2 CFR Part 200 may seem like old news to some grant professionals, but for others they may just be getting their feet wet with all the changes in the new grant regulations.
Lots of things have changed from the “old” way of doing things in the world of grant management.
Here are five big changes in the world of Federal grant management:
- Internal Controls – broadened to impact every area of the organization
- Risk assessment –before receiving Federal funds and as part of being a pass-through entity
- Procurement –strengthen processes and procedures
- Performance Measurements – more accountability while also allowing some flexibility
- Protecting Personally Identifiable Information – new privacy rules affect nearly everyone.
Let’s look at some of the main areas:
Internal Controls-They are NOT Just for Finance-Types
There have been lots of 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!
This means a focus on internal control structures, policies and procedures and “tone at the top”
(Hint: Time and effort reporting is key control point!)
And with this focus on 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 area that has had a bunch of questions is 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 purpose of this risk assessment varies depending if you are a funding agencies or a pass-through entity.
The risk assessment by funding agencies determines whether or not an applicant should be in the running for a Federal award or not.
In contrast, most pass-through entities are using the risk assessment to determine a monitoring plan for their subawardees.
This interpretation does vary a bit between Federal agencies, so be sure to check with your funding agency about THEIR view on the risk assessment.
Procurement – 5 Points of the New 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.)
And you have some additional time to get all the aspects of this in place as the OMB has extended the implementation of this piece of the new grant regulations to 2017.
Performance Measurements – It’s all about 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 what’s to know: “What results are we getting for the money we invest?”
(Remember when it was enough to just spend the “last dollar on the last day.”)
This trend of measurable results is expected to accelerate and put more and more pressure on award recipients to deliver on the promise of RESULTS.
Protecting Information – Have You Involved the IT Folks Yet?
How widespread is the knowledge of Federal requirements at your organization?
Here’s one that often gets missed:
The protection of personally identifiably information (also known as Protected PII) is a new requirement in the 2 CFR Part 200 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.
There are much more stringent requirements for award recipients designed to protect these types of protected information.
And this means involving:
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.
And expect even more requirements for IT with the ramp up of the DATA Act in coming months and years.
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?”
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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.