17 Questions: A Cheat Sheet for Program Offices Implementing the New Grant Regulations

In our last article we talked about 14 questions your Human Resources Department should be asking about the new grant regulations. In this article, we switch focus to the Program Office and sift through the 823 “musts” for Federal grant recipients contained in 2 CFR Part 200. Grant management training for Program Staff has even more major areas of change when it comes to the new grant regulations. Here are 17 questions for your Program Staff to ensure they are getting up to speed on the new grant regulations…(without needing to digest all 100+ pages of the Administrative Requirements and Cost Principles) Performance Measurements:

1. Do current or past awards include performance measurements?
2. How do you communicate the ways performance is measured by your funding agency to program staff and others?
3. How do you monitor activities under Federal awards to assure performance expectations are being achieved for each program, function or activity?

Risk Assessment:

4. Do Federal funds pass-through to subrecipients for any of your awards?
5. If so, are you familiar with the new risk assessment requirements that must be done prior to awarding work?
6. Do you have a risk assessment framework and monitoring plan for your subrecipients in place yet?

Internal Controls:

7. What internal controls are in place to mitigate risks of waste, fraud, and abuse of Federal funding?
8. What internal controls are in place to safeguard against any inappropriate alteration of records?
9. What internal controls are in place to ensure compliance with Federal statutes, regulations, and the terms and conditions of the award that could have a direct and material effect on a Federal program?
10. How do you safeguard protected personally identifiable information as well as any information designated as sensitive from accidental or deliberate disclosure?

Cost Principles

11. What is your process for program staff to review spending on the Federal award for allowability of costs?
12. Have your reference materials, training resources and forms been updated to reflect the new Cost Principles in Sub Part E of 2CFR Part 200?

Time and Effort Reporting

13. How do you provide reasonable assurance that the charges for time and effort reporting are accurate, allowable, and properly allocated?
14. Describe how direct employees know what activity/code (such as a federal award) to charge their time to.

Well-trained Workforce

15. How do new staff members receive training on the requirements and restrictions for grant management of Federal awards?
16. How are current staff members trained on the new requirements contained in 2 CFR Part 200 Administrative Requirements and Cost Principles?
17. What is your process to keep staff up-to-date on changes to grant guidance and the terms and conditions of specific Federal awards?

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. Click here to get all the details! 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.