Is the idea of the new grant regulations making you feel unsettled Super Circular Mistakes ?
Maybe even a little anxious?
Here are two common OMB Super Circular mistakes that you may not even know you are making.
Mistake #1: Living In The Past
Since the founding of United States, federal grants were historically seen as a gift with a few “conditions” thrown in.
Even the Federal government didn’t seem to take the concept of performance and accountability too seriously.
Audit findings continued year after year, and many times no serious monitoring of how grant funds were spent occurred until after the bulk of the funds were long gone.
We have entered a new time in the evolution of grant management with the OMB Super Circular changes.
Some are even calling it “The New Age of Accountability.”
And similarly, the concept of performance measurements contained in the new grant regulations can feel a bit intimidating.
What the Olympics Can Teach Us About Performance Measurements
The Olympics can teach us a lot about living with a world of performance measurements.
This is especially true if the idea of performance measurements is a new concept for staff at your organization.
(And in areas like research, it may feel nearly impossible to create concrete performance measurements in the uncertain world of exploration and discovery.)
Performance is What Matters
In the past, making an effort may have been “good enough.”
But now it is performance that matters.
At the end of the day, no one wants to hear that you worked really hard to get to the Olympics.
They want to know if you won a medal.
The same applies to managing grants.
In this new world of the OMB Super Circular, achievement of results is paramount.
And that takes clear performance measurements that are known and understood by the program staff.
How are these changes in the grant environment being communicated at your organization?
Mistake #2: Still Passing the Buck
Let’s face it.
The old days of grant management often didn’t drive a high degree of accountability with federal spending.
Past program staff, past administration and past lack of understanding were often blamed for spending problems.
The promise to do better in the future was seen as all that was required for more grant funding.
Just put together a corrective action plan and it was off to the races again…
That’s all changing with the new certifications and disclosures contained in the OMB Super Circular changes.
Now high ranking officials will be required to get some “skin in the game.”
No more blame game or pointing fingers about a few uninformed employees Super Circular Mistakes …
Warning: Certifications by High Ranking Officials Required
The new grant regulations contain a “Certification of Costs” to be completed by a high ranking official with the authority to legally bind the grant recipient.
This new requirement includes provisions for prosecution for false statements and omission of material facts under the False Claims Act.
It may be a totally new experience for some as they realize the “buck stops here” when signing on the bottom line.
Are your officials comfortable enough with the “nitty-gritty” details of program spending to say:
‘‘By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash Super Circular Mistakes receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award.”
Do You See Other Mistakes Being Made?
What do you think?
Are there other areas that you are concerned about?
Do you see other disasters just waiting to happen?
Let us know what’s keep you up at night.
We’d love to include these in a future discussion.
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!
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.