Finding Proof in Grants Management Procurement Solicitations

In December 2022, NGMA hosted a webinar presented by Mara Ash entitled “What Do You Need in Your Grant Procurement Solicitations to Ensure Your Procurement is ‘Finding Proof?’” Below are the key takeaways from her presentation. Missed the live webinar? Past webinar recordings are available to members at no cost here.

There is so much going on in grants these days. Trillions of federal dollars have been awarded and more funding is on the way. More money means more projects, more purchases and more ways to get into trouble.
Procurement is the largest area of questioned costs in grants. The amount of information out there can be overwhelming and confusing. So where do you start?

Know Your Requirements

Yes, we always say you need to know your requirements. But how do we know which requirements are applicable? Well, you can start with 2 CFR 200, Uniform Guidance, which applies to all grants. There may be some exceptions to 2 CFR 200, and that will be in your terms and conditions related to your grant. Your terms and conditions can have additional requirements on top of 2 CFR 200. Here’s what we recommend: Take all of your requirements and create a compliance matrix to determine the requirements and which requirement trumps another requirement. As a rule of thumb, the terms and conditions of your grant will lay out which requirement takes precedence.

  • For local and nonprofits:
    • 2 CFR 200 from §200.318 to §200.327
  • For state entities and quasi-state entities:
    • §200.317 + §200.321, §200.322, §200.323
  • Local policies:
    • Must comply with all local, state and federal laws, rules and procedures.
    • Do not need to have a separate policy for grant procurements; however, you should consider what needs to happen differently for grants.
  • Terms and conditions of the grant:
    • Search for specific terms related to purchasing.

Documenting Grant Procurements

What is considered grant documentation? Well, everything in the procurement process, from your procurement policy to the vendor execution.

You don’t need to have a separate policy for grant purchases; however, you do need to understand how grant procurements are different and they must be addressed. This difference needs to be documented. The policy and this documentation get your procurement started right. Policies must reflect how purchases are made, from advertising to selection for both formal and informal purchases. Federal grantees are encouraged to use “schedules” or “co-ops” which are procurement methods performed by one agency for use by multiple agencies. Schedules and co-ops reduce burden, cost and time to selection.

Grantees must document the selection process as well as the procurement. This includes who was on the selection committee, how they scored, i.e. rubric, and how the vendor was selected. Remember to add the grant terms and conditions to your solicitation and award. This ensures your vendor will meet your grant requirements as well as ensure the project will get done on time, in-budget, and in-scope.

Boom! Procurement Done!

I’m finished now, right? No. Now begins the fun of post-award monitoring. Why is that important? Well, a good monitoring program will allow you to ensure procurement costs are allowable, especially when the grant procurement is part of forced accounts. Post-award monitoring should be done at a level to reduce the risk of non-compliance, poor performance or risk of not completion. When monitoring, don’t forget to verify all terms of your contract are being performed and integrated by your vendor.

Hot Tips!

Does the procurement documentation tell the complete “story” of the procurement – from the initial invitation to the award of the contract? Every part of the process should be documented. If you didn’t document it, it didn’t happen. Below is a quick list of things to check.

  • Federal, State and Local Procurement Compliance
    • Is the procurement consistent with your entity’s procurement policy?
    • Is your entity’s procurement policy compliant with federal and state procurement compliance?
  • Allowable Costs and Cost Principles Compliance
    • Are costs allowable as per the grant terms?
    • Are costs consistent with the 2 CFR 200 cost principles?
  • Devil in the Details
    • Keep detailed documentation about everything from the scope of work to the selection.
    • Document post-award monitoring and how you as a “responsible” grantee are mitigating the risks posed by vendors.
    • Perform self-assessments regularly through either internal audits or regular reviews to ensure you are following your procedures and the procurement was compliant with federal, state and local policies, as well as grant terms and conditions.
  • Um, I Still Need Help!
    • Managing grant and all the requirements:
      • nnnThere are many consultants out there. Using a consultant doesn’t mitigate your requirements. The biggest bang for your buck is a good compliance matrix so you can check and double-check as you go along.
    • Outsourced and co-sourced post-award audits:
      • You don’t need a certified accountant for this work. These can be performed under GAGAS or Internal Audit standards.
    • Preaudit assessments:
      • Before the auditors arrive on your doorstep, perform a pre-audit assessment. This will help you understand what or where you are deficient in your processes as well as the opportunity to fix them before the auditor shows up. You can do this on your own or hire someone to help!

