For the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA).

On August 7, 2025, the White House issued Executive Order 14117, Improving Oversight of Federal Grantmaking, which introduces sweeping reforms to how federal grants are awarded, reviewed, and monitored. This article outlines the key provisions of the order, explores its implications for grants and financial professionals, and highlights the critical role of professional associations such as the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA) in navigating this transition.

Key Provisions of the Executive Order

The Executive Order directs federal agencies to take several concrete steps to improve the integrity and impact of grantmaking. Each agency must now appoint a senior official responsible for reviewing new discretionary grant announcements to ensure they align with the Administration’s national priorities. This added layer of oversight is intended to bring greater consistency and strategic focus to funding decisions. In addition, federal agencies are required to implement more rigorous and transparent review processes. While this promotes fairness and clarity for applicants, it may also result in delays or compressed timelines for funding announcements and awards.

Additional key provisions include directing the Office of Management and Budget (OMB) to revise the Uniform Guidance to simplify application requirements. This simplification is intended to improve access for under-resourced communities that have historically faced barriers to apply. Further provisions include requiring agencies to update grant agreements to include termination provisions, allowing funding to be discontinued if projects no longer align with federal goals. While this introduces flexibility for agencies, it also creates uncertainty for recipients. Another provision directs agencies to require specific authorization and justification for fund drawdowns, shifting the burden of accountability to the front end of the funding process. This change is intended to prevent misuse of funds before it occurs, rather than relying solely on post-award audits.

Overall, this Executive Order signals increased scrutiny of programs perceived as ideologically driven or lacking in measurable impact. Grants professionals should be prepared to defend the relevance, rigor, and replicability of their proposed work.

Implications for Grants and Financial Management

These reforms are designed to enhance transparency, accountability, and strategic alignment in federal grantmaking. For professionals in grants and financial oversight roles, the implications are wide-ranging.

Applicants can expect clearer guidelines and more predictable review processes, which will help them better understand funding priorities and compliance expectations. However, the increased scrutiny may also mean that applications and drawdown requests will be evaluated more rigorously, particularly in terms of alignment with national objectives and demonstrable outcomes.

While the revisions to the Uniform Guidance are intended to streamline the application process, the transition period may introduce delays as agencies adjust to new procedures. The inclusion of termination provisions in grant agreements introduces a new level of flexibility for federal agencies—but also requires recipients to remain agile and responsive to shifting federal priorities.

Importantly, the Executive Order encourages agencies to broaden their recipient pools, with a focus on including first-time applicants. This could increase competition but also opens the door to new partnerships and innovative approaches to program delivery.

Strategic Recommendations for Grant and Financial Professionals

To navigate this evolving landscape effectively, grants and financial professionals should adopt a proactive and strategic approach. It is critical to start preparing in advance of funding announcements. Maintaining a portfolio of grant-ready projects—complete with impact data, performance metrics, and potential partners—can significantly streamline the application process. It’s also essential to keep your SAM.gov registration current, renewing it well before expiration which can avoid any potential administrative delays.

When crafting funding proposals, ensure that your narratives are tightly aligned with both the specific funding opportunity and broader administration priorities. Use the scoring criteria provided in the notice to guide your content, and make sure your narrative clearly supports measurable outcomes and aligns to the budgeted activities. Proposals should be written in plain language, avoiding jargon and emphasizing clarity and accessibility—reflecting the federal government’s renewed focus on readability. It is critical to stay alert to changes in funding opportunity announcements, even for recurring programs. Treat each opportunity as new and carefully review the language and structure to ensure your application aligns with updated priorities.

Indirect cost rates are another area to closely watch. Lower rates are increasingly preferred, and capped in many cases, so it is imperative to work with your grants or finance office to understand your current rate and explore options for strategically reducing the rate. Ensure directly allocable costs are not in your cost pool out of convenience.

Accountability of performance outcomes is more important than ever. Applications should include measurable benchmarks for success and demonstrate a commitment to evidence-based practices. Citing open science principles, replication studies, or third-party validations can strengthen your case and align with federal expectations. Post-award compliance will no longer rely solely on financial progress reporting. Financial and programmatic reporting systems must be strengthened to support real-time performance tracking. Federal agencies will expect more than just financial compliance-they will want to see evidence of impact.

Finally, consider expanding your network of partners. The Executive Order encourages broader participation in federal grantmaking, which may increase competition but also presents opportunities for new partnerships and innovation. Collaborating with new or non-traditional organizations may enhance your performance outcomes and increase your competitiveness in a broader recipient pool.

The Value of Professional Engagement: NGMA and AGA

In today’s rapidly evolving grants and financial management landscape, staying connected to professional associations is not just beneficial, it’s essential. Two organizations stand out for their leadership, resources, and community: the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA).

