Preparing for What’s Next: Navigating Federal Budget Shifts and Program Sustainability

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

Staying Scrappy in a Shifting Landscape: Real-World Strategies for Grants Professionals

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

OMB to Issue New Revisions Aimed to Streamline 2 CFR 200

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.

The Road to Certification: My CGMS Journey and What I Learned Along the Way

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.

Grants Management: Identifying 10 Internal Control Gaps

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.

Key Steps to Successfully Close Out an Award

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.

Mastering Financial Transparency: Key Strategies for Audit-Proofing Your Organization

In September 2024, Tasha Fox led a webinar presentation on mastering the art of financial transparency. The objectives of the presentation were to understand the scope and requirements of large-scale audits across various public and nonprofit sectors, develop and implement robust internal control systems, and create a comprehensive audit preparation plan adaptable to diverse organizational needs Below are key takeaways from her presentation.

Missed the webinar? View the recording HERE. (Member login required.)


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Financial transparency is crucial for both the public sector and nonprofit organizations. By focusing on three key areas, you can navigate the complex world of financial audits with confidence and use them as opportunities for improvement. Here are three essential strategies to help audit-proof your organization:

1. Understanding Audit Scope and Requirements

A fundamental step in preparing for an audit is understanding its scope and requirements. Different sectors face unique challenges:

  • Public sector organizations often deal with financial audits, compliance audits, and performance audits, each with its own focus and requirements.
  • Nonprofits may face financial statement audits, Single Audits for federal funding recipients, and state-specific audits.

Regardless of your sector, it’s crucial to familiarize yourself with the relevant regulatory frameworks, such as Government Auditing Standards (Yellow Book), Office of Management and Budget (OMB) Uniform Guidance, and Financial Accounting Standards Board (FASB) Accounting Standards.

2. Developing Robust Internal Control Systems

Strong internal controls are the backbone of financial transparency and audit readiness. It’s important to tailor these controls to your organization’s specific needs:

  • Public sector entities should focus on segregation of duties, budgetary controls, and transparent procurement processes.
  • Nonprofits need to pay special attention to donor fund management, volunteer oversight, and controls over fundraising activities.

Implementing effective financial policies and procedures, leveraging technology for enhanced control, and addressing common weaknesses are all critical steps in building a robust internal control system.

3. Creating a Comprehensive Audit Preparation Plan

Being proactive in audit preparation can significantly reduce stress and improve outcomes. An effective preparation plan should include:

  • A timeline with key milestones, working backwards from the audit date.
  • Meticulous organization of financial records, ensuring completeness and accuracy.
  • Advance preparation of key financial documents, including sector-specific documentation.
  • Internal pre-audit reviews to identify and address potential issues early.
  • Team preparation through clear role assignments and training on audit processes.

By focusing on these three areas – understanding requirements, strengthening controls, and thorough preparation – organizations can approach audits with confidence and use them as opportunities for improvement and transparency.

Remember, mastering financial transparency is an ongoing process. Stay informed about changing regulations, continuously refine your internal controls, and view each audit as a chance to enhance your financial management practices.

Tasha Fox, CPA is an instructor for Graduate School USA and the founder of Fox Accounting Services.

Key Takeaways on Maximizing Recovery on Your Grants by Leveraging Indirect Cost

In January 2024, Nicolie Lettini of Cherry Bekaert led a webinar presentation on leveraging indirect costs to maximize profits. The objectives of the presentation were to define indirect cost; learn how it is determined and how it impacts organizations; and understand how to maximize revenue by leveraging indirect cost. Below are key takeaways from her presentation.