Mara Ash is the CEO of BFS Strategic Partners, a client-focused management and consulting firm. She has over 25 years of financial management, compliance, audit and consulting experience serving all levels of government and nonprofit organizations.

Grants Management Advice to My Younger Self

Changing careers in mid-life is always daunting, but I’ve done it before. When I accepted a new job as the planner (a/k/a grant manager) for a metropolitan police department, I anticipated being able to draw on my research, writing and mediation skills. I had fairly extensive experience working in grant-funded programs and writing grants for various state and nonprofit agencies. While with FEMA, I worked with both the local military and state administrative agencies during pre- and post-disasters, so working in this venue felt comfortable and was an easy transition for me. However, what I was not prepared for was how dynamic, challenging and FUN this newly-minted profession of “grants management” was to become.

When I started, there was no such profession as “grants management.” An agency would apply for grants to federal, state or philanthropic grantors, receive an award and hand it over to their finance department to administer and account for the expenditures. Once every year or so, you waited for the auditors to show up and go over the books. Little did I know the system was teetering on the brink of transition.

As my feet were getting wet and I was beginning to understand the intricacies of individual grant programs and how each system worked…WHAM the whole thing changed! The federal rules were completely rewritten. Multiple and disparate sets of federal compliance, guidelines, circulars and administrative rules were consolidated and streamlined into one overarching Uniform Guidance. Additionally, a tsunami of federal funds flooded the marketplace in the form of the American Recovery and Reinvestment Act. As a consequence, federal oversight flipped from routine auditing of financial compliance to site monitoring for vaguely defined “performance outcomes.” The question I, as a grants manager, became accountable for changed from “Did you spend the grant money correctly?” to “What did the grant funding actually accomplish?”

It was a complete paradigm shift. Many experienced grants professionals left the field, taking their history and experience with them. As a newbie, it was an exciting time to be an active part of a new national focus on transparency and accountability. It was awesome! And now, here we are once again. Another paradigm shift is in progress. All the old rules and systems are again being revised and revamped. Another “wave of change” is offering the grants community more opportunities to learn, grow and improve our profession.

I entered this field on the crest of the wave of change in grants management. I waxed up my board (training and conferences), paddled hard (submitted lots of applications), caught the swell (systematized internal processes) and locked in for the ride. I’ve been riding that wave now for 17 years, and I still feel the rush.

A few guidelines that got me through the first few years in the field are summarized below. I would have loved to receive this advice from the start and hope it can help those who are early into their grants management career.

  • Make a list of ACRONYMS.  Carry it with you. Keep adding to it.
  • Do your job with ALOHA– compassion, understanding and respect. Being courteous, professional, respectful and friendly goes a long way in building relationships. For me, living in Hawaii and being able to call someone who’s a kindred spirit and located six time zones away to “talk grants” is invaluable.
  • Be ETHICAL. We are in a field that is under constant scrutiny. You are the fiduciary of public funds. You hold the public’s trust to fulfill the terms and conditions of that funding.  Maintain scrupulous records and set a high bar for accountability.
  • Be PASSIONATE about grants! This profession is doing good work. The projects funded are vital. You make a difference every day with each project and program, meeting community and organizational needs that would otherwise remain unfulfilled.
  • Be PATIENT with yourself. There’s a lot to learn and absorb. Mistakes will be made.  Applications won’t be funded the first or even the second time around. This is a highly competitive field. Keep learning and improving and don’t give up.
  • Have FUN! Every day is an adventure. The unexpected always comes up. Each challenge is an opportunity to learn something new and to grow your skillset.

The best thing I did when I was starting out was to learn to look at grants management from all sides, and to expand my skills. I approached my job as a puzzle to piece together. I enlisted help, teamed up, and together we celebrated our WINS and commiserated our LOSSES. But most importantly, we kept trying. Today is an exciting time to enter the profession of grants management. Please become part of our welcoming community. Catch your own wave, and lock in for the ride of your life!

Lynn Miller, CGMS is a grants supervisor at the Honolulu Police Department in Honolulu, HI. She has been a member of NMGA since 2007 and has served on the education and membership committees, as well as other advisory roles.

Establishing Trust with Clients as a Grants Management Consultant

My grants management career is quite varied. I began my career in grants management over 25 years ago while working for a local municipality. In 2019, I switched gears and established my own consulting company, a minority woman-owned small business called KLR Consulting Services, LLC. As an entrepreneur, I quickly noticed the difference in my grants management day-to-day tasks and how I accomplish them. My focus and responsibilities expanded from simply completing tasks required by an organization to completing tasks for my own business and, most importantly, building trust with clients. Building trust is a key component in managing any successful consulting business. How do I go about it?

