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How Strong Is Your Grant Compliance Framework?
Grant requirements can be complicated. Developing a systematic grant management program provides a framework to mitigate against noncompliance. A sound framework includes five main elements. Answering the following questions will help identify areas you may need to strengthen to ensure your organization’s compliance. Who is your grant administrator? This seems like a simple question, but if an organization only has a few grants, grant administration may be one of many roles. Or, responsibility may be shared among several roles. That situation works until the size of the organization and the complexity of the grants make responsible grant management impossible. When the responsibility and complexity of grant management becomes too demanding to include as one of many responsibilities, it’s time to identify one person to take the lead. Eventually, that person may build the team responsible for overseeing and coordinating grant administration. It is easy to see the benefits of having one person develop the full knowledge of grant requirements and take responsibility for establishing policies and procedures for the organization. This person provides guidance for the organization and monitors compliance requirements. They also serve as the point person for grant related audits. Do you have policies and procedures for grant administration? A grant administrator’s first priority is to develop policies and procedures that outline each step in the lifecycle of the grant. Typically, this document will answer the following questions:
- Who approves grant applications?
- Who executes grant agreements?
- What systems will be used to track grant activities, such as qualifying expenses, reporting dates, performance metrics (both financial and programmatic)?
- What documentation is required for compliance?
- Who reviews and approves grant activities to ensure compliance?
- Who develops and manages a schedule and process for annual financial reporting (financial statements and grant reporting, e.g., single audit)?
- Who is responsible for training staff in grant requirements?
- Are subrecipient contracts standardized, and do they comply with your responsibilities as a grantor?
- Who is responsible for resolving audit findings?