Publisher’s Note: This is Part 2 of a two-part article on the often-overlooked grant reviews. Be sure to start with Part 1.
To help you get started, below you’ll find the top five practices needed to ensure that your grant office is most effective in regards to your review duties. I believe that each of these practices is necessary to ensure that a grant office can perform optimal program and fiscal reviews.
#1 Approved Written Policies and Procedures for Grant Reviews
None of us would start a cross-country trip without a map or GPS to guide us on our journey. So why would any organization expect that something as complicated and sensitive as program and fiscal reviews should be conducted without a written set of policies and procedures?
In fact, I believe that all grant policies and procedures should be contained in a formal document approved and authorized by the highest authority within the organization—no matter how small it may be. If your employer doesn’t have such a document, I recommend that you speak with your administrators as soon as possible. For when there are roadblocks created to avoid letting you perform internal reviews, you will need to have such a document on which to base your ability to do your job.
Once everyone understands that you are simply following the written policies and procedures, you should encounter fewer obstacles. And of course, if you remind your coworkers that it’s your job to find any errors prior to a funder finding them, most project managers are cooperative. I explain that I’m there as a “free” consultant to help them prepare for a funder’s visit.
#2 Authority to Compel Compliance
Your president or CEO needs to make clear to all personnel that the grant office has the authority to compel compliance with the written policies and procedures. There is no room for debate in this area. Every grant-funded project needs to have regularly scheduled program and fiscal reviews. Because mistakes will inevitably be made, it is your grant office’s responsibility to mitigate these mistakes in advance of your funders’ audits.
Therefore, your organization’s CEO or president should:
- Make clear that the grant office has the authority to compel compliance with grant requirements;
- Establish a culture of respect for your grant office; and,
- Stand behind your grant office when there are disputes.
In other words, it shouldn’t matter if the project manager is the CEO’s cousin or best friend. Your administration should expect that all staff members will cooperate with your grant office. It’s as simple as that.
#3 Access to All Grant-Funded Personnel
Your grant office must be able to openly and freely make inquiries regarding grant-funded program strategies, benchmarks, outcomes, expenditures, etc. without interference from managers or other administrators. This is necessary in order to ensure compliance with the wide range of contractual conditions and applicable rules and regulations. Staff members must not be afraid to openly speak with the grant office in order for it to effectively perform reviews.
#4 Access to All Grant-Funded Project Files
To ensure a thorough review can be conducted, your grant office must be allowed to review any and all grant files and records that document the implementation, performance, and expenditures for the organization’s grant-funded projects. These files typically include accounting records, invoices, purchase orders, day-to-day operation files, participant files, attendance/sign-in sheets, promotional materials, staff calendars, official correspondence, budget modifications, program plan changes, time and effort sheets, etc. Without access to these files, your grant office will not be able to conduct a comprehensive review .
#5 An Established Process by which to Address Non-Compliance Issues
Image that there was a national law that set the speed limit on interstate highways at 45 miles per hour – but there were no regulations or approved penalties that compelled drivers to comply with the law. If there are no consequences, why would people keep their speed under the maximum decreed by law? Well, I think that we can all agree that most people would simply ignore the law.
Similarly, it’s been my experience that the same is often true in regards to compliance with contractual conditions. Sadly, at times we all will probably encounter a project manager that simply won’t comply with requests and directives given by the grant office. They may fail to submit their reports on time. Or they may not worry about achieving their outcome objectives per the timeline submitted with their grant proposal.
I was once told by one of my managers that she wasn’t worried about performing all of the promised outcomes because I (the grant office) am great at explaining situations in ways that funders will understand. Well, I’m good but sometimes good isn’t good enough. Funders want organizations to achieve what they were paid to do and often no excuses (however valid we might think they are) are acceptable. This is especially true of federal agencies that expect all of their grantees to perform their stated outcomes – no matter what.
Therefore, it is extremely important that your organization has an established process by which you can address non-compliance issues. Having such a process (and knowing that it will be used) can be a strong deterrent to project managers that may consider not complying with grant office recommendations.
If your organization has established these five practices, I’m confident that you will be able to catch any errors or omissions before an external audit by a funding agency. And while your colleagues may still not be in love with internal reviews, they will most definitely love the fact that visits from your funders will be nearly stress-free.