Grant management is not just about doing everything right.
It also includes monitoring to make sure things aren’t being done wrong.
Grant fraud and misuse of grant funds is an unfortunate reality of grants management.
Grant professionals should be aware of 9 typical types of concealment behaviors that may indicate grant fraud is taking place.
It’s worth noting that simply because a person exhibits a particular behavior does not necessarily mean they are committing fraud.
However, these warning signs are examples that may require further attention:
Warning Sign #1: Blaming grant regulations
• Blaming mistakes on lack of experience with grant requirements or unreasonable regulations–including giving confusing or irrational explanations for mistakes
Warning Sign #2: Defensiveness about questions
• Annoyance and defensiveness at being questioned
Warning Sign #3: Constant forgetfulness
• Recurring or excessive “forgetfulness”
Warning Sign #4: Promises are broken
• Promising to cooperate but then attempting to obstruct instead
Warning Sign #5: Passive-aggressive resistance
• Subtle resistance; such as giving “too much” information in one area, little or none in another; and answering questions that weren’t asked
Warning Sign #6: Hanging on to the past
• Using “we’ve always done it that way” or, “someone else said they’d take of it” excessively as an excuse
Warning Sign #7: Playing the blame game
• Habitually “blaming” someone else; not taking personal responsibility (using “we” and “our” instead of “I”)
Warning Sign #8: Access during non-work hours
• Willingness or volunteering to work long and/or different hours; refusing or resisting taking time off; demand to do tasks alone; refusal or promotion or change in job functions and accessing/using computers at unusual hours
Warning Sign #9: Lack of disclosure
• Failure to disclose unusual practices or transactions; changing accounting practices without notice or without any instructions for a change
Monitoring Grants Includes Keeping Your Eyes Open
Good internal controls include prevention and monitoring policies, procedures and actions.
A component of monitoring includes being observant of what is going on around you.
Of course, human behavior is complex and can often be misinterpreted.
But the way a person behaves or a change in their demeanor can indicate an attempt to conceal a fraud.
Grant professionals have a duty to their organization, their funding agency and ultimately the taxpayers to monitor grant spending for signs of waste, fraud, and abuse.
What are you doing to make sure your good grants don’t go bad?
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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.