Since 1978, NGMA has served as a cornerstone for grants professionals across all sectors—federal, state, local, tribal, nonprofit, higher education, and the private sector. NGMA provides full lifecycle grants management training, professional certification through the Certified Grants Management Specialist (CGMS) credential, and continuing education opportunities. Members benefit from access to the Grants Management Body of Knowledge (GMBoK), a robust calendar of webinars and sector meetings, and a vibrant community forum that fosters peer learning and support. NGMA is committed to promoting best practices and professional excellence in grants management, helping members stay ahead of regulatory changes and funding trends

Meanwhile, AGA, founded in 1950, is the leading association for government financial management professionals. With a mission to advance accountability, transparency, and performance in government, AGA empowers its members through training, certification, and leadership development. The Certified Government Financial Manager (CGFM) credential is a hallmark of professional excellence in public sector finance. AGA also plays a key role in shaping policy and promoting ethical standards through its code of ethics and strategic initiatives. Members gain access to a national network of professionals, thought leadership, and tools that support career growth and good government practices

Together, NGMA and AGA offer a powerful combination of expertise and community. Engaging with both organizations allows professionals to bridge the worlds of grants and financial management- ensuring compliance, maximizing impact, and advancing their careers. Whether you’re navigating Uniform Guidance, managing indirect costs, or leading performance audits, these associations provide the knowledge, tools, and support to succeed.

Conclusion: A Joint Call to Action

This Executive Order represents more than a policy update—it’s a call to action for grants and financial professionals to lead with strategy, integrity, and adaptability. By aligning practices with the new federal framework, professionals can continue to secure critical funding, support community priorities, and contribute to a more transparent and effective federal grantmaking system.

Connecting to both NGMA and AGA will empower you to stay ahead of policy shifts, share best practices, and uphold the highest standards in grants and financial management as the federal landscape evolves. Leveraging the collective knowledge and support of both organizations will ensure you can navigate these federal changes with confidence—ensuring that public funds are administered effectively, transparently, and in service of the greater good.

Stacie Massey is Deputy Director of Grants and Financial Reporting at the Ohio Office of Budget and Management. Stacie has over 25 years of public sector experience in previous roles at the Ohio Public Employees Retirement System, Ohio Auditor of State, Ohio Department of Public Safety, and Ohio Emergency Management Agency.

Effective October 1, 2025, the U.S. Department of Health and Human Services (HHS) will officially retire its 45 CFR Part 75 framework. Going forward, HHS will adopt the 2 CFR 200 Uniform Guidance in full, with agency-specific provisions codified under 2 CFR Part 300.

For many organizations, this may look like a simple regulatory update. In reality, the changes bring new requirements that will affect day-to-day operations, financial oversight, and long-term planning. Smaller organizations, in particular, may feel the weight of these revisions, as lean teams and limited infrastructure make it harder to adapt quickly.
At the same time, the shift offers an opportunity to strengthen internal systems and build lasting capacity.

Key Changes

1.  Regulatory Realignment

HHS has now aligned itself fully with the 2 CFR 200 framework, supported by a new set of rules under Part 300. Grantees will need to update internal policies, grant manuals, and related documentation to reflect the new structure. While streamlining this framework is intended to create consistency across agencies, it requires focused administrative work to ensure nothing is overlooked.

2.  Lower Budget Revision Thresholds

The threshold for prior approval of budget revisions has dropped from 25% of total direct costs to 10% of the total approved budget, including cost share. As a result, grantees should expect to seek approvals more often and will need to monitor budgets more closely to avoid delays.

3.  Expanded Civil Rights Certifications

Grantees must now certify compliance with Title IX and other civil rights requirements across all awards, not just those where the language appears in the Notice of Award. This change increases accountability and underscores the importance of integrating civil rights compliance into every program.

4.  Stricter No-Cost Extension Rules


Requests for no-cost extensions must be submitted at least 10 days before the end of the budget period in the final year of performance. Previously treated more flexibly, this deadline is now a firm requirement, and late requests will likely be denied. Careful planning during close-out will be essential to avoid leaving funds unspent.

5.  Termination for Convenience


HHS now reserves the right to terminate awards for its own convenience, with no appeal available to grantees. This provision creates real financial risk, particularly for smaller organizations with limited reserves or few funding sources. Building contingency plans will be critical.

Preparing for the Transition

Adapting to these changes will require preparation, but there are practical steps smaller organizations can take:

• Review policies and practices. Conduct a gap analysis to identify where current systems do not meet the new requirements.
• Update internal documents. Manuals, standard operating procedures, and templates should reflect new rules and thresholds.
• Invest in training. Staff and board members should understand both the changes and their roles in maintaining compliance.
• Strengthen documentation. Consistent, well-organized records of financial activity, performance data, and civil rights compliance will help ensure readiness for audits.
• Communicate with funders. Proactive dialogue with funding agencies can clarify expectations and provide room for flexibility during the transition.

Looking Ahead

The new guidance is more than a compliance exercise. For smaller organizations, it is an opportunity to create stronger, more resilient systems that will support growth and stability over time. By approaching the revisions with intention and preparation, organizations can not only remain in compliance but also position themselves to thrive in a funding environment where accountability and competition continue to grow.

Those who invest in building strong compliance infrastructure now will be better equipped to deliver programs effectively, serve their communities with confidence, and sustain their work well into the future.

D’Laun Oubre, MBA is a seasoned grants management leader with nearly two decades of experience in accounting, post-award compliance, and federal funding oversight. As Director of Grants Management Services at Kim Joyce & Associates, she has stewarded $30 million+ in funding while mentoring teams, embedding internal controls, and shaping best practices in federal grants compliance.

