Efficient onboarding and intuitive form-building tools were essential to launching the State of Montana’s massive COVID-19 grant program in just a few weeks.

In April 2020, Montana Governor Steve Bullock faced a major challenge. In the midst of a pandemic and economic crisis, The State of Montana received $1.25 billion of funding as part of the Coronavirus Aid, Relief and Economic Security (CARES) Act. The funds needed to be distributed to in-need organizations and individuals across the state as soon as possible.

Bullock and his team needed a grant application management solution that would be easy for Montanans from all walks of life to fill out. They also needed a system that was safe and secure. Finally, because they would have to very quickly train hundreds of state employees to review and track submissions, the State of Montana needed a user-friendly, centralized system.

With Submittable, along with a lot of smart organization and planning, they had a process up and running smoothly in a matter of weeks.

“I’ve worked with different application softwares over the years for both grant
management and for other purposes in the office. Submittable
provides quick turnaround when you can edit your own forms—and
it doesn’t require a lot of training to learn how to do that.”

    Angie Nelson, Senior Budget Analyst

Facing the challenges of a pandemic

The roadblocks faced by the State of Montana were the very same roadblocks that Montanans were faced with in the wake of coronavirus: they had to set up remotely, without access to their offices, on limited resources and time.

Both parties forged ahead by remaining flexible and anticipating problems before they surfaced.

The first step the State of Montana took was the swift creation of forms that asked enough information to guard against fraud but not so many questions that their application added barriers to getting help or slowed down the review process.

The second step was taking old forms and systems online and making them consistent—for example, housing grants that had for years been conducted with paper applications needed to be converted into a digital process, with new questions added to address the pandemic.

One of the program coordinators, Angie Nelson, Senior Budget Analyst, explained how easy form building was essential for her team’s quick start.

“We created a team of folks that included one that currently worked with Submittable, which was helpful,” Nelson says. “And the functionality of being able to drag and drop fields to create forms was very helpful because it allowed more people to start work on forms in a pretty rapid succession, rather than having just one or two people trained to do that.”

Onboarding for everyone

Grant reviewers also needed to be trained—and there were about 300 of them. Many were government workers who had been displaced from their normal day jobs thanks to COVID-19, and they came from diverse educational backgrounds. Staff who had previously managed forest fire or transportation grants were suddenly put in charge of small business stabilization or PPE funding.

“We had Diana [a Submittable onboarding specialist] host some training sessions that were less than an hour and went through the basics,” Nelson explains. “Those were recorded, so when we had folks come later on, we would forward that training for them to watch. Then as we went, each team would deal with their own unique issues through phone calls, Zoom calls, Microsoft teams calls, and Google Hangouts with Submittable.”

Learning to pivot

When the program went live, the state was flooded with 5,000 applications in one day. By the time applications had closed, that number has since increased to over 18,000.

As issues arose, the state and Submittable joined forces to problem solve in real time.

First, the team quickly realized that applicants had the same pandemic-related issues that both the state and Submittable faced: they were away from their offices and often lacked time and resources.

“Obviously a lot of folks are maybe not working in their offices with their printers and all of their network equipment,” she explains. “We moved to accepting photos of documents and other non-traditional file types. We just tried to be flexible as we needed to pivot in the middle of the process.”

Submittable also took extra steps to ensure the forms were mobile friendly for those away from their desktops and offices. And when repeated questions arose about certain requirements or application steps, Submittable made clarifying changes to the forms to streamline mid-process.

Reviewing thousands of documents while still being thorough

Once documents were in, applications needed to be reviewed and either approved or rejected. Submittable’s platform made it easy for the state of Montana to create teams of reviewers and limit certain permissions to only those who needed them.

“We also very heavily used [Submittable’s] review process features: the reviewer permission levels and the auto assignments,” Nelson explains. “One thing that worked very well was creating team leaders for each group: Level One reviewers did the first basic review of checklists and Level Two dealt with the issues. Then the compliance team, the folks reviewing the financial aspects, made sure each application was ready for award payment.”

Support for everyone alike

Submittable assigned a dedicated support person to Montana’s program who helped administrators, reviewers, and submitters alike.

When the state needed to provide step-by-step instructions to applicants on how to handle a specific action within their application process, the Customer Support team quickly wrote multiple help articles.

“There has been a very high volume of usage of support,” Nelson says. “I personally appreciate the support folks and that we received feedback from support. If they saw a particular portion of an application folks were having an issue with, and if they had a potential improvement that would maybe help  applicants be more successful, they’d let us know. So that feedback was appreciated.”

Tracking and reporting made easy

Once grants are awarded, administrators are able to track and analyze data within the platform.

“For me personally, and for some of the higher level folks in management and troubleshooting, the advanced reporting feature is utilized daily,” Nelson observes. “Folks are using it to sort and pivot and pull updated data daily for various purposes. Reporting has been a very heavily used feature—and a great and effective one for our team.”