A few tried-and-true tactics that have been successful for me are:

1) Be transparent with your clients. Share good and bad outcomes. You can’t always have good outcomes, but whether the news is good or bad, a client should always be fully aware of where their project stands. Sharing bad news is never easy, but doing it in a courteous and straightforward manner and offering alternate solutions whenever possible goes a long way.

2) Regularly engage with your clients and establish an open-door approach. Keep your clients posted on a regular basis. Whether it’s via weekly emails and/or regular meeting dates, do what works best for you and your client. Maintaining regular engagement and ensuring your clients know they can reach out to you anytime is a critical step in establishing trust.

3) Ensure your interaction with the client is professional and, most importantly, sincere. Behaving in a professional way is common sense advice for anyone. But being sincere in your interaction changes the game. When working with clients, I manage their projects as if they were my own. Their success is my success and vice versa. I genuinely want the best outcome for all my clients and I make sure they know this every step of the way.

In all my projects, I provide an abundance of attention to the management and compliance issues associated with my clients’ projects. I share with them any areas of risk and give them the opportunity to correct them. I have found that being transparent with my clients gives them a sense of relief. It makes them feel good to know that they have partnered with a consultant that has their best interest at heart.

Transitioning from working for an organization to becoming a consultant in the same field of work is a challenging and sometimes overwhelming experience! Through the ups and downs, these things hold true: Service, dedication and genuine caring are the most powerful assets a consulting business in this or any field of work can have. I am proud to say that my consulting business embodies them all.

Kellie Russell is the CEO of KLR Consulting Services, LLC. She has been a member of NGMA since 2019 and currently serves on the NGMA Education and Membership Committees and is the Chair of the NGMA Atlanta Chapter.

Best Practices for Tribal Grants Professionals

Tribal grant managers are tasked with an array of duties. Not only do they have to be experts in their field- housing, policing, justice systems, social services, language and culture, but they also must have basic knowledge of grants management. From pre-award to post-award, a tribal grants manager should have a grasp on the ability to help draft a grant application, know how to read an award letter, budget development, budget monitoring, the ability to navigate software, rules, and regulations of their grant, and more. This is a larger task than some may believe.

Many factors play a role in why a tribal government is truly successful in the overall scope of grants management. The integrity of a tribe’s grants administration depends upon the knowledge and experience of its grant professionals, who must thoroughly understand their duties and responsibilities. With that, I offer five practical best practices for grants professionals — I’ve had to do each of these myself– who work for a tribal government.

1)    Establish grants management policies and procedures. If there are no grants management policies and procedures, advocate for their development. Grants management policy and procedures help formalize the grant proposal-seeking process, proper execution, the management of funds, and close-out processes of the tribe’s grant awards.

2)    Don’t get stuck on your “island.” Set up coffee breaks with fellow grants managers. Get to know the staff in other departments. Find out who is a grants management “champion,” and ask them to take you under their wing. Find out your contacts’ training history, how they learned to manage a grant, what tips they may have for you, and more.

3)    Establish a grants management training plan. Formalized training in grants management is highly effective. This can come from professional organizations, such as NGMA, or higher educational institutes. Take a grant writing course even if you are not responsible for writing grants. This will be very helpful in learning the “behind the scenes” efforts it takes to obtain a grant and providing insight on how to manage it once received. Be the driver of your professional development plan.

4)    Make your project officer your new best friend! Do not hesitate to reach out to your grantors and seek any resources they may have. They are there to help! Your success is their success.

5)    Leverage your resources and promote the skill. If funds are not available for grant-writing professionals, create your own. Your people are your best resources. If at least one person in your organization knows how to write a grant, offer community training to help others gain interest in the profession.

The role of a grants professional is essential in Indian Country. The work you do helps provide families’ homes, feed the elderly, provide childcare, teach the youth, promote education and career development, ensure public safety, improve infrastructure, maintain lands, restore languages, and enhance the overall quality of life for many. I hope this information helps you in obtaining the guidance and support you need to succeed in your roles.

Sabrina Renteria is a Relationship Manager at FSA Advisory Group, an American-Indian and women-owned firm that provides financial advisory services in Indian Country.