Missed the webinar? View the recording HERE. (Member login required.)
____________________________________________________________Key takeaways regarding indirect cost:
1. Understand True Cost. Direct cost and indirect cost should not be considered two separate items.  Cost is cost, no matter how you slice it. A common perception is that recognizing and claiming indirect cost related to a grant will take dollars away from the program. This implies that indirect cost is optional. Indirect cost is a component of True Cost, and therefore exists and is not optional. Too many organizations end up subsidizing the indirect cost component, which creates sustainability risk. If a program becomes too expensive to subsidize, then the program is likely to become short-lived. So remember, just because you don’t recognize indirect cost does not mean it doesn’t exist, you are subsidizing and taking tax payer dollars away from General Fund services such as Public Safety and Parks and Recreation.
2. A Negotiated Indirect Cost Agreement (NICRA) is almost always a better option than the 10% de minimis. While it takes time and effort to come up with the indirect cost rate calculation, most organizations will find that the indirect cost rate is significantly higher than 10%. Besides knowing you have a higher rate, the additional benefits of having a NICRA far outweigh the up-front work to obtain one:

  • Cost Recovery – As mentioned above, indirect costs are real costs incurred by the organization as a result of the grants it manages. By collecting indirect costs on grants, the organization can recover some of these costs and maintain its financial stability over time.
  • Improved Financial Management – By collecting indirect costs, the organization can gain better visibility into the true cost of managing grants and allocate resources more effectively. This can help the organization make informed decisions about the grants it manages and ensure that it is using its resources efficiently. Sometimes, it can even inform a decision to not go for a grant because the subsidy would be too great and exceed the award (yes, this happens – there is a transportation grant out there with an indirect cost rate of 110%)!
  • Compliance – Many funding agencies require grant recipients to collect indirect costs on grants to ensure that the funds are being used appropriately and that the true cost of the program is understood. In some cases, grant applicants may look more favorable to the grantor when an understanding of indirect cost is demonstrated by having a NICRA.
  • Match Requirement – You have the ability to use your NICRA as your match requirement, which frees up cash AND allows you to access new grants that you would have otherwise passed up due to inability to set aside the cash as match requirement.
3. One of the biggest challenges for recipients, grantors, and cognizant agencies alike is that the Uniform Guidance isn’t perfectly clear in some areas, leaving room for subjective interpretation. One of these areas has to do with admin cost versus indirect cost. These are two separate things.

Admin cost is typically related to the cost to service a handful of grants. For example, admin cost is the salary and benefits of the grant administrator/program manager spread over the grants they support. Indirect cost, on the other hand, is not readily identified with a specific project or organizational activity and is related to agency wide indirect cost that support not only grants but all services in an organization regardless of funding source – think of this as the cost of running payroll and IT support services related to the support of the overall grant and all direct staff supporting it. Now, some grant Notification of Funding Awards (contracts) clearly spell out that no indirect cost is allowed, however may still provide for an admin cost, and usually with a cap. In that case, you would not be able to claim anything besides admin cost. But it is critical to note that the grant contract must explicitly state that “indirect” is unallowable not just admin, otherwise indirect is allowable.

Nicolie Lettini, MBA, is a director with Cherry Bekaert. She has more than 23 years of experience providing accounting, advisory and cost allocation services, financial analysis and management consulting services to government contractors, government and public sector, nonprofit organizations and professional services clients

Understanding the Single Audit, Common Pitfalls, and How to Avoid Them

In September 2023, Claire Hilleary and Ariel Lybarger of Moss Adams led a webinar presentation on common Singl Audit pitfalls and how to avoid them. Below are key takeaways covered in their presentation.   

Missed the webinar? View the recording HERE. (Member login required)

What Is a Single Audit?

A Single Audit, also known as a Uniform Guidance audit, is a comprehensive examination of an organization’s financial statements and compliance with federal award requirements. Single Audits are conducted to ensure organizations expending federal awards meet the necessary regulations and are accountable for the funds they receive.

A Single Audit includes an audit of both your organization’s financial statements and compliance with federal award requirements for those programs identified as major programs—based on application of the risk-based approach and criteria outlined in Title 2 Code of Federal Regulations (CFR) Section 200.518 and .519—for the audit.

Through the audit process, the auditors determine whether your organization’s financial statements fairly present the financial position of the organization and whether they’re presented in accordance with Generally Accepted Accounting Principles (GAAP) or another comprehensive basis of accounting.
Both the financial statement audit and the compliance audit provide information on the internal controls design appropriateness and operating effectiveness, which enables management to identify systematic weaknesses in a timely manner.

What Governs How It’s Completed?

