Have you ever made a really big blunder that spells career suicide? Do you wish someone had spared you from the pain? One time I nearly cost my husband his job with a simple mistake that could have had disastrous consequences…and it’s not what you are probably thinking. You see, I didn’t understand that soup tureens have two handles. Let me explain why that matters.
Early in my husband’s career, he invited the president of the company and his wife over for dinner. It was to be a meet and greet that could advance his job prospects and also build relationships between us for the future. Now, at the time we were living in an old farmhouse we purchased a year earlier. If you’ve ever seen the show “American Pickers” you know that often old farm properties are a collection of Americana-sometimes junk and sometimes treasures. This place was no exception and I stumbled upon several old pieces of porcelain pottery for my own collection. I was so proud of my “finds.”
The big day arrived and I slaved over a hot stove slow cooking beef stew, homemade biscuits and apple pie to welcome the boss and his spouse. We greeted them at the door, provided them with the grand tour of the house, outbuildings and wood lot and settled in for the long-anticipated meal. Mouths watered as the smell of cinnamon and fresh baking powder biscuits filled the air. Time to serve the meal…
Small Mistakes Could Have Big Consequences
Now you may be wondering what this has to do with training, especially grant management training…you see, the reason I bring this up is that you never know how one small mistake, innocently made can have big consequences.
Many years ago, I worked with a nonprofit that had a large construction grant program reviewed and years of good work seemed to hang up on whether or not blue jeans could be considered part of a “uniform” or “goods or services for personal use.” The difference meant an audit finding, disallowed costs and the potential payback of grant funds.
All that drama over a small oversight in training!
But back to my story… I went to the kitchen to start dishing up the steaming stew in my prize porcelain “find”-a beautiful one-handled serving dish decorated with flowers and a gold band on the edge. My husband came in to help bring the food to the dining room.
Now, I have to admit. My experience with farm life was pretty limited prior to this move. My husband on the other hand was raised in the rural lifestyle and started his early years in the proverbial one-room country school house. Suddenly, my husband stopped short in his shuttling food to the dining room to ask the following question:
“Do you know that soup tureens have two handles?”
I did not.
He went on to explain the difference between soup tureens and chamber pots was the number of handles. “Chamber pots have only one handle” he calmly explained.
Now for those of you who (like me) were not raised in the finer points of rural living, a chamber pot is what you use during those long cold winter nights when you don’t want to stumble out to the outhouse when it is 2AM. The one handled pot is so that you can reach it from its place of utility under the bed.
Who knew? (Certainly not me-who was about to serve the most important meal of my spouse’s career in the equivalent of a nicely decorated toilet.) Yikes! Talk about career suicide!
Fortunately, my husband’s little bit of training at just the right time saved me from unknowingly sabotaging his future.
In my years of training people on the finer points of federal grant management; I have likewise been able to save grant recipients from sabotaging their grants with little mistakes that have big consequences.
Let’s look at three areas where a little training could Soup Tureens save you from a lot of drama with your grant.
Three Grant Training Areas That Could Cost You Big
Here are three areas where a small amount of training could prevent expensive mistakes.
Mistake #1: Charging Time Based on Budget Instead of Actual Time
This mistake comes up time and time again. In fact, I recently shared a story of an organization that had $20 million in funding stopped for this mistake.Soup Tureens Employees either don’t receive instruction about how to charge their time or they get the wrong instructions.
The Uniform Guidance (2 CFR Part 200) is clear. The final charges to grants should always be for the actual time spent working on the grant, not the budgeted amount. See paragraph (i) Standards for Documentation of Personnel Expenses in §200.430 Compensation—personal services.
Mistake #2: Not Checking or Documenting Excluded Parties Review
This mistake so simple to avoid, yet so frequent that it has its own category in the Federal Audit Clearinghouse-the online repository of grant recipient audit results. These regulations restrict federal funds from flowing to certain types of parties who are debarred, suspended or Soup Tureens excluded from awards, subawards, and contracts.
The first type of mistake happens when no one checks the eligible contractors or subawards in covered transactions (typically $25,000 and over.) The second type of mistake happens when people check but miss keeping documentation that they checked. There is a saying in the world of documentation: “If it’s not in writing, it doesn’t exist.” This means that checking for suspension and disbarment, but not documenting with a screen shot that shows when you checked and who you checked is the same as having not checked. See more at 200.213 Suspension and debarment.
Mistake #3: Ignoring Conflicts of Interest
Even if everything is on the “up and up” letting people with conflicts of interest participate in selection, administration or awarding of contracts and subawards can take allowable costs and transform them into unallowable costs. That is because underpinning the five new procurement methods in 2 CFR Part 200 is that purchases must not be made when there are conflicts of interest.
And conflicts of interests can take many forms affecting employees, agents, and officers, but also parent, affiliate, or subsidiary organizations as well. See more at: 200.318 General procurement standards.
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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.