Six Techniques to Finding Grants Management Solutions within Your Organization

One of the greatest benefits of the National Grants Management Association (NGMA) is the wealth of knowledge we can obtain from several great resources at our disposal such as:

  • Grants Management Body of Knowledge (GMBoK) Training
  • Annual Grants Training (AGT)
  • Current and past webinars
  • NGMA Network message board

Yet, as grants specialists, we struggle with how to share with our teammates and co-workers the knowledge about guidance and regulations that is trapped in our heads and screaming to get out in a way that is effective and clearly understood.

As it’s been fondly stated many times, learning about grants is like drinking from a fire hose. While this is true, why don’t we take control of that fire hose and be a firefighter? After all, in the grants world, we are often moving from one fire to another, right? What makes a firefighter successful is the training and education they receive formally and on the job. To define it further, how a firefighter can apply their education and practical skills is what makes them successful in protecting lives and property.

In grants management, training and education provide a solid foundation for internal controls throughout the entirety of the grant cycle. A simple Lean Six Sigma1 technique known as DMAIC (Define, Measure, Analyze, Improve and Control) can be used to find a solution for challenges in your organization. I have found using these techniques to be successful in my own practices.

Define – Identify Needs

Look within your organization to determine what your challenges are. Often, a simple self-assessment or a survey is enough to get a snapshot to understand your organization’s strengths and weaknesses.

Measure – Mapping the Process

Mapping out your organization’s processes and how the Code of Federal Regulations (CFR) impacts your organization gives you a solid understanding about what is missing. As you start to analyze what your challenges are, you can find ways to improve them, like developing trainings. You can add additional “swim lanes” to determine how agency-specific guidance or state regulations and statues impact your organization and the process.

Analyze – Find Focus and Solution

Using the challenges that have been identified in your organization within the grant lifecycle, you will find a lack of formal and consistent training is often the root cause of many issues. This could be long-term employees who need to learn the changes within the CFR guidance or new employees who have never worked on a grant before.

Determine if you want to consider contracting an outside consultant to assist with training or if you want to implement training in-house. Factors such as budget, capacity, space and scheduling should factor into your final analysis.

Improve – Implement the Trainings

Take action to tackle the identified issues, come up with a plan or strategy to develop and implement these trainings.
Every organization is different and how you implement your training is up to you! Choosing the appropriate platforms is crucial and may cover a variety of methods including:

  • Training courses (in-person and/or online)
  • Recorded presentations
  • Written manuals and materials

The attention span of the average person in a training or educational setting is very limited. It has been widely debated how long an attention span may be for the average person in a session. Below are a few tips to help keep your session lively and make the best use of your training time for maximum impact:

  • Keep your sessions short. Longer trainings should not exceed two to three hours and short sessions or quick updates should be no more than 20 minutes.
  • Plan time between trainings and allow attendees the opportunity to use what they learn.
  • Don’t get bogged down in the details. Distill the information into short factual points. Keep it simple.
  • Teach attendees where to find the answers at the source.
  • Plan exercises – find methods in the training to keep the group engaged and foster teamwork.
  • Make the course interactive. Don’t just lecture, involve the audience in your session by:
    • taking questions throughout your presentation,
    • giving examples and stories,
    • showing videos,
    • giving live demonstrations,
    • adding funny photos, memes and artwork,
    • calling on people to share their experiences,
    • and asking questions.
  • If possible, provide snacks and water – foster a friendly and welcoming environment. Did you know that hydration is key to cognitive processes? It keeps the blood sugar levels up!

Control – Maintaining the Solution

Now comes the easy part! Set the trainings as part of your regular offerings within your organization. Make sure to budget, if needed, or secure resources to continue the program.

Take surveys to get feedback from attendees on how to improve the process even more. Listen to your audience – they are your customer!

Use Your Resources!

And finally, the last bit of advice… Remember those bullet points at the start of the article? Use these and other resources as tools throughout the process. Learn from others and discuss challenges! Don’t invent the wheel again; improve upon it instead!

Patrick Ballinger, CGMS is a grant coordinator for the Office of Management and Budget with the Pasco County Board of County Commissioners in Florida. He currently serves on NGMA’s Education Committee and the GMBoK Training subcommittee. He is the current president of the Pasco County Government Toastmasters, mentors with the Leadership Development Program and has obtained the Green Belt certification with Lean Six Sigma. Patrick works in partnership with the Pasco County Training and Development team to offer regular training courses about grants to county employees. He may be reached at pballinger@pascocountyfl.net.

1 Lean Six Sigma is a method that uses a collaborative team effort to improve performance by systematically removing waste and reducing variation. It combines lean manufacturing/lean enterprise and Six Sigma to eliminate the eight kinds of waste.