The new grant regulations contain over 823 “musts” for Federal grant recipients Human Resources on 2 CFR Part.

So how do you know which ones apply to you and your job managing Federal awards?

In this series we broke all 104 pages of grant regulations for you into a series of questions that focus on the major areas of change in each department.

This article concentrates on the areas affecting the Human Resources Department…

Support Women in STEM Fields:

Expanding opportunities for women in the science, technology, engineering and math (STEM) fields is a public policy focus of the new grant regulations contained in 2 CFR Part 200.

Ask these questions:

1. Does your organization currently have a family leave policy included in your Employee Handbook?

2. Is the organization considering a documented travel policy for all entity travel that allows for temporary dependent care in circumstances that are:

• Above and beyond regular dependent care and directly results from travel to conferences and are a direct result of the individual’s travel for the Federal award and are only temporary during the travel period

3. Do your policies for conference spending support costs for identifying locally available dependent care resources?

Conflict of Interest Policies:

The new grant regulations increase the requirements for standards of conduct both for Federal agencies and Federal grantees.

Take a look at your current employee policies and procedures to determine:

4. Does your employee handbook include a standards of conduct which covers conflicts of interest including:

• The performance of its employees engaged in the selection, award and administration of contracts include a stipulation that no employee, officer, or agent can participate in the selection, award, or administration of a contract supported by a Federal award if they have a real or apparent conflict of interest.
• The officers, employees, and agents of the non-Federal entity must neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.
• A standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value.
• Provision for disciplinary actions for violations of such standards

Internal Controls:

Internal controls are not just for Finance-types any more. 2 CFR Part 200 brings the emphasis on internal controls out of the audit and accounting departments and spreads responsibility for reasonable assurance of the effectiveness of internal controls throughout the organization.

5. What internal controls are in place to mitigate risks of waste, fraud, and abuse of Federal funding?

6. What internal controls are in place to safeguard against any inappropriate alteration of records?

7. How do you safeguard protected personally identifiable information as well as any information designated as sensitive from accidental or deliberate disclosure?

Disclosure Requirements

No more waiting for auditors to “discover” improprieties. Now grant recipients have a responsibility to disclose what they know.

8. What is your process to monitor for conflicts of interest, violations of law and gratuity violations potentially affecting the Federal award?

9. What is your process to notify the funding agency for mandatory disclosures of conflicts of interest, violations of law and gratuity violations potentially affecting the Federal award?

Monitoring

A new level of accountability is designed into the new grant regulations. Grant recipients have increased demands to demonstrate they are monitoring that Federal funds are used effectively and that there are consequences when there are instances of noncompliance.

10. What is your process to evaluate and monitor compliance with statute, regulations and the terms and conditions of Federal awards include contract provisions such as the Davis-Bacon Act?

11. What is your process for taking prompt action when instances of noncompliance are identified?

Well-trained Workforce

The Council On Financial Assistance Reform (COFAR) priorities include developing highly qualified personnel as a cornerstone to better outcomes for grants Human Resources on 2 CFR Part.

Human resources, program offices, and other departments working on Federal awards should ask:

12. How do new staff members receive training on the employee requirements for conflicts of interest, time and effort reporting and other requirements for working with Federal awards?

13. How will current staff members be trained on the new requirements contained in 2 CFR Part 200 Administrative Requirements and Cost Principles?

14. What is your process to support a well-trained workforce through employee development?

Ready to Improve Your Grant Management?

How about you?

Would you like to be a better grant manager?

We have another grant management training seminar coming soon.

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Hope to see you there!

Author:

Lucy Morgan CPA, MBA

CEO, Compliance Warrior

Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.