Want to get more federal grants dollars in the future?
Get ready for more up-front scrutiny by the federal agencies.
Federal awarding agencies have a new requirement to perform a risk assessment prior to awarding federal funds.
This is just one of the many changes coming about with the new grant management regulations contained in the new “Super-Circular.”
Federal Grants: Look Before Leaping
Ever seen grant monies spent with seemingly little or no oversight?
The stories in the press certainly give that impression as headline after headline talk about grant Mis-Management and the latest Inspector General report.
To paraphrase Bob Dylan: “The times they are a-changing.”
The new grant regulations call for federal agencies to include a risk assessment prior to awarding federal funds to minimize the risk of waste, fraud and abuse of taxpayer dollars.
Pass-through Entity: Step Into the Shoes
If you are a pass-through entity you get in on the fun as well!
The 2CFR 200 guidance requires pass-throughs to perform this same type of risk assessment for its sub-recipients.
In essence you “step into the shoes” of the federal agency to ensure federal funds are flowing to a sub-recipient who is willing and able to comply with Federal regulations, and the terms and conditions of the sub-award.
This risk assessment should also be used by the grant recipient to determine the appropriate level of monitoring needed for the sub-recipient throughout the grant period of performance.
Risk Assessment: 10 Things to Check
The new grant regulations call for federal agencies to establish a framework for the risk assessment, but stop short of telling agencies and pass-through entities exactly what they need to check.
Feel like you are threading the needle when it comes to the risk assessment?
Fortunately, the new guidance provides several tips on what to focus on.
Here are 10 areas of risk to consider:
• Ability to meet management standards
• Amount of monitoring already in place with other federal agencies or prime recipients
• Evaluation of the application for funding opportunity
• Extent of new personnel or changed systems
• Past history of performance for federal awards and subawards Risky Business
• Previously submitting applicable reports in a timely manner
• Prior compliance with award terms and conditions Risky Business
• Quality of the management systems
• Results of audits such as findings and questioned costs
• Stability of finances at the organization
Reviewing this list of risks can help you prepare for what could go wrong.
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.