She’s an active member of the National Grants Management Association and a trusted voice in the field of federal grants compliance.

The August 2025 Grants Management webinar, Funding Interrupted: Navigating Grant Terminations in a Shifting Federal Landscape, addressed one of the most pressing issues in today’s federal funding environment: the increasing frequency of grant terminations and the evolving rules that govern them. The session provided a detailed overview of the regulatory requirements under the Uniform Guidance, recent policy changes, and strategies for grantees to remain resilient amid uncertainty.

Understanding Federal Grant Terminations

At the foundation of the discussion was an overview of how federal grants may be terminated and the regulations around grant terminations under 2 CFR 200.340-345. Grants may end in three primary ways:

• For Cause – A funding agency unilaterally ends a grant due to noncompliance.
• By Mutual Agreement – Both parties consent to end the grant under agreed terms.
• For Convenience – A federal agency discontinues the award due to shifting priorities or funding changes.

Termination provisions must be clearly defined in grant agreements and passed down to subrecipients and contractors. Grantees also carry specific responsibilities during and after termination, including closeout procedures, returning unobligated funds, and managing property and records. Importantly, certain costs, such as personnel termination expenses or unrecoverable activity costs, may be allowable under 2 CFR 200.472 if they are reasonable and not due to negligence.

Recent Policy Shifts Impacting Terminations

The federal landscape has shifted considerably in 2025, reshaping how terminations are handled and what grantees must prepare for. Two key developments are:

1. The One Big Beautiful Bill Act (OBBBA)
   This legislation introduced faster termination timelines, expanded discretionary authority for agencies, and added new reporting and justification requirements. While the provisions increase transparency and oversight, they also require grantees to adapt quickly when awards are reduced or discontinued. OBBBA also established enhanced protections for grantees, including clearer appeals pathways and stronger expectations for contingency planning.
2. Executive Order on Improving Oversight of Federal Grantmaking
   Issued on August 7, 2025, this Executive Order (EO) requires annual reviews of discretionary awards, limits the use of these funds for administrative costs, and directs OMB to update the Uniform Guidance. Notably, the EO allows agencies to terminate discretionary grants “for convenience” if they no longer align with national priorities, signaling greater volatility for many programs. Agencies are now encouraged to incorporate termination clauses into current and future agreements, making it even more important for recipients to read the fine print of their awards.

Strategies for Navigating Terminations

Preparedness and agility are key in managing grant terminations. Grantees are advised to:

• Closely monitor federal funding notices and guidance for early signs of changing priorities.
• Maintain thorough documentation of policies, expenditures, and performance reports to support compliance and potential appeals.
• Establish internal communication protocols to ensure quick, coordinated responses to termination notices.
• Build risk mitigation and contingency plans into every program, including diversifying funding sources and strengthening relationships with state and local partners.

Additionally, communication is key. Upon receiving a termination notice, grantees should immediately clarify scope and requirements with the awarding agency, notify all subrecipients and contractors, and document every interaction and cost incurred. Appeals processes differ by agency, but preserving rights through timely documentation and legal consultation is essential.

Key Takeaways

1. Federal policy changes have expanded agency authority to terminate grants more quickly and for broader reasons, requiring grantees to stay alert to shifting political and budget priorities.
2. Thorough documentation, clear communication, and contingency planning are critical tools for navigating unexpected terminations and safeguarding allowable costs.
3. Grantees must proactively prepare by building risk mitigation protocols, monitoring federal guidance, and understanding appeals processes to remain resilient in today’s volatile funding environment.

In the current federal climate, we see that grant terminations are no longer rare exceptions but a growing feature of the federal funding landscape. With new legislation and executive directives reshaping the rules, grantees face greater uncertainty, but also greater opportunity to strengthen internal systems, ensure compliance, and build resilience. By focusing on preparedness, documentation, and communication, organizations can position themselves to navigate terminations effectively and continue advancing their missions despite federal shifts.

Career burnout is very real in grants management. With huge responsibilities, strict deadlines, and the constant pressure of aligning programs with funder expectations, many of us hit the wall sooner than we’d like to admit. The advice we usually hear? Step away from your work: take a walk, meditate, go on vacation, pick up a hobby, or drink more water. These are all wonderful and necessary, but if you’ve tried them, you know they often provide only temporary relief.

So what do you do when the vacation glow fades and the inbox is still overflowing? One answer may be to stop stepping away from your career—and instead start leaning into it. Here are a few “outside the box” approaches I’ve found can truly help rekindle passion and keep burnout from becoming the defining chapter of your professional story.

1. Rediscover Why You Fell in Love with the Work



When was the last time you paused to ask yourself: Why did I choose this field? Burnout often clouds that original spark. Reconnecting with your “why” is more than a pep talk—it’s about intentionally revisiting the parts of your career that once excited you.

Try journaling about what first drew you to grants management. Was it the satisfaction of stewarding dollars to nonprofits doing critical work? The intellectual puzzle of compliance and regulations? The joy of helping mission-driven organizations succeed? By pinpointing your entry point, you can often find ways to reignite that same energy in your current work.

