Not always fun, but always necessary!
Federal grant compliance is a topic that may not be sexy, but it is integral to the success of any federal grant you may have received. To guide this conversation, I tapped into the expertise of federal grant compliance consultant and trainer Jerry Bertrand of Public Impact Advisors. Jerry has spent decades in the nonprofit and grant sectors in a variety of leadership roles, specializing in the Uniform Guidance, grant and financial management policies, and their related areas. He currently serves as a trainer, coach, and consultant to a number of federal grant recipients and applicants. If there is a question about federal grants, Jerry most likely has the answer.
I hope you can use this article as a go-to resource when you need to prioritize your activities, as well as cut through some of the online clutter and jargon out there, leaving you more time for your deliverables. And this skill set is not limited to federal grants – it can help you to be competitive for future streams of funding of all types.
Keep “On Track” by looking out for the phrase “Jerry Says” to check out important takeaways. Read on!
With Great Funding Comes Great Responsibility
If you are an organization that has received a federal grant, give yourself a pat on the back, you did it – funds are now coming in, not just going out! And as the mantra goes: “With great funding comes great responsibility” - aka grant compliance.
In many ways, staying in compliance with a federal grant is just as important as securing one. Beyond meeting the grant deliverables, staying compliant indicates your organization is capable of securing and maintaining a complex grant. Staying compliant also creates an ongoing relationship with the federal agency awarding the grant, which bolsters your chances for winning future grants (both governmental and non-governmental).
The Cornerstone of Federal Compliance: Uniform Guidance
While each type of federal grant has its specific compliance measures based on the agency issuing the grant, there are fundamental compliance standards that are common to most federal grants: These are called the Uniform Guidance, also known as 2 CFR §200.
2 CFR §200 is the foundation of compliance for federal grants, and if you were to have a physical copy, ideally it would be annotated and dog-eared from constant referencing as part of your compliance practices.
Jerry Says: This nearly 300-page document (single spaced) should be required reading as part of your onboarding process. As these guidance measures are almost universal for federal funding, you can feel confident that these are the agreed upon standards for the granter and the grantee alike. And federal program and grant officials as well as auditors use these guidelines when assessing compliance.
The Green Book (aka Standards for Internal Control in the Federal Government): Your Companion to the Uniform Guidance
The Green Book, issued by the Government Accountability Office, puts forth a framework for internal controls that the Uniform Guidance strongly suggests federal grant recipients follow. It gives you guidance on designing the internal control systems that will ensure compliance with federal awards. While this is a valuable resource, you should consult with your direct funder in conjunction with the Green Book.
Jerry Says: Keep a copy of the Green Book with your Uniform Guidance document. Both of these documents should be included in your grant portfolio so they can be referenced at any given time during the grant period. This will save you time, money, and headaches along the way.
Jerry’s Handy Tips
Jerry also shared three handy tips to help you stay compliant, and a bonus tip specific to the current federal landscape. These tips are not just helpful for compliance on a federal level, but are good practices as a grant professional in the fundraising and nonprofit sectors.
Tip #1: Create explicit (see: written) policies and procedures on grant compliance, including checklists where helpful, so each staff member knows their individual role and responsibilities.
- Jerry Says: By creating written policies and procedures for each area of compliance, important steps are not missed, and processes can be easily replicated for new staff as your organization evolves. Use the Uniform Guidance, Green Book, and Terms and Conditions of the award as a resource.
Tip #2: Understand common grant compliance findings (in this case, findings are a formal acknowledgement of an instance of noncompliance) so you can steer clear of them. These include noncompliance with Uniform Guidance directives on procurement, subrecipient oversight, beneficiary eligibility, and cost allowability.
- Jerry Says: For example, there are special Uniform Guidance standards related to salaries and wages charged to grants. When charging this time to a grant, document all time worked, both on federal and non-federal activities.
This means recording work beyond your normal work day - no matter how seemingly minimal - including nights, weekends, and holidays. Then ensure charges to the grant for a particular period align with the percentages shown on the timesheet or certifications for the same period.
Through comprehensive timesheets or other validation, you tell the entire story of your efforts. This is a non-negotiable in compliance, and also creates a strong audit trail that indicates the dollars were utilized correctly.
Tip #3: Create a “Culture of Execution”
- Jerry Says: “A Culture of Execution” means compliance should be baked into your organization’s Standard Operating Procedures. To do this, dedicate at least a day or two in each budget year to train your staff about their roles in compliance. This empowers your staff to confidently understand and perform their specific roles in your organization’s compliance efforts.
Bonus Tip: Compliance in Uncertain Times
Politics aside, your grant is directly affected by funding streams allotted by the Federal Government. As we have seen recently, acute events such as a government shutdown can put federal funding on hiatus – known as a lapse in appropriations. These are real dollars, so your organization should be prepared for these situations, even if their occurrence is rare.
- Jerry Says: Don’t fret – there’s a safety net. The White House’s Office of Management and Budget's (OMB) website has a resource page and FAQs addressing how to receive your drawdown funds during a government shutdown, and what to do if there is a lapse in appropriations. This website also includes a list of contingency plans for specific agencies across the federal government.
Knowing and using the proper compliance procedures will keep you on top of your federal grant award, and that’s just where you want to be!
You can also contact Jerry directly if you and your organization are looking for more formal training and coaching through his firm Public Impact Advisors, and of course your GrantStation Membership is your stop for supplies, insight, and resources as your “Mission Train” continues on the “Tracks to Success!”
Jerry Bertrand, Director at Public Impact Advisors, is a consultant, coach, and trainer, helping government and nonprofit organizations flourish. Though federal grants management can be challenging, Jerry brings a seasoned background and practical angle toward problem solving that propels organizations forward. In working with clients, Jerry's approach has been crafted by a career implementing and overseeing social service programs, leading to solutions that are realistic, achievable, and grounded in understanding of the complexities of federal financial assistance. Jerry’s areas of specialty include the Uniform Guidance (2 CFR 200); grant and financial management policies, procedures and systems; cost allowability; avoiding and recovering from audit challenges; and training in all of these areas.