Thinking Through Post Award Grant Management from a Pre Award Vantage

Picture this – you work at a nonprofit and have a big, audacious project that you are looking to get off the ground. You are carefully researching different funding sources and feel strongly that federal grant funding will help provide the financial boost that you need to get things moving. Seems like a win, right?

For those who have spent countless hours preparing federal grant applications, you know that this isn’t easy. 

• You need to have a strong case statement and adequate responses to the narrative prompts in the application to ensure that you have justification for this funding. 
• There needs to be a robust budget and budget justification that outlines how you will spend your funds, and that these funds comply with federal requirements.
• It is critical to have those partnerships in place to understand how you will manage your relationships with contractors and subrecipients, and their respective role(s) in the administration of the federal grant.
• All required attachments must be formatted and fully completed to ensure that they meet the requirements outlined in the funding opportunity announcement.

But, wait – this is just the beginning of your federal grant management journey. Sadly, many grant-seeking entities do not look beyond obtaining federal funding, which is very risky behavior. If the focus is solely on getting the grant, there are so many things that leave your organization vulnerable, especially during a time when federal grant funding is highly scrutinized.

So, if you are focused solely on the pre-award side, it is essential to at least share with your team or clients why post award grant management really matters and how you should start these conversations during the pre-award process. I’m sharing some key considerations below and you should consider integrating these during the grant submission process.

Unlocking Critical Details for Effective Grant Compliance

Do you remember “Where’s Waldo?” and you had to find Waldo in a sea of other black and white striped figures trying to distract you? This is similar to what you should consider when reviewing the funding opportunity announcement. The funding opportunity announcement is like a window into the federal government agency and allows you to gather intel and critical information needed to prepare for your federal grant submission.

There are so many juicy details – let’s take a look at this sample from a SAMHSA funding opportunity announcement: FY2024 Community-Based Maternal Behavioral Health Services Program (No. SM-24-013).

I have highlighted some items in the table of contents to showcase how you should look at the table of contents from a post-award perspective.

Evaluation – You will need to collect data on your program. It’s not just about putting together a nice evaluation plan in your proposal, but also about how data collection will get done in real time. Will this be done internally or externally? Do you have the systems and tools needed to gather this information? How will you keep measuring your progress?

Financial – Is there a cost share requirement, and if so, what will you be using as the cost share? If there are specific funding restrictions or caps in specific cost categories, how are you accounting for that in your budget, and does this impact your project narrative?

Administrative – You may be required to participate in conferences or meetings once the award is administered, and the costs must be factored into your budget. Also, check the reporting requirements and other legislation requiring your adherence.

Managing Pre and Post Award Compliance Risks

When engaging in grant-seeking, inherent risks are built into the process. Furthermore, many federal agencies assess risk and determine the organization’s financial stability through specific questionnaires that they request applications (and later awardees) complete to ensure the organization’s fitness. Will these financial, operational, strategic, reputational, or other risks significantly impact your organization and its core functions and operations? This is something that needs to be evaluated. I strongly recommend using a risk matrix to assess the impact and severity of each risk and include other stakeholders (within and external to the organization). If you can map out some of these risks before proposal submission, you’ll be well on your way to having comprehensive mitigation strategies in place to keep activities moving and minimize the impact of specific issues as they arise.

It is also essential to assess the potential risks when partnering with other external parties (sub-recipients and contractors). You’ll want to assess the risk so you can determine whether or not to include special conditions in the terms and conditions of the contracts and other monitoring activities that might need to be included. Some questions to consider might be:

1. Have you received federal funding before?
2. What internal controls do you have in place related to the management of grant funding?
3. Can you share the segregation of duties for core financial and programmatic functions related to grant management?
4. What is your policy related to conflicts of interest?
5. Have you ever been debarred or suspended from receiving federal funding?

There are other questions, but this is a good starting point.

If It’s Not Written Down, Does It Exist? Post Award Grant Management Best Practices

The best way to reduce organizational risk and to ensure that your organization incorporates the requirements of 2 CFR 200 is to develop robust policies and procedures. In practice, many federal agencies request these policies and procedures (the natural extension of the internal controls). This covers a broad range of financial, operational, and programmatic elements as required to administer federal grants. 

Through these policies and procedures, you’ll want to answer the following questions:

• Has management designed policies and procedures to handle a wide variety of circumstances?
• Do those documents provide a path for handling the unexpected?

If you do not have core policies documented, how can the pass-through entity, awarding agency, and/or auditor be assured that you will be a good steward of federal funding? Since newer updates are related to the October 1, 2024 Uniform Grant Guidance updates, these must be included in your most recent policies.

I know this is a lot to absorb, but the more you can document and track, the better this will mean for your organization in the long run. Start with the highest priority policies and then go from there.

Questions? Our experts at MyFedTrainer are here to help!