2. Expand Your Perspective Beyond Your Usual Seat



One of the most powerful burnout antidotes is stepping into another vantage point—while staying within your field. For me, the turning point came after leaving my job having years of experience as a federal grants management specialist. I knew every clause of 2 CFR 200, but I had never experienced the other side: what it feels like to be a nonprofit organization struggling to win and manage a grant.

Switching gears to consulting has been eye-opening. Suddenly, I wasn’t just enforcing compliance rules; I was helping organizations tell their stories, build strategies, and compete for funding. This role reversal didn’t just expand my expertise—it gave me new respect and energy for the work.

You don’t need to change careers to try this. Volunteer to review grants for a local foundation. Shadow a program officer. Teach a grant writing workshop at a community college. These fresh perspectives will challenge you, sharpen your skills, and remind you why your work matters.

3. Turn Learning into a Hobby



Self-care doesn’t always have to mean leaving your work behind. What if your “hobby” could be a form of professional play? Take an online course in a skill adjacent to your role, such as nonprofit storytelling, data visualization, or even AI tools for grants management. Start a blog where you translate the complexity of grants into plain English. Mentor a student who’s curious about entering the field.

By channeling curiosity into side projects, you trick your brain into seeing your career not as an endless grind, but as a living subject you get to explore on your own terms. It’s less about “work” and more about intellectual joy.

4. Build Micro-Moments of Mastery



Burnout often comes from feeling like no matter how much you do, you’re always behind. One antidote? Design tiny, achievable wins. Instead of putting “Award five grants today” on your list, try breaking it into micro-goals like “Review these statements of work today” or “Review submitted budget proposals by noon.”

Celebrate these small victories. Not with balloons or cupcakes (though those are nice) but with a simple acknowledgment: I moved the needle forward today. Over time, this habit rewires your relationship with deadlines, replacing overwhelm with steady progress.

5. Create Your Own “Career Ecosystem”



Finally, remember you are not a single role—you are an ecosystem. Maybe you are a grants manager, but you’re also a writer, mentor, strategist, or teacher. Burnout often happens when we let one role swallow all the others.

So, diversify. Build space for the other parts of your professional identity to thrive. For example, you might dedicate one hour a week to writing an article on best practices, or schedule quarterly meetups with peers to exchange fresh ideas. These outlets give oxygen to your ecosystem, making the whole system healthier and more sustainable.

Closing Thought



Managing burnout isn’t about escaping your work—it’s about reframing your relationship with it. By leaning in, shifting perspectives, and creating opportunities for curiosity and mastery, you can transform burnout from a dead end into a bridge toward deeper fulfillment.

The next time you feel bogged down, instead of asking, “How can I get away from this?” try asking, “What fresh angle can I discover within this?” You might just find that the spark you thought was gone was only waiting for you to see your career from a new light.

Key takeaways from the HORNE team’s presentation at the NGMA Compliance Conversations webinar “Grants in Transition: Practical Steps on Navigating the Now & Preparing for What’s Next.” 

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The federal funding landscape is poised for major transformation with significant proposed changes to discretionary funding, program priorities, and agency responsibilities suggesting a period of turbulence that demands strategic foresight and proactive planning from states, local governments, nonprofits, and education institutions. To navigate what’s ahead, stakeholders must pay close attention to shifting federal priorities, prepare for reform-driven sustainability efforts, and develop adaptive strategies for long-term success.

Major Shifts in Federal Budget Priorities Are Coming

At the heart of the upcoming changes is the recently passed “One Big Beautiful Bill Act” (OBBBA). The OBBBA brings significant shifts to federal grant funding, with a clear reallocation of resources across sectors. One of the most notable changes is the elimination of numerous climate and environmental grant programs, including those related to low-emission energy, climate justice, and greenhouse gas reduction. These cuts reverse many of the investments made under the Inflation Reduction Act, signaling a shift away from federal support for green initiatives. Similarly, in education, the bill tightens Pell Grant eligibility and introduces new but limited workforce-training vouchers, reducing overall support for low-income and non-traditional students.

At the same time, the bill increases targeted grant funding for rural and agricultural programs. A key highlight is the doubling of the Rural Hospital Fund to $50 billion, aimed at offsetting the impact of deep Medicaid cuts that threaten access to care in low-population areas. The USDA also receives enhanced support for rural grants, farm-related funding, and protections for domestic biofuels.

Defense and homeland security spending are also set to grow significantly, with defense budgets increasing by 13% and homeland security receiving an additional $175 billion. Other areas receiving increased attention include traditional infrastructure and rural/agricultural assistance. The Department of Transportation’s infrastructure programs, drinking water initiatives under the EPA, and charter school programs are also positioned for potential funding increases.

With respect to larger federal funding opportunities for local and state governments with potential infrastructure projects, the legislation, as passed, includes large opportunities in these areas:

• Roads, Bridges, and Major Road Projects: $194.38 billion
• Airports: $20 billion
• Public Transportation: $35.26 billion
• Electric Vehicles, Buses and Ferries: $6.25 billion
• Ports and Waterways: $3.25 billion

Sustainability and Reform Require State and Local Preparedness

As federal funding priorities shift, states and local entities will be expected to carry more of the burden, particularly in areas like broadband expansion, education, and disaster response. We have seen several program-specific examples illustrate how sustainability and reform are being restructured to rely more on local execution and preparedness.

