Compliance in the Midst of Chaos:

Managing your federal award when everything is URGEN

T

Learning ObjectivesManaging your federal award when everything is urgent:

Introduce management tools for determining true “urgency” in project management “Triage” of requests System Implementation

Review regulatory options and supplements that streamline project management 2 CFR 200’s Fixed Amount Award (FAA) 10% “de minimus” for indirect cost

Discuss “rescue” techniques for overburdened projects experiencing ongoing chaos Vin Diesel model Angelina Jolie model Liam Neeson model 007 model

Determining “Urgency”

“Triage”

Commonly used medial term with grant-management (or project management) applicability

─ Ignores non-critical “deadlines”

─ Considers core issue and ability to resolve

─ Question to ponder when all things equal: “what is the consequence of inaction”

Triage in Grant Management

Creating Systems/Processes

“Systems/Processes”Development of a consistent, documented and repeated method for responding to events or implementing activities:

─ Systems should eventually become invisible, it just becomes “the way we do things”

─ True systems are taught and re-taught so that everyone understands what happens and when

─ Systems do not have to be complicated, they can be as simple as a checklist, template or chain of communication

“Systems/Processes”

Regulatory connection to the establishment of “systems” is “internal controls”

Your internal controls should check whether or not your “systems” are consistently applied

Examples of systems: files for your grant records; methodology for monitoring sub-grantees; procurement process

____ Current mission / vision / values statements

____ Board member recruitment system

____ Board member orientation system

____ Board development and training strategies

____ Attendance policies

____ Membership and term limitation policies

____ Organizational chart

____ Chair and officer job descriptions

____ Committee charters

____ Board operations and policy manual

____ Chief executive performance review process

____ Board self-evaluation process

____ Board calendar with meetings, events, activities and updates

____ (Other items:)

BOARD OF DIRECTORS

Recommended “Systems” Check:

Recommended “Systems” Check:

____ Current strategic plan

____ Diversity plan (for Board and staff)

____ Marketing plan

____ Fundraising / Development plan

____ Board and committee work plans (with objectives and timelines)

____ Yearly operations plan, including staff work plans

____ (Other items:)

PLANNING

____ Valid methods to assess client needs (focus groups, surveys, etc.)

____ Established service outcomes to match client needs

____ Established target indicators for each outcome

____ Data collection methods for each target indicator

____ (Other items:)

PROGRAM AND OUTCOMES EVALUATION

____ Client program records

____ Volunteer records

____ Personnel records

____ Financial records

____ Donor and contributor contract records

____ Mailing lists

____ Work flow descriptions for each major operational activity

____ Operations manual containing work flow descriptions

____ Inventory of computer hardware, software, peripherals, etc.

____ Procedures for each major function to maintain computer systems

____ Regular backups of computer disks (one copy stored offsite)

____ Disaster recovery plan (one copy stored offsite)

____ (Other items:)

Recommended “Systems” Check:INFORMATION MANAGEMENT

____ Board-adopted fiscal policies

____ Board-approved fiscal year budget

____ Financial procedures / internal controls manual

____ Inventory system

____ Depreciation schedules

____ Cash flow analysis system

____ Partial or full accrual accounting system

____ Monthly financial statements with balance sheet

____ Yearly audit or outside review

____ Program analysis system

____ Tax and other reporting schedules

____ Payroll record system

____ (Other items:)

FINANCESRecommended “Systems” Check:

Systems/Processes

“Grant managers, stay in your lane!”

Systems/Processes Grant management is directly connected (but not

always engaged in) organizational systems

2 CFR 200.303 (a) Internal controls require that your organization “establish and maintain effective internal controls over the Federal award that provide reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”

Systems/Processes

Grant managers help the entire organization apply the regulations and Standards for Internal Control in the Federal Government is a part of that

Grant managers have a perspective that differs from, but compliments leadership and program management

Useful tools for “systems” check:• http://

managementhelp.org/organizationalperformance/nonprofits/systems-checklist.htm

• http://www.gao.gov/assets/670/665712.pdf

• https://www.mango.org.uk/guide/healthcheck

Regulatory Tools to help with managing

“chaos”

OMB “Super Circular”

• Developed by the COFAR- Council on Financial Assistance Reform beginning in 2011

