Simplify grant compliance certifications by modifying OMB's requirements. OMB should modify Circular A-102, "Grants and Cooperative Agreements to State and Local Governments," to require that the common grants management rule provide that all cross-cutting certifications may be submitted by incorporating them by reference into grant applications. Further, OMB should modify the SF-424 to eliminate the assurances and to add the following statement: "By virtue of this signature, the applicant certifies that it: 1) incorporates into the application by reference the cross-cutting assurances contained in the common rule; and 2) will comply with the assurances."
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