Submittable’s fund tracking features also made it easier for the state of Montana to see the bigger picture while juggling so many different grants and programs at once.

“The other main feature that we really used was the funds feature: the ability to track funds with the funds tab and use that dashboard,” Nelson shares. “We like the more visual perspective of all the different funds and how much is awarded and paid out. When you have multiple programs and multiple funds, it’s so helpful to see where we’re at and track that information.”

Ongoing help through tough times

As of the beginning of September 2020, over $1 billion of $1.25 billion in Coronavirus Relief Funds have been committed with over $329 million of that awarded, supporting nearly 12,000 Montana businesses and organizations.

“I’m just really proud of the group of people that have come together and worked tirelessly over long hours to help people in Montana, the businesses, the organizations,” Nelson says. “None of us have met in a room together. This was all done remotely and to be able to successfully roll out programs and do our very best to help people has been an accomplishment.”

The programs will continue to benefit Montanans across the state as long as funding and need persist.

“We had [a grant application] that went live this week for loan deferments for businesses,” Nelson says. “We’re still moving and still heavily utilizing the full life cycle of the Submittable’s software.”

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We experience conflict in our workplaces, in our communities, and our institutions. While conflict is inevitable, it is not irreparable. How do effective leaders approach conflict? How can we ensure that our conflicts are civil?

The leaders who have personally experienced conflict tend to be more comfortable addressing conflict than others. Observing parents or caregivers engage in arguments that eventually resulted in greater understanding, and trust seems to precede an aptitude for successful conflict resolution.

Leaders who have experienced shouting, name-calling, and resentment in their personal lives typically have to work harder to understand how to best address conflict resolution with confidence.

To be effective, leaders need to understand that serious, respectful disagreements are part of normal communication and that all participants must seek to understand. They have seen how listening stimulates creative problem-solving skills and collective genius within teams. When they see trouble brewing, they are quick to confront it before issues have time to fester. Conflict is not about winning; it is about learning.

Successful Conflict Resolution

The communication model, “Compassionate Communication,” developed by neuroscientist Andrew Newberg, M.D. and Mark Waldman, has proven to be extremely effective in resolving conflicts. In brief, it recommends that participants:

Speak briefly. Do you know that the brain can hold only about ten words in working memory (i.e., your current state of consciousness)? Considering that most Americans speak for two minutes before pausing, the listener may only remember one-tenth of what was said. To encourage clarity, insist that participants state their issues and responses in ten words or less. Watch how the tone of the conversation, the word choice, and the quality of listening changes.

Speak slowly. The best key-note speakers use this technique to catch the audience’s attention and emphasize a point. The same is true when tempers flare. Varying your cadence by shifting to a slower pace at critical moments helps lower the temperature of emotions.

Speak warmly. Even in conflict, a warm tone of voice can engender trust and cooperation. Why? We unconsciously mirror the neural activity of the speaker’s brain. This process, known as neural resonance, allows us to more fully understand and more accurately assess the information that is being imparted.

Listen deeply… And without judgment for understanding. This foundation can help resolve even the most seemingly intractable arguments.

These techniques take practice. However, if we want to live in a more peaceful, joyful world, where work environments encourage cooperation, collaboration, and creative thought divergence, it will be worth the effort.

Train Your Brain

Try training your brain to think in 10-word sentences by playing this adapted version of the 10-10 Game. Ask a friend, family member, or colleague to join you and follow these steps:

1. Sit comfortably. Take a deep breath. Relax.
2. Hold your hands in front of you, making a fist. With each word you speak, raise one finger. When you’ve used all ten fingers, you must stop talking and listen to the other person’s ten-word response.
3. After listening to the other person’s ten-word response, respond only to what they said. Don’t go off-topic.
4. Keep going until you reach a point of understanding or the issue has been resolved.

You will end conflicts at home before they begin because there will not be any room for emotional derailment. The 10-10 Game is fun and simple. And, it forces your brain to find the best words to convey what you mean rapidly. It creates the ideal conditions for resolving conflict with respect for everyone involved.

Linda Cassell, M.Ed, CPCC, is an independent certified neuro leadership coach at Management Concepts and president of Quantum Leap Coaching and Training, LLC. An expert in leadership development, crisis management, and culture transformation, Linda works with executives in the commercial, non-profit, and public sectors. She holds a Bachelor of Science and Master’s degrees in Education from Kent State University and is a graduate of the Coaches Training Institute. Linda also holds a Neuro Leadership Coach certification from the Mark Waldman program.

What’s changed for you in 2020?

• A boss or colleague left your organization
• New government restrictions changed how you do your job
• Your team implemented a new process

It wouldn’t matter if you read those bullets today, ten years ago, or even a century ago. Largely, they’re the same concerns we face virtually every year. Humans don’t react well to change, so these concerns mean that we have foreboding cultural angst that manifests itself as plain old worry.

