effective grants management from concept to completiona4b6762a... · effective grants management...

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Effective Grants Management from

Concept to CompletionWyoming Association of Municipal Clerks and Treasurers Institute

September 12, 2019

Rachel Chadderdon

Training & Grants Compliance Coordinator

Casper College

SESSION OBJECTIVES

• Understand the full life cycle of a grant: Pre-Award, Award, and Post-Award

• Core principles of grant management in order to administer the project, comply with rules and regulations, and report to the funder

• Ground Rules: • Be willing to share thoughts and ideas• Ask questions as we go and for clarification if needed• Take care of needs

WHAT IS A GRANT?

• A financial/monetary award given by a government agency, foundation, corporation or other entity to fund a particular projectØAwarded through a proposal or application

o Notice of Funding Availability (NOFA), FOA (Funding Opportunity Announcement), Request for Proposals (RFP)

ØReceived for a set of mutually agreeable goals/deliverables

• A grant is NOT free money! ØCurrent climate is very competitive ØMany funders only award grants to organizations they knowØPressure for demonstrating fiscal responsibility and ability meet

project objectives

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WHAT IS EFFECTIVE GRANTS MANAGEMENT?

• Process that provides oversight and monitoring of grant awards that is in compliance with the rules and regulations of the funding source.

• Core principles of effective grants management:

ü Organize for receipt and management of fundsü Develop a task management planü Establish and maintain systems for compliance and financial

managementü Maintain a sound purchasing systemü Follow necessary personnel practicesü Properly manage property purchased with grant fundsü Follow procedures for security, health and safetyü Establish system of quality review and control

• Begins BEFORE the grant is awarded

WHAT IS EFFECTIVE GRANTS MANAGEMENT?

Source: https://research.smu.edu.sg/grant-life-cycle

Grants management is part of the full grant life cycle

PRE-AWARD PHASE

• Beginning of the grant life cycle

ØPlanning and researching grant opportunities

ØProposal development and preparation

ØSubmission of application

ØApplication review

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PRE-AWARD PHASE –PLANNING AND RESEARCH

• Selecting Projects

ØAlign project goals with organizational strategic initiatives

ØAvoid mission driftØ Never chase grant dollarsØ Never design a project to fit a funders requirements

Ø Identify partners and stakeholders

ØCommunicate with stakeholders – project plans and roles

ØSecure organizational approvals


• Project Purpose

Ø Define purpose and need for project

Ø Identify specific goals to reach desired objective

Ø Is grant funding appropriate?

Ø Collect relevant data and documents to support need

Ø What change is expected as a result of the project

Ø What population will be served/impacted

Ø Identify resources needed and timeline for completion


• Finding Grants:

ØGrants.govØAssistance ListingsØFoundation CenterØFederal agency or state websitesØState Legislature or Congressional staffØWyoming Community Foundation (wycf.org)ØProgram Officers and Grants CoordinatorsØBoard Members of private foundations

https://www.grants.gov/web/grants/search-grants.html

https://beta.sam.gov/search?index=cfda

http://foundationcenter.org/

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PRE-AWARD PHASE –PROPOSAL DEVELOPMENT

• Decide whether or not to apply

ØEligibility requirements for the grantØProject fit with grant programØ Likelihood of receiving awardØApplication requirements ØMatch requirementsØ Internal review process – ROIØProject funding requirements vs average grant awardØReporting and compliance requirementsØCompetition


• Special eligibility terms that make award more or less likely

Ø LocalityØ Targeted demographicsØPrevious history with granting organizationØDesignated area such as Rural Business Development Grants

from USDAØQuality relationship with board members or high level

officialsØ Letter of intent (required or optional)ØDue dates and timelineØSimilarity of your project with previously funded projectsØMake absolutely sure you are eligible before applying


• Collaboration, Collaboration, Collaboration!

ØCity and CountyØNonprofitsØCommunity Colleges and University of WyomingØWorkforce and Economic Development

• Ensure buy-in from all the stakeholders/partners

• Coordination - don’t compete internally

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• Will award fund the entire project

Ø If not, what is your contingency plan?o Other sources of fundingo Project phases

ØFactor in other costs along with the direct project costs when looking at the award amounto Application developmento Compliance costs

ØHow will you fund the project after the grant has ended


• Ensure you have time to prepare a quality application

ØStaff availability for writing the grant and assisting with preparation

ØProgram requirements vs the needs and capacity of your organization

ØComplexity of application

ØReadily accessible information

ØStatus of your relationships with stakeholders and collaborators

PRE-AWARD PHASE –APPLICATION SUBMISSION

• Gather Application Resources

ØOrganizational chartsØAnnual reportØAuditsØBudget documents for project and matchØCost estimates (if available)Ø List of stakeholders and letters of supportØPolices – travel, personnel, property, purchasingØWhat else?