The standard-setting body that governs Single Audits in the United States is the Office of Management and Budget (OMB). The OMB issues the Compliance Supplement that auditors use to conduct Single Audits. Single Audits are required for non-federal entities (NFEs) that expend more than $750,000 of federal dollars within their fiscal year. An NFE means a state, local government, Indian Tribe, Institution of Higher Education (IHE), or not-for-profit organization that carries out a federal award as a recipient or subrecipient. Recently, OMB proposed revisions to the Uniform Guidance, most notably to raise the Single Audit threshold from $750,000 in federal awards expended within a fiscal year to $1 million, the first increase in the Single Audit threshold since 2013.

Types of Findings

Audit findings can be categorized as a Financial Statement finding or a Compliance finding:

Financial Statement
A financial statement finding relates to accounting controls or the accounting assumptions used to prepare the accounting records. These findings represent departures from GAAP or deficiencies in the internal controls designed to ensure the financial statements fairly present your organization’s financial condition.

Compliance
A compliance finding is related to noncompliance with federal laws, statutes, regulations, and program terms and conditions, or deficiencies in the internal control over compliance designed to ensure the organization complies with such provisions. This type of finding is specific to an individual compliance issue for a major program.

Financial statement and compliance concerns must be evaluated and categorized into one of three categories: a control deficiency, significant deficiency, or material weakness.

Control Deficiency
The design or operation of a control over financial reporting or compliance doesn’t allow management or employees to prevent, or detect and correct, misstatements or noncompliance on a timely basis. A control deficiency is less severe than a significant deficiency.

  • Design deficiency. A control necessary to meet the control objective is missing, or an existing control isn’t properly designed so that, even if the control operates as designed, the control objective wouldn’t be met.
  • Operation deficiency. A properly designed control doesn’t operate as designed or the person performing the control doesn’t possess the necessary authority or competence to perform the control effectively.

Significant Deficiency
A deficiency, or combination of deficiencies, that is less severe than a material weakness, yet important enough to merit attention by management.

Material Weakness
A deficiency, or a combination of deficiencies, exists in internal control for either financial reporting or compliance, such that there’s a reasonable possibility that a material misstatement of the entity’s financial statements or material noncompliance won’t be prevented, or detected and corrected, on a timely basis.

Material weaknesses and significant deficiencies in internal control over financial reporting or over compliance must be reported as part of the financial statements or Single Audit report. Internal control or noncompliance concerns not categorized as a material weakness or significant deficiency can be communicated in a separate management letter to the auditee.

Next Steps Checklist

What Will Your Single Audit Look Like?

Each Single Audit is different, so it’s important to discuss with the auditor what to expect, what should occur, your responsibilities, and the specific duties of the auditor. Cover this in your engagement letter.
Factors that influence what occurs during the audit include the complexity of your organization and the availability and completeness of the documentation supporting the internal control system, financial statements, and program activities and expenditures.

Generally, auditors will perform audit steps to:

  • Determine if your organization’s financial statements are fairly presented
  • Determine if the Schedule of Expenditure of Federal Awards (SEFA) is complete, accurate, and fairly presented in relation to your financial statements
  • Gain an understanding of and potentially test key internal controls
  • Determine if your organization complied with select federal statutes, regulations, and terms and conditions of your federal awards
  • Follow up on prior audit findings
  • Obtain evidence to form and support their opinions on the financial statements and program compliance
  • Develop and report internal control and compliance findings for the current year in the Single Audit report

Auditors won’t provide any opinion on your internal controls. If they identify something they see as an issue, they’ll report it as a finding, but won’t offer opinions as they would on the material accuracy of your financial statements or compliance.

If a finding related to internal controls is identified, and corrective actions are taken, an internal audit specific to those controls and processes may be an effective way to prevent the finding in subsequent years.

Common Pitfalls in Grant Compliance

The most common pitfalls in grant compliance are found in the following areas:

  • Reporting
  • Matching, level of effort, and earmarking
  • Sub-recipient monitoring
  • Eligibility
  • Allowable costs
  • Indirect costs
  • Procurement

Reporting

  • Inaccurate reports. Time and effort reporting, including inconsistent application of requirements across all funding sources, and time charged across all sources exceeds 100%.
  • Unsupported report data. Point-in-time system reports not retained.
  • Late reports. Delinquent report submissions or unsubmitted project close-out reports.

