As we approach the end of 2016, its a good time to reflect on all the changes to grant management in the last year.
How’s it going at your organization?
Have you survived the implementation of 2 CFR Part 200 aka the Uniform Guidance?
Are you up to speed with the new regulations or are you more of a work in progress?
Would it surprise you that changes to 2CFR Part 200 keep coming?
The grant management trends that we’ve been talking about show no signs of slowing down.
Here is our perspective on the top federal grant management trends for this year.
Trend #1: Less Understanding
The complexity of grant management has dramatically increasing with the new grant regulations.
And it’s not just grant recipients!
(I hear story after story about federal agencies not accepting things from the new guidance like the new 10% de minimis indirect cost rates!)
Yes, change makes it harder for all of us.
Here are just a couple of examples:
- New risk assessment for both funding agencies and pass-through entities
- Expanded certification of costs requirements for officials able to legally bind the organization
The net results are that the penalties for messing up are more punitive and Federal agencies will have less understanding of grant mismanagement than ever before.
It starts with reviewing risk before awarding funding.
- In the past, often you didn’t get any serious review of your grant until much of the funding was already spent.
It continues by making it increasingly difficult for new applicants without a proven track record to get that first grant, and harder for applicants with audit findings and other issues to keep getting funding.
- Our research showed that over 1/3 of grant recipients has some form of audit findings, and often over multiple years.
And it covers the grant from start to finish with certifications that make senior officials at the organization potentially face harsh penalties included jail time for misstatements, and omissions of material facts.
- No more days of saying you aren’t involved in the day-to-day grant management of the program so you didn’t know things were going south…
Federal agencies are also being held accountable for recovering mismanaged funds from grant recipients.
Trend #2: More Accountability
The new regulations add additional accountability for grant recipients.
You could even argue that the monumental shift of responsibility onto Federal grant recipients is the most pivotal change in grant management in decades Grant Management Trends.
The new risk assessment provisions were expanded last year to raise the bar even higher with the additional requirements for risk and integrity.
(Wondering about the integrity assessment-check out this Q & A article from this summer.)
These provisions affect grant recipients in both pre-award and post-award activities.
And not meeting the new risk and integrity requirements can have lasting effects.
A grant applicant who does not receive a Federal award for reasons of risk or integrity will be deemed to be ineligible for Federal awards. (§200.212)
What’s more that listing will be in the electronic Federal Awardee Performance and and Integrity Information System (FAPIIS) database for five years!
Trend #3: More Electronic Review
The DATA Act is changing the ways grant recipients collect and report results from their grants in the near future.
Increasingly, grant recipients will hear about required data elements that will come about through the implementation of the DATA Act.
This means considerable thought needs to go into how your information will be collected in the future to ensure you are able to comply with the new requirements that will be coming soon.
But the DATA Act is not just for grant recipients.
Additionally, Federal agencies will increase their review of grant recipients through OMB-designated repositories of government-wide data.
And if that is not enough, new analytical tools are coming online that will be at the disposal of Federal agencies to detect waste, fraud and abuse.
These tools will be looking for false claims in the application and and waste, fraud and abuse of Federal funds during the management of the award.
What does this have to do with data collection?
The more data collected, the more ways Federal agencies will have to look for waste, fraud and abuse in grant spending.
It’s the Transparency Act on steriods!
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.