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PRE-AWARD PHASE –APPLICATION SUBMISSION

• Finally! Grant Submission!

ØGrants.gov for most federal grantso Requires sign up that can take several days – plan aheado All applications must have a Dun and Bradstreet (D&B) Data

Universal Numbering System (DUNS) number and register with System for Awards Management (SAM)

o Don’t wait until deadline to submito Some federal agencies have their own sites

ØState, Foundation and Corporations will have their own processeso Pay attention to deadlines and submission requirements

Ø Track status of application

PRE-AWARD PHASE –APPLICATION REVIEW

• Review time – patience is a virtue!

Ø Initial screening for completeness

ØProgrammatic review to assess quality and substance of the proposed project

ØFinancial review of proposed budgets

AWARD PHASE

• Middle of the grant life cycle – award decisions and notification

• Three Scenarios:

ØWoo hoo! We got the grant!

ØOh no! We got the grant!

ØBoo hoo! We didn’t get the grant!

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AWARD PHASE – WHOO HOO!

• Kick-off meeting with all responsible parties to ensure everyone understands their respective roles

• Review notice of award/funding very carefully and compare to approved grant application

ü Contact person for funder and granteeü Full or partial fundingü Terms and conditionsü Start and end datesü Match requirementsü Errors, corrections and/or clarificationsü Method of payment ü Deadline for acceptance

• Accept grant and provide assurances and certifications

AWARD PHASE – OH NO!• Do you really have the capacity to accept funding and implement

the project?

• Considerations:ØRestrictive requirements in NOFA and/or NOA

ØChanges in organizationo Staff changeso Partner or stakeholder changeso Matching funds dried up

ØBudget or programmatic revisions/changes

ØWho accepts the grant and timeline for doing so

ØOther reasons to refuse grant?

AWARD PHASE – BOO HOO!

• Review the reasons for denial

• Notify partners/stakeholders

• Request copy of scored application

• Request a copy of proposals that received funding

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POST-AWARD PHASE

• Implementation, reporting, and close out

ØProject start-up

ØManagement and execution of project

ØSubmission of financial and programmatic reports

ØProject completion

ØGrant close out

POST AWARD - PROJECT START UP

• Organize for receipt and management of the funds

ØProject file or binder for all actions and communicationü NOFA/RFP/Application Guidelinesü Submitted proposal and attachmentsü Award notification ü Copy of executed grant agreement and approved budgetü Terms and conditions of the grant and any special provisionsü Amendments and modificationsü Supply and inventory listsü Procurement and vendor selectionü Personnel time and effort worksheetsü Evaluation forms and dataü Financial and programmatic reportsü Other correspondence from funderü Close out and audit documentsü What else?

POST AWARD - PROJECT START UP

• Develop a task management plan

ØPublicize award internally and externally (follow parameters)

ØHire grant funded staffØSet up grant account in accounting systemØRefine scope of work ØConduct regular team meetingsØCalendar of meetings, deadlines, trainings, etc.ØGrantee training – who needs to attendØCross training of staff

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POST AWARD – MANAGEMENT & EXECUTION OF PROJECT

• Compliance is the cornerstone of effective grants management

ØRequires in-depth knowledge of the grant requirements, and having the resources and personnel to meet them

Ø Includes having proper policies in place and strong internal controls


• Potential consequences of improper grant compliance

Ø Loss of funding

ØBad press

ØAudit findings

ØDesignation as ”high risk” grantee by awarding agency


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Mistakes Gross Negligence Criminal Fraud

Recipient includes costs in budget which are unallowable under specific awards. Examples include: Food, Scholarships, Contingencies

Direct recipient failed to implement proper internal controls and adequately monitor sub-recipient activity and expenditures resulting in theft of Federal funds.

Recipients used Federal funds to pay for a wedding reception, building construction, and personal credit card bills.