Matching, Level of Effort, and Earmarking

  • Inaccurate records. In-kind volunteer hours not reviewed.
  • Inaccurate calculations. Currency conversion or insufficient match funds due to Excel formula error or conversion not performed.
  • Supplement, not supplant. Funding is meant to augment, not replace.

Sub-Recipient Monitoring

  • Assistance Listing Number (ALN), formerly the Catalog of Federal Domestic Assistance (CFDA), not communicated to sub-recipients
  • Unique Entity ID (UEI), formerly the Data Universal Number System (DUNS) number, verification not completed
  • Risk assessments not completed regularly
  • Monitoring not completed, or not completed adequately or in a timely manner

Eligibility

  • Inaccurate determination. Program participants didn’t meet the maximum age, income, or geographic thresholds; no process in place for eligibility determination, such as age, income, background checks, and citizenship
  • Record retention. Process doesn’t ensure consistent retention of documentation

Allowable Costs

  • Payroll allocations are based on an estimate rather than actual
  • Time related to program payroll isn’t contemporaneously documented
  • Time related to program payroll isn’t reviewed and properly approved
  • Program expenses aren’t reviewed and approved by grant manager
  • Costs not allowable
  • Costs not properly supported

Indirect Costs

  • Indirect costs include unallowable costs
  • Indirect rate is misapplied
  • Indirect methodology not documented or not applied consistently across programs

Procurement

  • A procurement policy exists, but the organization doesn’t enforce it
  • The organization has appropriate procedures but didn’t update its policy
  • The organization cannot prove that a vendor was checked for suspension and debarment
  • Sole source justification wasn’t properly completed
  • Supporting documentation is not retained to support due diligence performed

How to Prepare for a Single Audit
Prior to the audit, there are actions your organization needs to take. Below are some steps auditees can take to help your Single Audit go smoothly.

  • Gather and summarize all federal grant information
  • Prepare financial statements and notes
  • Prepare a detailed draft of the SEFA
  • Ensure policies are developed and up to date, in place, and comply with the federal awards
  • Provide the auditor with access to information
  • Review prior Single Audit findings
  • Prepare the Schedule of Prior Audit Findings
  • Review and update internal controls
  • Seek help, when or if needed – asking questions early and often may prevent audit findings in the future

Five Grants Management Systems to Develop to Ensure Success

When a grants manager hears the term “grants management system,” they may picture a complicated, costly, technology-driven, data management system that requires an outside professional consultant to develop. This perception frequently leads to the employing entity to dismiss consideration, citing budget constraints. In truth, I have found that an effective grants management system can be a simple set of tasks or activities that help a grant manager understand administrative responsibilities, programmatic commitments, subaward/subrecipient management, expense monitoring, and overall performance tracking and reporting. Of course, there are other tasks and activities to consider, however, developing a firm understanding of these five systems has worked for me and my colleagues. Here, I will focus on simple systems that can be deployed without the cost of developing a technological solution.

Administrative Responsibilities

Understanding that administrative responsibilities start well before a grant is awarded, or even considered, is crucial.  The entity must have the capacity to:

  • perform general administrative tasks associated with reviewing opportunities;
  • assist programmatic staff in developing effective project narratives, timelines, and budgets;
  • meet the application requirements according to grant guidance documents;
  • interact with grantors;
  • communicate with stakeholders, including other business units within the entity; and
  • ensure that an effective structure is setup in the entity’s accounting systems.

This is not an exhaustive list but should give a general understanding that there is a significant investment of time and effort associated with the administrative responsibilities required for a given grant. These activities can be managed using something as simple as a checklist that includes as many foreseeable tasks as possible.

As new tasks are identified, updating the checklist is essential to ensuring the next grant is sufficiently evaluated for capacity, as compared to performing the task and hoping to remember it the next time. To enhance the effectiveness of a checklist, it is helpful to identify the staff or functional area responsible for each item or section of the checklist. Doing so provides the broadest opportunity to assess an entity’s overall capacity and to weigh the cost of capacity against the value of a grant.

