENT

OFFICE OF MANAGEMENT AND BUDGET

WASHINGTON. D C 20503

JUN 29 1987

Mr. Brent O. Hatch

General Counsel

National Endowment for the Humanities

Washington, D.C. 20506

Dear Mr. Hatch

We have received and reviewed your letter of June 15, 1987, and are in agreement with your resolution to require only one certification of debt status. Proceeding as you have proposed would be consistent with our approval under the Paperwork Reduction Act of 1980 of your application forms.

Sincerely,

James B. MacRae, Jr.

Deputy Administrator

Office of Information

and Regulatory Affairs


NATIONAL ENDOWMENT FOR THE HUMANITIES

Office of the General Counsel

June 15, 1987

James B. MacRae, 3r. Deputy Administrator Office of Information

and Regulatory Affairs Office of Management and Budget Washington, D.C. 20503

Dear Mr. MacRae:

I appreciate your taking the time to meet with Susan Metts and me to discuss the remaining issues concerning the delinquent debt certification. After reviewing our grant-making process and our desire to put this issue to rest, we propose the following resolution.

The Endowment will continue to use the current cover sheet [Tab A] in all of its programs. In programs where awards are always made to individuals [Tab B], only the individual applicant will be required to certify his debt status. The phrase "Not Applicable" will be stamped or printed in the signature block for institutional certification.

In programs where the grant is awarded to the Institution

[Tab C], only the authorizing official will be required to certify the debt status of the Institution. The phrase "Not Applicable" will be stamped or printed in the signature block for individual certification.

In programs where either the individual or the institution may receive the award [Tab O], both signature blocks are left open. The new instructions [Tab E] make it clear that only one signature is required and indicate that the proper signature is the individual's if applying as an Individual or the institution's if applying through an Institution as is indicated in Block 2 of the cover sheet [see Tab A].

Although we remain convinced that we could require both the institution and the project director to certify where the project director is a recipient, albeit semi-indirect, of federal funds and the primary intended beneficiary of the grant, the resolution outlined above meets your agency's concerns and hopefully will allow us to carry out Endowment business without further delay. Therefore, we ask that you approve the use of the cover sheet certification as proposed and the amended instructions to the cover sheet for all of our program guidelines [Tabs B-D]. Upon approval from your office, we will implement the changes immediately.

Again, I appreciate your assistance in this issue and hope this resolution will prove the end of the matter.

Sincerely,

Brent O. Hatch

General Counsel

Attachments


ENCLOSURE 2 TO C& G MEMO 87-25

July 27, 1987

Contracts & Grants Officer Evans

Subject: University of California Debt to Federal Government

In answer to your questions regarding delinquency on repayment of Federal debt, the University of California is not delinquent on repayment of any Federal debt at this time.