Categories of Misuse of Federal Funds

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• Recently in the news:

ØDuke University sued for millions over fraudulent data – 60 grants worth approximately $200 million affected – settled for $112.5 million (March 2019)

ØUniversity of Wisconsin-Madison settled for $1.5 million due to allegations related to participation in rebates and discount programs (March 2019)

Ø Three ex-officials at Arkansas nonprofit going to prison for fraud (August 2018)

ØNonprofit owner given jail time for spending grant money on herself instead of summer jobs for youth (August 2017)

ØUC Davis settles grant fraud allegations – paid $499,700 to resolve allegations (December 2014)


• Sources of grant compliance requirements

Uniform Guidance

State Statutes &

Regulations

Terms & Conditions of Grant Award


• The Uniform Guidance

Ø The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

ØConsolidated and streamlined eight previous federal regulations into comprehensive guidance codified at 2 CFR Part 200 (Subparts A – F)

ØSignificant changes to Procurement, Indirect Cost Recovery, Sub-recipient Monitoring, and Time and Effort Reporting

ØNew awards after 12/26/14

https://www.ecfr.gov/cgi-bin/text-idx?SID=6214841a79953f26c5c230d72d6b70a1&tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl

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Ø Subpart A contains acronyms and definitions used throughout the Guidance.

Ø Subpart B discusses general provisions including the purpose of the Guidance, its applicability, and effective date.

Ø Subpart C covers administrative requirements directed primarily at federal agencies including pre-award activities and requirements for the contents of federal awards.

Ø Subpart D includes many of the administrative requirements that will be areas of focus for compliance including procurement, internal control, and subrecipient monitoring.

Ø Subpart E includes reforms to the Cost Principles previously found in Circulars A-21, A-87, and A-122; and

Ø Subpart F includes the reforms to single audit requirements which were previously found in Circulars A-133 and A-50.


• Establish and maintain effective internal controls over federal awards to ensure:

Ø Transactions are properly recorded and accounted for

ØFunds, property, and other assets are safeguarded against loss from unauthorized use or disposition.

ØAwards are being managed and executed in compliance with federal statutes, regulations, and the terms and conditions of the award

• Establish and maintain a sound financial management system

• Financial management is not just for finance staff• Timely and accurate reporting• Expenditures are tied to the grant

Ø If it’s not documented it didn’t happenØSource documentation for audit trail

• Payroll records and time and effort reportsØStaff paid with grant fundsØSignatures


http://www.ecfr.gov/cgi-bin/text-idx?SID=fa23e8067ad4f5db7b4e304f331e45cf&mc=true&node=sp2.1.200.a&rgn=div6

http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=fa23e8067ad4f5db7b4e304f331e45cf&mc=true&n=pt2.1.200&r=PART&ty=HTML





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• Three major components for a sound financial management system:

üAccounting system that meets GAAP for public and nonprofit organizations

ü System of cost management and controls

üReporting system that fairly and accurately documents grant expenditures



• Understand direct and indirect costs• Use the Uniform Guidance and grant agreement for

direction on charging costs to grants.• Costs may be charged to the grant if the cost is:

• Allowable • Included in approved grant budget• Not excluded as part of your grant award notification• Allocable• Treated consistently when charged• Reasonable• Necessary


• Maintain a sound purchasing system

ØUse same process for purchasing with federal and non-federal fundso Must reflect applicable state, local and tribal laws and

regulationso Must conform to applicable federal law and Uniform

Guidanceo Must follow more restrictive rule

ØSee Uniform Guidance Subpart D 200.317 – 200.326

https://www.ecfr.gov/cgi-bin/text-idx?SID=dc18b18d6faedd8607cd73ade02df262&mc=true&node=sg2.1.200_1316.sg3&rgn=div7

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• Allowable Procurement Methodologies

1. Micro-Purchaseo $3,000 ($10,000) o No quotes, must be reasonableo Equitable distribution when possible

2. Small Purchaseso Over $3,000 ($10,000) and under $150,000 ($250,000)o Quotes from at least 2 sourceso No cost or price analysis


3. Sealed Bidso Over $150,000 ($250,000)o Formal process for biddingo Price is major factor

4. Competitive Proposalso Over $150,000 ($250,000)o RFP with evaluation methodso Proposals from adequate number of sources

5. Sole Sourceo Uniqueo Emergency situationo Specific authorization from fundero Inadequate competition after RFP processo Must document justification


• Additional purchasing/procurement requirements:

ØEngage in full and open competition

Ø Take affirmative steps to assure minority and women’s businesses as well as labor surplus area firms are used when possible

