In a recent webinar we looked at a number of burning questions that grant professionals had about the new grant regulations.
And we heard from a lot of you!
In this article, we are going to walk you through three areas of the most burning questions we were asked.
What’s Happening to Grant Management?
The first question is “What’s Happening?”
If you are wondering what got this snowball rolling downhill, it was the change to the new grant regulations released December 26, 2013.
This change consolidated ALL previous grant guidance into one BIG “Super-Circular”
The official name is: 2 CFR PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS,
COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
But it is commonly called the “Super Circular, “Uniform Guidance” or “UG” for short.
When Is This Happening?
The new regulations take effect December 26, 2014.
The part applicable to audits starts with fiscal years AFTER December 26, 2014.
OMB extended a grace period for (JUST) the procurement standards implementation that ended Dec. 26, 2017.
This meant you could operate during this grace period under the old procurement standards, or the new standards standards-as long as you declare which one you are using during that period.
(And the grace period ONLY affects the procurement part of the standards, the rest still “go-live” on Dec. 26th 2014.)
What Are The Biggest Changes?
There are a number of areas that represent big changes from the “old” way of doing things in the world of grant management.
The main areas of change are:
-Internal Controls – Broadened to impact every area
-Risk assessment –before funding and before passing-through funds
-Procurement –stronger definition of processes and procedures
-Performance Measurements – while allowing some flexibility
-Protecting Personally Identifiable Information – This affects nearly everyone.
Let’s look at some of the key areas:
Internal Controls-They are NOT just for auditors anymore
There were more questions about the new requirements for internal controls than any other thing…except possibly procurement.
Internal controls touch every part of the new grant regulations and are a HUGE priority for OMB.
Here are the main points:
>Strong internal controls are a MUST for award recipients
>Focus on structure, policies and procedures and “tone at the top”
>Time and effort reporting is key control point
And don’t forget that official in your organization who is certifying costs must be comfortable with internal controls as well!
Risk Assessment-Check BEFORE You Fund
The next set of burning questions had to do with the new risk assessment.
This requirement of the new grant regulations requires both Federal agencies and pass-through entities to perform a risk assessment prior to awarding funding.
The new grant regulations do talk about the framework this process will take, but we haven’t really seen it in action yet.
Don’t despair!
Once the new Notice of Funding Opportunities include this provision, we will dedicate a future article to what this means to award recipients.
Procurement – 5 Points of the bear claw
In a previous article, we discuss the five methods of procurement covered in the new grant regulations.
Check out these five methods in “New Procurement Rules Clarified By OMB”
OMB has illustrated the new procurement concepts by putting them into a format of a bear claw.
Yes, it is memorable.
(But I have to admit thinking the whole thing could have been explained with a simple table graphic.)
Performance Measurements – Results, results, RESULTS!
Just like the old adage in real estate: Location, location, location.
Results, results, results will be the new mantra for award recipients.
More and more, the Federal government is asking “What results are we getting for the money we invest?”
No more is it enough just to spend the “last dollar on the last day.”
Expect more and more pressure on award recipients to deliver on the promise of RESULTS.
But at the same time, the Federal agencies may allow some flexibility on the compliance requirements if you are meeting the performance measurements.
(This should be interesting to see how it all shakes out as it moves from theory to the “real” world. )
Protecting Information – It’s NOT just IT’s job anymore!
The protection of personally identifiably information (also known as Protected PII) is a new requirement in the uniform guidance.
Much like the new internal controls requirements, it affects a broad swath of people working directly on the grants, as well as people indirectly involved.
Award recipients have much more stringent requirements designed to protect these types of protected information.
And this means involving:
-Program staff
-IT staff
-HR
-Finance/accounting
-Procurement
All these groups should consider:
>Where do these types of sensitive information live?
>How could they be accidentally or intentionally disclosed?
>What safeguards are in place to prevent protected PII from getting into reports and databases designed to capture grant information?
Don’t miss this new requirement in the rush to implement other parts of the new grant regulations.
Want Some Help Protecting Personally Identifiable Information?
(Hint…It’s a MUST with the new grant regulations.)
Click Here to get a copy of our new Special Report: “How Safe is Your Sensitive Grant Information from Exposure?”
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.
