I recently shared an article on LinkedIn on the 7 warning signs for grant management monitoring, and I was amazed by the response!
It felt like people were leaping up from their desks to get their 2 cents in for the top grant management monitoring tips as well!
And many of the ideas were actually much more comprehensive than my humble little post so I wanted to share the top tips with you!
(Thank you to everyone who contributed to the comment thread on LinkedIn!)
What Is Grant Management Monitoring?
First of all, it’s important to remember that grant management is not just about doing all the right things…
It also includes something called “monitoring” which is all about making sure wrong things aren’t being as well.
Monitoring serves a critical function as part of the organization’s internal controls to defend against grant fraud and misuse of grant funds.
With the new grant regulations contained in 2 CFR Part 200, monitoring and strong internal controls may be the deciding factor in whether or not your organization is picked for future grants thanks to the new requirement for risk assessments to be performed by Federal agencies prior to awarding work.
Top Tip’s for Grant Management Monitoring
When good grants go bad, there are almost always warning signs that the grant management train is going off the tracks.
Here are some of the top tips from our readers for monitoring:
Step One: Review the Invoices Thoroughly
When you are getting invoices from subawardees and contractors, take the time to review the invoices completely.
Tip #1: Make sure the math on the invoice adds up.
You would be surprised at how often a simple calculation or math error can trip up even the seasoned budget analyst or grant specialist.
Tip #2: Ensure that the indirect costs on the invoice match the agreed upon (and allowed) indirect cost rate.
Again this seems simple enough, but as we know communication doesn’t always flow as we would like.
(And with a larger organization, it seems even more common)
Tip #3: Require supporting documentation, such as the GL detail ledger that supports the charges on the invoice.
Remember you bear the ultimate responsibility as the prime recipient to keep sufficient documentation to support the costs charged to the Federal award are allowable!
Tip #4: Compare the type of work to the timeline for the work to be performed.
Here are some examples of what to look for:
If you are seeing recruiting costs and you know the hiring phase is over; it’s time to throw up the red flag!
Likewise, if you see meeting and conference spending for “dissemination of results” before there are any results to share that should also have you getting on the phone to the Principal Investigator. (PI)
Tip #5: Make sure the work is completed within the period of performance.
This is one more reason you need to see the detail of when the work was performed.
It’s a small but critical step to avoid disallowance of costs after the grant ends.
Tip #6: Check to see if the PI is reviewing the services on the invoice.
Are they really “in the know” about what’s going on at both on-site and off-site locations?
Does the PI get regular progress reports so they can compare the spending against the project timeline?
Tip #7: Verify that performance objectives are being met by the subawardee and contractor
If the project scope calls for 200 new participants each year and the entire for the year has been invoiced, but only 30 participants have been recruited, you have an issue to investigate.
(And remember it’s yours to catch in your role as a responsible grant manager monitoring the subawardee and contractor effectively.)
Step Two: Examine the Reporting Process
Tip #8: Look for regular monitoring from others
It takes a village to monitor effectively and if you are the only one monitoring spending and compliance you can feel as lonely as the Maytag repairman.
Know who else is monitoring your subawardees and contractors both inside your organization and at other organizations.
The more people checking, the more likely that missteps will be caught.
Tip #9: Are the program and financial reports received on time?
When reporting is delayed, it often signals that there are problems with the results or the processes to generate reliable reporting.
No one wants to be the bearer of bad news.
But when you have the responsibility for effective monitoring of grant performance, you can just about bet that a late report is a sign of trouble.
Tip #10: Read the darn reports!
Do I really have to say this?
You may also be surprised by how many times the reports from subawardees and contractors are viewed as a box to be checked off rather than a source of important communication.
It’s not enough to receive their audit report!
You also need to open it up and look for findings and other warning signs.
Step Three: Actively Look for What’s Missing
Tip #11: Watch the flow of information
When you ask for further details or information do you get stone-walled?
Worse, are you given answers that just don’t add up?
It’s time to look further.
Tip #12: Inspect the written policies and procedures
If the subawardee or contractor doesn’t have key written policies and procedures in place, this points to bigger issues.
Take the time to ask people where the written policies live and what they say.
Having policies that no one reads or understands means people will only follow them through blind “luck.”
Tip #13: Conduct the “sniff” test
As I mentioned before, in most cases the warning signs of grant mismanagement were there for all to see but were still missed.
What is the demeanor of the program and finance staff when you talk with them about the project?
Does the “feel” of the report leave you with more questions than when you started?
We all have a little inner voice that is picking up on signals that we may not want to admit consciously.
Listen to your “gut” and look further.
Remember when Federal funds are lost to mismanagement and outright waste, fraud, and abuse; the ultimate losers are the people who were set to benefit from the Federal award.
Want to find out more about Internal Controls and Federal Grants?
If you’d like to find out more about the internal control requirements for Federal grant recipients, check out the MyFedTrainer.com free special report: The Basics of Internal Controls.
Click here to get your copy.
-Lucy Morgan, CPA, MBA, GPA Approved Trainer