For instance, the Broadband Equity, Access, and Deployment (BEAD) program has issued updated guidance removing many social equity and engagement requirements while maintaining a focus on network resilience, compliance with labor laws, and accountability. This reduces federal oversight in favor of more state-driven implementation models.

In education, the proposed budget consolidates 18 federal grant programs into a single $2 billion formula grant. This change provides states with increased flexibility but also places the responsibility on the states to make strategic, needs-based decisions aligned with local workforce trends and policy shifts.

The FEMA Building Resilient Infrastructure and Communities (BRIC) program similarly underscores a move toward local responsibility. Proposed reforms prioritize empowering state, tribal, and territorial governments to lead disaster recovery efforts while the federal government retains core response duties. This includes encouraging local mitigation strategies, cost-sharing innovations, and fiscal preparedness.

Across all areas, one message is clear: sustainability in the face of reform will depend heavily on how well state and local entities prepare for and manage change.

Strategic Planning Is Crucial for Navigating Change

Given the sweeping nature of these shifts, we recommend these strategies to help organizations adapt:

• Diversify Funding Sources: As traditional funding streams are reduced or restructured, stakeholders should explore non-traditional sources and public-private partnerships.
• Budget Forecasting and Tracking: Accurate forecasting will be essential in anticipating funding gaps and identifying opportunities. Monitoring guidance changes in real time ensures that organizations can remain compliant and responsive.
• Target Traditional Grant Areas: Established programs in agriculture, transportation, homeland security, and law enforcement (e.g., DOJ’s COPS program) are expected to remain viable. Entities should refocus efforts on these dependable areas.
• Improve Communications: Real-time updates and transparent stakeholder engagement are critical. Establish recurring reporting mechanisms and communication protocols to ensure alignment across teams.
• Initiate Internal Task Forces: Organizations should consider forming internal working groups to analyze federal guidance, digest programmatic shifts, and lead planning efforts across departments.

Finally, understanding local-level impacts, developing backup plans, and preparing to advocate for essential programs will be critical steps in ensuring resilience through what may be a prolonged period of federal funding realignment.

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Sarah Legner, CGMS is a senior manager; Ashley Swain is the director of compliance and monitoring; Kyle Skene, CPA, is a senior manager; and Lindsey Howard is a compliance and monitoring manager at HORNE LLP. Learn more at horne.com. 

Key takeaways from the BFS team’s presentation at the NGMA Compliance Conversations webinar “Grants in Transition: Practical Steps on Navigating the Now & Preparing for What’s Next.” In this webinar, the BFS team provided practical steps to navigate the shifting federal funding landscape.

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We are grateful to the grants professionals who joined us for an important compliance conversation on grants in transition. These conversations are more than just training—they’re a space to tackle real-world pressure points and share strategies that help agencies stay one step ahead of compliance risks.

In this session, we focused on what’s keeping folks up at night: policy gaps, spending stress, desk reviews, and documentation pressure. And we didn’t just talk about the problems—we shared practical tools to help solve them.

Here are a few highlights and takeaways from the session.

Review, Track, and Update Your Policies – Starting Now

With changes to 2 CFR 200 coming in FY26 and a steady stream of impactful Executive Orders (EOs), now is the time to review and align your internal policies and procedures to keep pace with the evolving federal landscape. We recommend:

• Reviewing policies now to see where alignment is possible
• Tracking EO-related changes that may affect policies and compliance
• Updating policies and procedures regularly as part of internal controls best practice
• Flagging policies that may need revision later, once 2 CFR 200 has been updated

Don’t wait for formal implementation dates to begin your internal work. Proactive alignment not only supports compliance, it strengthens your operational integrity.

Audit & Desk Review Focus Has Shifted – Are You Ready?

Traditionally, audits focused on familiar territory: HR, procurement, and other program-facing policies. But today, the lens is wider—and sharper. Auditors are no longer just checking boxes; they’re evaluating how your policies, practices, and spending align with program intent, performance outcomes, and federal priorities.

Even policies that once went unnoticed may now raise red flags if they’re outdated, misaligned, or undocumented. In this new environment, internal policy reviews, clear justification, and organized documentation aren’t just best practices—they’re essential tools for audit readiness and risk mitigation.

Are you a Red Flag?

• Do you have high unobligated balances?
• Do you have a spend-down strategy that aligns with program goals?
• Do your programs and policies align with the intent of your programs and the current EOs?

Budget Modifications Require Strategy – and Transparency

Budget realignments don’t have to be reactive. We talked about how to navigate spending down and budget shifts with confidence by:

• Staying within the lines – understand pre-approval thresholds
• Aligning spending with program goals – don’t just “use it or lose it”
• Talking to program leads early – don’t wait for a crisis
• Documenting every step – because if it’s not documented, it didn’t happen
• Drawing down regularly – don’t let claimed-but-unreimbursed funds pile up

Too many agencies fall into the “use it or lose it” trap without a strategic plan. We emphasized that spending should be intentional, documented, and defensible. With today’s unpredictable funding environment, sitting on reimbursements is a risk. Claim within 30 days of expenditure whenever possible.

