Sneak Preview: Policy Updates Should Get Organization-wide Review

October 19, 2017 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) Grant recipients, when updating their internal grant policies and procedures, should ensure that these updates are reviewed by staff so that the entire organization is aware of the changes and trained on how to follow them, a Maryland city official told attendees at the recent Federal Grants Forum in Baltimore, Md., hosted by Thompson Information Services.

As a condition of receiving federal awards under the Office of Management and Budget’s uniform grant guidance, nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the award in compliance with federal statutes, regulations and the terms and conditions of the award (§200.303)(a)) . Having written policies and procedures can enable nonfederal entities to provide this level of assurance when administering an award.

There are many reasons why a nonfederal entity would need to update its existing grant policies and procedures, Jesse Buggs of the city of Bowie, Md., Office of Grant Development and Administration told forum participants. These include changes in federal regulations, new requirements from a funding agency, a change in internal activities or an external relationship, or the implementation of a new organization-wide commitment to improvement. Buggs noted, however, that nonfederal entities preparing to rewrite their policies and procedures should initially develop them in draft form for organization-wide review, prior to adoption and implementation.

“Go through a process of circulating any updates to the policies and procedures through the proper channels so that you can get comments back,” he said. “Allow for staff to comment on [the changes] and then set up a long-term process to make sure that you provide training to staff [on the procedures]. The majority of these [type of] changes are made by management based on certain circumstances or conditions, but staff training is often lacking.”

Buggs added that effective grants policies and procedures also should have a certain amount of flexibility. “Don’t write yourself into a corner,” he said. “Make sure that you have some flexibility in the written document so that you can make adjustments where appropriate within the organization’s operational structure.”

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)


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