Example: If the most basic administrative capacity requirements total 240 staff hours, at an average of $30 per hour, the minimum capacity cost is $7,200. This does not include the cost for programmatic staff to perform implementation commitments. For a $20,000 grant, the administrative costs are 36% of the grant, excluding any applicable fringe benefits or indirect costs. Many grants allow a maximum of 10% administrative costs. In such a case, it is probably not in the entity’s best interest to pursue a $20,000 grant.

Programmatic Commitments

For this article, “programmatic or program” refer to the business unit or staff implementing the grant. With a few exceptions, there are most likely specific outputs and outcomes for which the program has made a commitment.   Commitments, sometimes referred to as deliverables, are specified in a project narrative and/or work plan. There is an expectation that commitments or milestones will be completed within estimated time periods or not later than the end of the project period specified in the grant award. Developing a system for tracking commitment status and timelines can, again, be as simple as creating a checklist by converting the commitments from a narrative format to a line-item format, complete with due dates and a space for status notes.

Example: The commitment in a narrative format may be presented as: Through this grant, the energy costs will be lowered by an average of 20% for 45 disadvantaged homeowners in the first quarter of the grant’s project period through the purchase and installation of energy-efficient windows.
Converting the narrative into a measurable line-item format might be presented as: This grant will benefit 45 disadvantaged homeowners (output) to reduce household energy costs by an average of 20% through the purchase and installation of energy-efficient windows (outcome) in the first quarter of the project period (timeline).

For this example, the status at the end of the first quarter could be something to the effect of: 48 households benefited; average energy cost reduced by 27%, or 34 households benefited; average energy cost reduced by 17%; commitment delayed due to window supplier backorder.  

Through this type of checklist, both updates make visible the progress for the commitment and are available in a single location for inclusion in any required performance reports to the grantor. The checklist will also play a role in the Performance Tracking and Reporting section discussed later.

Subaward/Subrecipient Management

The systems discussed in this section are the result of identifying and addressing prior significant deficiencies. My organization had a lot of “hit and miss” attempts to develop a single solution over the past several years. A major lesson I learned is that you don’t know what you don’t know until you find out that you don’t know, and then you have no choice but to fix it. This has been the mantra that propelled my organization to prioritize the development of our current system, which addresses pre-award, subaward agreements, and post-award implementation of subawards.

By mirroring the typical grant cycle, we are able to capture activities that had often been skipped or performed in a less-than-effective manner. As with prior sections, the system can start with a simple checklist that includes the various activities and requirements. However, because of the complexity surrounding subawards and subrecipients, we engaged in a process-mapping exercise that starts from the moment the need for a subaward is identified through all of the steps leading up to the subrecipient receiving reimbursement for services rendered. The results of the mapping led to multiple systems for ensuring appropriate and compliant selection of subrecipients; standardized agreement templates that include all federal and/or other grantor requirements; standardized subrecipient budgets and reimbursement requests; standardized expense review and approval processes; standardized monitoring and risk assessment.

As mentioned earlier, each of these systems can be combined and used as a checklist, or they can be maintained as separate components to be used, depending on the phase of the subrecipient management cycle. The key takeaway here is that a system, even an imperfect system, will help a grant manager be successful. The more activities and tasks that are captured in and through the system, in addition to the consistent standardized manner in which an organization adheres to the system, is paramount.

Expense Monitoring

While it may seem intuitive, revenue and expenses associated with a grant should be tracked separately from the entity’s other sources of revenue and expenses in a financial management or accounting system. However, that may not always be the case. A successful grants manager will ensure that each grant is uniquely identifiable and trackable.

My organization has a robust financial system that prevents comingling grant funds with other funding sources, including other grant sources. However, that alone does not always provide the information needed to ensure appropriate monitoring. Financial accounting often captures the what, the who, and the amount associated with an expense; however, it rarely captures the why. This is where an additional system becomes necessary.

Two of the more effective and efficient systems used in day-to-day expense monitoring are what we refer to as a tracking tool and a standardized expense review process. Each grant has its own standard tracking tool that serves the purpose of capturing the data that will help assemble both financial and performance reports. The tracking tool is set up to be in alignment and make visible the original budget as approved in the grant award, as well as tracking the actual expenses incurred in each cost category. An observation prior to implementing the tracking tool was that when a grant was awarded and the budget established, there was little attention paid to actual expense allocations occurring during a given performance reporting period. This led to significant rework, expense transfers, and requests to the grantor to reallocate the budget, with no guarantee that the request would be approved. This opened our organization to substantial financial risk and the likelihood of noncompliance. The tracking tool functions as an early warning system if spending drifts unexpectedly.