If It’s Not Documented…It Didn’t Happen

We can’t say this enough: Good documentation is your first line (and often strongest) defense.  Make sure your grant documentation is:

• Centralized, organized and accessible
• Clear, legible, and tied to the decision being made
• Contextual – not just what happened, but why it happened

Action Items You Can Tackle Today

• Review and revise your policies, especially procurement, cost allowability, and disclosures.
• Centralize your grant documentation, so it’s ready when you need it.
• Start the budget reallocation conversations now, before deadlines close in.
• Prep for monitoring and desk reviews – they’re coming, even if you haven’t been flagged yet.

As the grants landscape continues to shift, stay focused on what you can control. Create a list of action items, tackle every item on the list and keep reviewing, documenting and making changes as needed to ensure compliance. Stay up-to-date by remaining engaged and continuing to seek and use information, resources and tools.

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Mara Ash, CIA, CGFM, CMRA, CICA is the CEO and Cindy Watson, CICA is the managing director of BFS Strategic Partners. For additional support and tools, visit decoded.expert. 

Federal Acquisitions Regulation (FAR) Also Being Streamlined

The White House Office of Management and Budget (OMB) is expected to propose revisions to the Uniform Guidance (2 CFR 200) later this year in an effort to align with the Trump administration’s push for administrative streamlining. Details on proposed revisions and a timeline are not yet available. The news comes less than a year after a significant revision of the Uniform Guidance by OMB.

In a presentation to the NGMA Capital Area Chapter this month (June 2025), Andrea Brandon, deputy assistant secretary for budget, finance, grants and acquisition for the U.S. Department of Interior (DOI), noted that leadership wants to further streamline [the Uniform Guidance], “to get down to the least amount of requirements necessary to comply with appropriations law and ensure the proper stewardship of federal funds.” She added that the proposed revisions will be available for public comment and urged stakeholders to review the proposed changes and submit comments. NGMA will provide additional details as they become available.

In further effort to streamline the federal funding process, the Federal Acquisition Regulation (FAR) is also being significantly overhauled.

Areas of focus will be:

Focus on risk. Agencies will more closely be scrutinizing federal funding risks, including improper payments, misuse of payments, and funds not being directly appropriated to beneficiaries of a grant program.

Focus on Data and Statistics – As we move in the direction of using more advanced technology, solid and clean data will be needed to ensure that the technology is coming away with the appropriate analysis and predictions. Therefore, there is a push to ensure that the data that is derived from the grant/cooperative agreements is clean, relevant, and unbiased.

Focus on outcomes rather than outputs. Grant recipients can expect agencies to request information that clearly identifies outcomes in award applications. Agencies will measure a recipient’s progress and maintain a scorecard to determine if grantees are meeting set outcomes. Rather than grantees providing short-term outputs showing they met the purpose of a grant, the emphasis will be on the outcome that shows grantees are using federal money effectively, efficiently, and appropriately.

Focus on technology. There will be more focus on using newer technologies such as artificial intelligence (AI), robotics process automation (RPA), chatbots, augmented/virtual reality, and blockchain (distributed ledger technology). The goal is to provide better analysis (including predictive), enhance process efficiency and speed, and gain real-time training/coaching in various areas across the grants management lifecycle.

Though not confirmed, it is believed that the proposed changes could be rolled out as soon as late summer. Make sure to bookmark NGMA’s Compliance Updates page for the latest information.

I remember the moment I decided to pursue the Certified Grants Management Specialist (CGMS) certification. It was after fielding the tenth question of the week from our Division of Public Health staff about the nuances of Uniform Guidance (2 CFR 200). Yet again, I didn’t have an immediate answer other than, “It depends.” As the grants portfolio lead coordinator at Nebraska Department of Health and Human Services (DHHS), I found myself thinking, “I want to be trusted. I want to have answers ready. I want to know these things confidently and right off the bat.” That was the catalyst that pushed me toward certification.

Taking the First Step

My certification journey officially began when I attended NGMA’s Grants Management Body of Knowledge (GMBoK) training. It was eye-opening. I connected with grants professionals from across sectors, from federal agencies to research institutions, and realized we all faced similar challenges despite our different backgrounds. The comprehensive overview of grants management principles gave me a framework to organize what I already knew and identify gaps in my knowledge.

One of the most valuable resources I received during the training was the GMBoK Guide, a textbook providing a detailed walkthrough of the Uniform Guidance that became my constant companion throughout my certification journey. Unlike the dense, legal language of the actual regulations, the Guide broke down complex concepts into understandable chunks and provided practical context for how these regulations play out in real-world scenarios. I found myself constantly referring back to specific chapters as I deepened my understanding of grants management principles.

But the GMBoK was just the appetizer. The main course, the CGMS exam, would require much deeper preparation.

The Study Marathon

Back at my desk, I developed a structured approach to studying. I outlined the key Uniform Guidance sections, developed a guide to allowability principles, created a list of important deadlines, and so on. I wanted to memorize anything I’d need to recall in specificity on the test. Rather than trying to absorb everything at once; however, I broke down the material into manageable sections.