• COFAR established by Obama Administration with intention of enhancing transparency of Federal spending and advancing efforts to detect and remediate fraud, waste and abuse in Federal programs

Super Circular…

• Incorporates OMB Circulars A-21, A-87, A-110, A-122, A-89, A-102, A-133 and A-50

• For states, tribes, colleges & universities, hospitals and non-profit organizations

• Applicable to Federal agencies 12/26/13; non-Federal entities 12/26/14

“Super "Circular does/states…

The intent of the new guidelines is to do the following:

• consolidate existing regulations,

• streamline processes,

• harmonize rules and regulations that seemed contradictory; and,

• simplify.

2 CFR 200

Two “new” regulations for easier grant-management:

1. Fixed Amount Award

2. Ten percent (10%) de minimus cost for indirect expenses

2 CFR 200.201:

• Introduces the “new” awarding instrument: Fixed Amount Award(FAA)

• FAA require no governmental review of actual costs incurred before completion of the award

• FAA may be used if the project scope is specific and if adequate cost, historical, or unit pricing data is available to establish a fixed amount award with assurance that there will be no increment above actual cost

• Introduces an option for applying a standard 10% of modified total direct costs to new awards to cover indirect expenses

• If used, it must be applied to all federal awards until the organization pursues a Negotiated Indirect Cost Rate Agreement (NICRA)

• Helpful for smaller organization with no NICRA and multiple awards

2 CFR 200.414:

Regulatory tools to help manage chaosGrant management tools can drive solutions to chaos when used as a part of overall project management:

Regulations are sometimes the only solution

COFAR considered “real life” experiences of grant management professionals when drafting 2 CFR 200, so regulations may capture an organizational problem others have already conquered

The union of Grant Management & Project

Management:

Action Hero Inspired “Solutions”

Angelina Jolie Model: Be Adaptable

Address problems by:

Changing to meet the needs of the individual and circumstances

Remaining nimble in decision-making with limited inherit bureaucracy

Requires autonomy

Vin Diesel Model: Strategy & Team Work

Address problems by:

Playing to the strengths of your team

Engaging multiple “voices” in decision making

Gathering facts and creating a plan before taking any action

007 Model: Classic & Decisive

Address a problem by:

Making a decision and taking action. Period.

Requires unilateral authority

Liam Neeson Model: “I have a particular set of skills”

Addresses a problem by:

Cultivating a level of expertise in one field

Creating a model based on acquired expertise

Consistently applying the model

Which “action hero” could best resolve the “chaos” using which grant management tool?

Scenario 1:

For your small nonprofit organization, your newly hired program director has been asked to wear many hats. In addition to his/her project management duties, they also serve as a compliance officer, grants manager and H.R. director. After all, there are only five people on staff.

While reviewing your largest project’s financial records, the new program director notices that several payments have been directed to a member of your board of directors for sole source consulting services. There are no invoices, consulting contracts or even a statement of work to support the payment. How would you address this problem?

“Action Hero” inspired solutions:

A. Be Adaptable

B. Apply Strategy & Teamwork

C. Be Classic & Decisive

D. Apply a particular set of skills

Scenario 2:

One of your project managers has sent 15 emails in the past 24 hours because he/she is concerned about having enough money available for payroll. It seems that one of his/her funders did not send additional funds for completed program activities on a grant with established milestones. He/she is frantic and does not understand why the funder has not sent money for the completed activities. Now, he/she will need an advance to cover expenses for an upcoming training conference in addition to the money needed to cover payroll.

You pull the grant and financial records for the project. After reviewing everything, you note that the project never requested an additional obligation of funds including a request for an advance as permitted in the grant agreement. A programmatic report was submitted to the funder. But, a financial report showing that the first milestone was met, and requesting the tranche of funds for meeting the milestone, was not submitted. The grant agreement requires both for payment. How would you address this problem?

Which “action hero” could best resolve the “chaos” using which grant management tool?

“Action Hero” inspired solutions:

A. Be Adaptable

B. Apply Strategy & Teamwork

C. Be Classic & Decisive

D. Apply a particular set of skills

Need more information?

Feel free to email or Skype me:

• Skype: Atoundra

• Email: alawson@pactworld.org

Thank you