The system used for standardized expense review applies to all grant expenses as well as subrecipient reimbursements. The system is similar in nature to a checklist, but is arranged according to the role each responsible party has in the process. This system was developed in response to an internal audit observation showing inconsistent expense review and approval processes among programs. A deeper audit revealed that the inconsistency frequently led to missing steps and authorized approvals, leading to rework and disqualification of expenses lacking sufficient supporting documentation. The system includes steps that the program must perform, including confirming that the expense is in alignment with the grant parameters and adheres to the basic cost principles of being necessary, reasonable, and allocable. The program must also ensure that appropriate supporting documentation is included, such as detailed invoices and performance reports, when applicable. The grant manager confirms the information and ensures appropriate program approvals are in place and adds it to the tracking tool before forwarding the request to Accounts Payable, where additional standard steps have been assigned for the person processing the transaction. This system has corrected the deficiencies through standardization, which includes clearly communicated roles and responsibilities.

Performance Tracking and Reporting

Performance reporting requirements are a primary expectation included in nearly all grant awards. The majority of grantors want to confirm that the program is implementing the grant according to the award and its related terms and conditions on schedule and within budget. Financial systems and the tracking system described in the Expense Monitoring section are sources for responding to the financial performance of implementing the grant. Having a system to track commitment performance is equally essential to the success of a grants manager. An effective grants manager will confirm that the reporting expectations are included in the checklist described in the Programmatic Commitments section. As mentioned earlier, the checklist makes visible the commitments and progress. The visibility ensures an additional level of accountability to the program.

The checklist’s visibility can help a grants manager compile additional performance metrics to be provided to the entity’s internal leadership, even if it is not a grant reporting requirement. An example of metrics of interest to my organization’s leadership include the percentage of commitments completed relative to the total commitments, the percentage of commitments completed within the established timelines, and the actual outputs and outcomes versus the estimated outputs and outcomes.

Example: Five completed commitments out of 25 total commitments is 20%. Of those five, three were completed within the timeline, or 60% on time. One of the commitments completed on time estimated that 45 households would benefit from the commitment (output) to provide disadvantaged homeowners with energy-efficient windows to reduce household energy costs by 20% or more (outcome). However, the actual number of homeowners receiving assistance was 49 and the average cost savings was 27% per household. This means that the commitment served 8.8% more homeowners and the savings were 35% higher than expected. These four performance metrics serve to show that the program is progressing through the completion of commitments but is missing the time commitments 40% of the time. The entity leadership or grants manager may want to know why there are delays and what can be done to help the program achieve its goals. If this information is presented in the grantor reports, it is highly likely that the grantor will be pleased to see that their assistance provided an even greater benefit than expected, even if it took longer than estimated. Most of all, this information can be easily captured through the checklist at any given point in time.

In addition to the benefits of the checklist, establishing a reporting calendar for the grant that triggers reminders to responsible parties helps to manage adherence to the grant requirements. A component of the reporting system I have found works for me is adding key internal dates on my calendar as a meeting to which I invite the responsible program staff. This serves as an effective “check-in” with the program and confirms report due dates.

In conclusion, having strong, consistent grants management systems in place, no matter how simple or complex, will help a grants manager be more successful in performing day-to-day activities. Continuous improvement to those systems, clearly defined roles, frequent communication, visibility, and leadership support increase efficiency and reduce the likelihood for audit findings or redundancy in effort. Standard work processes are essential. When multiple parties are performing grants management functions in silos with different processes and procedures, it will (not might) lead to problems that are often costly and time-consuming to remedy.

Robyne Clark, CGMS is a grants manager with the Arizona Department of Environmental Quality. Her favorite part of grants management is helping the recipient program staff who are applying for and/or implementing a grant navigate through the processes. She has been a Certified Grants Management Specialist (CGMS) since 2019.