Beyond the sheer volume of material, one of the most challenging parts was understanding how to apply it to different scenarios. The Uniform Guidance became my constant companion. While I didn’t have a formal study group, I did reach out to the NGMA Community Forum (message board) where experienced professionals shared valuable tips and insights. Even though I took a more independent approach, I would highly recommend CGMS candidates reach out on the message board site or search the NGMA Calendar for local chapter events to find a study group, which can be immensely helpful with support and accountability.

One of the most challenging aspects of the exam involves the particular flavor of information that needs to be memorized—much of it is info you would typically just look up online in your day-to-day work. Deadlines, specific dollar thresholds, exact timeframes, these were elements I had to memorize rather than rely on my usual “I’ll just check the eCFR” approach. It was a different kind of preparation than my usual work habits.

Test Day: The Ultimate Challenge

The morning of the exam, I arrived at my local testing center with a mixture of nervousness and determination. Three hours, 150 questions, and no breaks—it was going to be a mental marathon!

Settling into the testing room, I took a deep breath and reminded myself that I’d prepared well. As I worked through the questions, I found they weren’t just asking for regulations to be regurgitated; they also required applying knowledge to complex scenarios. Would this cost be allowable under these specific circumstances? How should a pass-through entity monitor a particular type of subrecipient?

By the final hour, my focus was waning, but I pushed through. Walking out of the testing center, I felt drained but also proud that I’d given it my all, regardless of the outcome.

When I received the email notification that I passed, I may have done a little celebratory dance. The months of study and preparation had paid off.

What I Wish I’d Known

Looking back on this journey, there are things I wish someone had told me at the start:

• The exam tests both application and recall. While understanding concepts is crucial, don’t underestimate the need to memorize specific elements like deadlines and thresholds that you might normally just look up.
• Consider finding study partners. Though I didn’t take this route, I’ve heard from others who passed that studying together made a significant difference. The NGMA Community Forum and chapter events can be a good place to connect with potential study partners.
• Trust your experience. The certification builds on practical knowledge. I found that relating new information to scenarios I encountered in my work helped make abstract regulations more concrete.
• Take care of yourself during preparation. It’s worth emphasizing that exhaustion doesn’t help retention. Building in breaks and maintaining balance is essential to effective studying.

Life After Certification

Since earning my CGMS, I’ve noticed subtle but meaningful changes in my professional life. There’s a newfound confidence when I provide guidance on complex grants issues. My perspective has broadened beyond my specific sector, allowing me to see patterns and solutions I might have missed before.

The certification has also connected me to a community of professionals who share my commitment to excellence in grants management. I had a great time at the Annual Grants Training this year—my first as a CGMS—where I received my official CGMS pin. The event was a wonderful opportunity to connect with fellow grants professionals and deepen my knowledge in this field as a newly certified specialist.

Maintaining the certification requires 60 Continuing Professional Education (CPE) credits every three years, which initially seemed daunting. But there are lots of opportunities to pick up CPEs, and I’ve come to see this as an opportunity to stay engaged with emerging trends and best practices.

Is It Worth It?

If you’re considering pursuing the CGMS, you might be wondering if it’s worth the investment of time and energy. From my perspective, yes.

Beyond the credential itself, the process of preparation transformed how I approach grants management. It gave me a more comprehensive and wide-ranging understanding that allows me to connect dots I might have missed before. It’s made me more confident in my role and opened doors to new opportunities for contribution and growth.

The journey isn’t easy. There were moments of frustration and doubt along the way. But crossing that finish line, knowing I’d earned recognition as a master-level professional in my field, was deeply satisfying both personally and professionally.

If you’re on the fence, my advice is simple: take the leap. The road may be challenging, but the destination is well worth the journey.

Sometimes, we get lost in the jargon of internal controls and grant management and forget the role of vigorous checks and balances in increasing trust with our funders, employees, and the public.

Grant recipients can help keep funders happy by ensuring the organization has strong internal controls that prevent good grants from going bad and ensure compliance with the Uniform Guidance, which requires recipients and subrecipients to maintain robust internal controls.

Here are some common grants management risks that allow grant fraud to occur and examples of what should alert you to dig deeper into what is happening at your organization.

How many of these 10 common risks have you run into?

Risk #1: Unethical Leadership
Examples of signs that management does not place a high value on ethical practice include:

• Lacking clear policies
• No clearly defined lines of authority
• Limited separation of duties
• Little individual accountability
•  Missing mechanisms to report fraud

Risk #2: Tolerance of Risky Behaviors
Risky behavior can happen at the highest levels, and the following demonstrate some high-risk behaviors (even at the highest levels):

• Aggressive accounting
• Poor oversight in the preparation of financial statements
• Inadequate comparison of budgets with performance
• Lack of Human Resources oversight in hiring, pay scales, and bonuses
• Missing or substandard personnel appraisals and reviews

Risk #3: Inadequate Technology Security
Information technology (IT) is an area that has historically been far removed from the grants management function, and these substandard IT security missteps can put your organization at risk:

• Easy access and lack of restrictions on computer usage
• Missing record retention policies for electronic records
• Lack of formal data backup and recovery plans

Risk #4: Poor Protection of Assets
Assets include cash, equipment, and other property types, from office supplies to electronics, and these assets can sometimes go missing due to:

• Substandard physical security of assets for facilities, records, computers, cash, and data files
• No consistent and periodic audit comparing existing assets with records of assets
• Weak monitoring of asset movement between locations and people

Risk #5: Weak Accounting Controls
Substandard or inadequate accounting controls and security can also play a role in the opportunity for fraud to blossom, including:

• Inadequate separation of duties
• Ineffective monitoring of duplicate payments and vendors
• Incomplete or late reporting
• Missing review of journal entries, new vendors, and account reconciliations

Risk #6: Insufficient Project Monitoring
While managing funded projects can be a busy, even chaotic time, it should be recognized that the period of performance is where opportunity is created for potential fraud. Signs of fraud risk include:

• Unusually large reliance on students or volunteers
• Multiple sources of governmental funding
• Special requirement projects (i.e., eligibility requirements)
• Projects that demonstrate little or no results
•  Slow or no project reporting

Risk #7: Incomplete Cash Controls
Because cash is the most easily converted type of asset, incomplete cash controls create a massive opportunity for fraud. Practices to look out for are:

• Separate accounts for things like cost share or matching, other donations, or departmental expenses exist without adequate controls
• Linked infrastructure between nonprofit and for-profit counterparts makes separating and auditing transactions difficult
• Use of cash or wire transfers for payments
• Lax monitoring of cash deposits

Risk #8: Lack of Monitoring
The role of monitoring is to determine if what you think is happening is happening…or NOT!
Without monitoring, the opportunity for frauds to go undetected is increased:

• Unusual, complex, or new transactions at the end-of-year or reporting period without sufficient review and approval
• Inadequate credit card or expense report oversight
• Unexplained discrepancies between the budget and the actual costs
• Shifting expense line items or accounts without proper justification

Risk #9: Conflicts of Interest
Conflicts of interest can happen with any organization, but a lack of a transparent process for dealing with them can lead to expensive cost disallowance for federal grant recipients and a public relations nightmare for many organizations:

• Principal Investigators (PI) or Program Directors with one or more outside businesses are not required to disclose interests
• Inadequate formal oversight by boards of management relationships
• Unclear reporting process
• Untrained staff on how to handle potential conflicts of interest
• Lack of multiple reporting paths for whistle-blowers

Risk #10: Ignoring Staffing and Payroll Difficulties
Finally, the opportunity for fraud is accelerated by staffing and payroll problems:

• Inadequate payroll system
• Lack of monitoring of payroll discrepancies
• Vague consultant or subcontractor agreements
• High staff turnover

Watch for Warning Signs!
While these risks have historically been associated with fraud, they do not prove fraud is occurring. But like the old saying goes, “Where there is smoke, there can be fire!”

Treat these common missteps as an early warning system that alerts you to carefully investigate the circumstances to reduce the risk of fraud at your organization.

Need to refresh your compliance knowledge? Join one of our upcoming trainings.

Rachel Werner is the principal of MyFedTrainer, a provider of training and ongoing support to grants administrators.

We all recognize that award closeout is a vital process. However, the multitude of administrative tasks necessary to manage grants often consume a grant manager’s time and attention. To ease the award closeout stress, Jennifer Zarek, CGMS, LSSYB, AmpliFund Implementation Team Lead, gave an NGMA webinar presentation on how to prepare for closeout from the time your grant is awarded. To support you in that process, below are five steps to help you create a solid foundation.

1. Create a Checklist

Create a standard checklist to use as your base for all awards. This can be customized once you receive your Notice of Award (NoA). For example, your checklist should note what reports are due and when. Further customize it to include any special conditions that apply to your award. Then group your checklist items by dates to best prepare for closeout—starting at 90 days before the end of the award. Finally, assign each checklist item to the role responsible for that task.

2. Establish Checkpoints

Improve compliance throughout the life of the award by implementing checkpoints in your award management processes. These are planned points where you assess the effectiveness of your grants management processes as well as your team’s efficiency to date. Regular audits of your grants management practices help you (and your team) stay on track, create capacity down the line, and identify potential issues before they become a problem.

3. Monitor Budget and Performance

Closely monitoring both budget and performance will allow you to draw down effectively, and in turn, ensure that funding will be proportionate throughout the timeline of the award. Best practices, such as establishing good internal communication and blocking off adequate time to prepare reports, can help you effectively monitor budget and performance from the start of your award. (If you are managing subrecipients, consider downloading this Subrecipient Monitoring Checklist.)

4. Centralize Documentation

Proper documentation is essential for successful closeout. Centralizing your document storage will spare you stress and significantly ease the process when it’s time to demonstrate what your program accomplished against the award goals and that you spent the funds properly per the award agreement. (Unfortunately, if you’re unable to prove this, you may have to return funds regardless of if the expense was allowable or not.) View AmpliFund’s Grant Management Centralization Guide for guidance.

5. Plan for the Next Award

After closeout, look back at the award with your team and discuss what worked, what didn’t work, and why. Solicit internal and external feedback for a broader perspective. Leverage this feedback to adjust your processes and fine-tune a plan for closeout that works for your organization. Then you can duplicate that process and use it for future awards.

Members: You may view the full webinar recording here for additional information on award closeout. For additional help and resources, view AmpliFund’s Award Closeout Toolkit.