What does an effective grant management compliance program look like?
In our last post we looked at 4 tips for operating an effective grant management compliance program. In this post, let’s expand our understanding by looking at some examples of what an effective compliance program looks like.
Effective grant management compliance programs include these four core elements:
Operating effective compliance programs often require integrating complex provisions, obligations, and regulations.
Sounds overwhelming? Let’s try breaking these components into some examples.
Tip #1: Create
Creating effective policies and procedures can serve as a framework for decision-making on issues the organization may encounter during the life of their grant.
Here are some examples of how creating strong policies and procedures can serve the organization:
• Assisting in making ethical organizational and business decisions
• Assisting in maintaining the organization’s core vision, mission, and values
• Detecting activities and practices that conflict with organizational standards and/or have a negative impact on the organization
• Providing a system to meet regulatory requirements
• Acting as a supportive resource for employees
• Supporting a culture of integrity within the organization and protecting the public reputation of an organization
How to write the best policies and procedures?
The best and most effective policies and procedures are:
• Clearly written
• Include “real life” examples.
• Address both who will be reading and following them as well as the job functions they are designed to address.
• Are regularly and consistently reviewed and updated.
Communication is Critical
Operating effective grant management compliance programs also means creating open lines of communication.
Here are some examples:
• Surveys and other tools for obtaining feedback should be put into place in ways that can be easily accessed.
• Installing an anonymous “Hotline” is a pro-active way for issues and challenges will be reported. (It is equally important to enforce a non-retaliation policy for employees who report problems–in some cases having this type of process may even be a requirement for your grant.)
• Newsletters and internal websites can be good resources to keep employees and other constituents and stakeholders informed.
• The Board of Directors and other oversight groups should also be regularly briefed on the compliance program.
Tip #2: Train
Without training the staff may not understand the expectations related to both the grant and other organizational policies and processes.
The first to be trained must be the trainers. This means all compliance staff.
Training should be carefully crafted and regularly reviewed.
Just as when writing policies and procedures, effective compliance training utilizes “real life” examples.
Training also needs to be geared towards continuous improvement and education.
Here are some examples of ways staff can be trained:
• Encourage staff to attend appropriate conferences and webinars
• Subscribe to related publications and email lists
• Actively network with peers.
• Enroll in classroom and online learning
Next, compliance training should be mandated for board members and other stakeholders. Some types of training that would be relevant to them include:
• Corporate governance
• Grant compliance and oversight
• Organizational leadership
Tip #3: Measure
Here are some examples of effective measurement tools for compliance programs:
• Measurable (quantifiable) goal-setting
• Measurement systems and reporting methods
When goals or benchmarks are not met, it is important to investigate the reasons why, identify problems, and implement solutions. (This is where corrective action plans come into play.)
Tip #4: Review
Examples of monitoring activities include some of the following methods:
• Review compliance to purchasing policies
• Test employee understanding of grant management requirements
• Examine grant spending for proper signatory authorization
• Evaluate conflict of interest policies and compliance
Who should review grant management compliance programs?
An effective way to review and monitor activities is to delegate and empower the monitoring process to teams and employees closest to the issues, regulations, obligations, and activities that must be in compliance.
However, careful attention needs to be paid to delegating monitoring and reviews to parties who do not represent any conflict of interest or inadequate segregation of duties in order to receive objective reviews.
Don’t forget consequences…
Reviews and monitoring processes and practices are ineffective unless policies are consistently enforced and disciplinary action is taken when required.
Lucy Morgan CPA, MBA
CEO, Compliance Warrior