ØPerform cost or price analysis for purchases over $250,000

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ØKeep detailed records for ALL purchaseso History of the procurement o Rationale for method usedo Selection or rejection of contractoro Basis for contract price

ØAward contracts only to responsible contractorso Check list for suspended and debarred companies on

www.sam.govo Contractors are subject to same rules and regulations

ØMaintain written standards of conflicts of interest (new)


Ø Individual conflict of Interest – must have documented policy

o No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if that person has a real OR apparent conflict of interest

o A conflict of interest would arise when that person or a member of his/her immediate family, his/her partner, or an organization that employs or is about to employ any of these parties has a financial or other interest in or tangible personal benefit from a firm being considered for a contract

o Must provide for disciplinary actions to be applied for violations


ØOrganizational conflict of Interest – new to the Uniform Guidance

o Because of a relationship with a parent company, affiliate, or subsidiary organization, the organization is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization

ØMust be sure to document policy and process as well as disciplinary actions to be taken for violation

http://www.sam.gov/

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• Personnel PracticesØGrant funded personnel must be treated the same as other

employeesØFollow same HR rules and regulations in hiringØReasonable compensationØ Time and effort reporting

• Property ManagementØ Title, use, inventory and disposition

• Security, Health and Safety ProceduresØBonding of employees, insurance for equipment, research

protections, personal identifying information (PII)


• Subrecipients and Contractors

ØSubrecipients are subject to monitoring, oversight, and compliance with the same rules and regulationso A sub-grant is for the purpose of carrying out a portion of the federal

award and creates an assistance relationship

ØContractors have certain provisions that they too must adhere too Contracts are for the purpose of obtaining goods or services for the

grantee organization’s own use and creates a procurement

relationship

• Determination is a judgment call and rests with the pass-through entity (your organization)

• Document the basis for your determination

POST AWARD - REPORTING

• Financial and programmatic reporting requirements

ØUsually due 30-45 days after the end of each quarter

ØWhere and how to submit reports will vary depending upon the funding agency

ØDeadlines and instructions will be included in grant award noticeo Financial reports collect standard datao Program reports are narrative but usually have character

limits

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ØPlan to report on:

üProject milestones and accomplishmentsüUpdates on any new program partnershipsüGrantee share of expenditures if requiredüDeviations from your approved budget/narrative

o Any changes to your approved scope of worko Did you obtain prior approval for any changes

ü Issue or challenges ü Training or technical assistance needs

ØTimeliness is next to Godliness


ØMonitor budgets to actual expendituresØGrant spending should be distributed over the four

quarters of the project yearØFiscal report expenditures should align with reported

program activities for that same periodØProvide explanation for large expenditures or budget

variations ex) equipment purchasesØBudget reallocations are generally allowed under 10% rule

o Check specific grant provisionso Over the 10% will require prior approval

POST AWARD - REPORTING• Changes or actions that require prior approval

ØChanges in project scope or objectives

ØChanges in key personnel

ØEquipment purchaseso Per unit value over $5,000 and useful life over 1 year

ØMovement of funds between restricted categorieso Personnel, Indirect

ØBudget line item shifts above the allowable percentage

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POST AWARD – COMPLETION & CLOSE OUT

• Evaluation of the project

ØConduct throughout project with a final evaluation at completion

Ø Improves quality and ensures complianceØProvides feedback to improve performance and make

correctionsØSome funders require an external evaluationØAssesses the achievement of stated objectivesØHelps identify exemplary projects


• All close out documents due within 90 days of the end of the grant period

ØFinal program reports

ØFinal financial reporto Unobligated funds balanceo No unliquidated obligations

ØFinal drawdown to reconcile all expenses

ØReturn excess funds

ØProperty close out and inventory


• Post-close out adjustment and responsibilities

ØCosts can still be disallowed based on later audits or reviews

ØReturn of funds due to later refunds, corrections or changes in in-direct cost rates

ØAudit requirements

ØProperty management and disposition

ØRecord retention

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WHEW!! DID WE COVER EVERYTHING?

üOrganize for receipt and management of funds

üDevelop of a task management plan

üEstablish and maintain systems for compliance and financial management

üMaintain a sound purchasing system

ü Follow necessary personnel practices

üProperly manage property purchased with grant funds

ü Follow procedures for security, health and safety

üEstablish system of quality review and control

Core Principles Grant Life Cycle

WHAT DID WE MISS?

Questions?

Clarifications?

Contact: Rachel Chadderdon

[email protected](307) 268-3041

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