As effective managers, we have the option of giving in to that worry or creating an environment where our peers, team members, and managers can worry just a little bit less. We can best alleviate the worry by leveraging social “anchors” in the world around us. In a sea of change, anchors provide a desperately needed degree of constancy.

Social Anchor Theory

Under Social Anchor Theory, some common contexts and norms provide steadiness in an unsteady world. Any time we can point to something unchanging, it’s an anchor. Even when disasters and civil unrest make members of society believe that life will never get back to normal, people turn to the aspects of their world that do not and will not change.

The concept of Social Anchor Theory is that we all can stabilize the world around us by recognizing those elements that will not change. It’s the reason a warm fire in the fireplace feels cozy. Those who appreciate a roaring fire know that passion will not change with time or situation. And while a hometown may grow or morph over time, it’s still a hometown, with some (if not all) of the familiar trappings.

As leaders, we can develop social anchors for our people. Utility companies do this by opening every meeting with a “Safety Minute.” Some organizations drag out the same holiday decorations for every holiday. Some managers have standard greetings that they use in virtually every situation. And while it may seem those become trite or hackneyed, they serve to anchor our expectations in routines. And those anchors become a comfort.
It creates the opportunity to identify the elements of our workplace and culture that become norms. What norms can leaders create?

• Food – Be it doughnuts or lobster, a regular treat can become an anchor
• Art – Whether it’s Dogs Playing Poker or Girl with a Pearl Earring, the familiarity of a piece of art becomes anchoring over time
• Ceremony – Following the same protocols time and again eventually becomes an anchor
• Theater – Consistently referring to the same plays or movies (e.g., These aren’t the droids you’re looking for) can develop into anchors as well

The idea is to provide cues that are consistent — and ideally unique — to the agency, organization, or team. Once those cues are well-ensconced, they become social context. Indeed, they may even become what Clopton refers to as social capital. They have intrinsic value in the relationship setting involved.

Why Bother Creating Anchors?

Over time, social anchors create a shared sense of service and commitment. Researcher Jessica Sellick points to several studies that demonstrate that social anchors also attract a higher caliber of talent. She asserts that anchors create staying power in the workplace, making it harder to leave.

Begin applying Social Anchor Theory today by drawing attention to the common, long-lived elements in your organization’s environment and affirm the comfort they provide. It’s a huge, long-term win.

Carl Pritchard, PMP, PMI-RMP, is the principal and founder of Pritchard Management Associates and a senior instructor at Management Concepts. An expert lecturer, author, researcher, instructor, and coach, Carl focuses on project management, particularly risk and communications. Carl earned a bachelor’s degree in journalism from The Ohio State University and PMP. He welcomes your comments and insights.

Audits by the General Accountability Office, Office of Inspectors General, internal audit offices and certified public accounting firms have greatly influenced grants management in many Federal, State, and local governmental agencies. While having auditors raise findings and recommendations is not an ideal mechanism for improvement, the role of auditors in grants management cannot be minimized.  The role of auditors will become magnified with the passage of the Coronavirus Act Relief and Economic Security (CARES) Act and the passage of the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act.  If history is any indicator, high risk grants and grantees become more evident when large sums of funds become available result in high risk grantees.  This was evident during the American Resource and Recovery Act (ARRA) of 2009.  During ARRA, more funds were available than the pool of adequate grantees could handle.  As a result, audits of ARRA grants revealed:

• Issues dealing with grantees not performing the tasks outlined in the grant agreement.
• Grantees, whose original mission, or area of expertise, did meet the objectives of the grant award.
• Issues dealing with non-compliance with Super Circular requirements

Since the CARES Act funding of $2.5 trillion is double the ARRA funding of $1 trillion, grant officials must be ever vigilant to ensure that grant funds are spent to meet grant objectives and legislative intent.  Grant officials can also count on auditors playing a major role to ensure compliance with grant requirements and the legislation that enabled the grant authorization.

There are many areas in which auditors influence grants management.  The most common areas are due to:

1. Single Audits
2. Audits of Individual Grant Awards
3. Programmatic Audits of Grant Operations

Single Audits- The most common interaction that grants officials have with auditors is through the Single Audit process outlined in 2 CFR 200.501-520.  Under 2 CFR 200.501, any non-Federal entity that expends $750,000 or more during the non-Federal entity’s fiscal year in Federal awards must have a single or program-specific audit conducted for that year.  Under 2 CFR 200.514, the audit must be conducted in accordance with Generally Accepted Government Auditing Standards. The audit must cover the entire operations of the auditee, or, at the option of the auditee, such audit must include a series of audits that cover departments, agencies, and other organizational units that expended or otherwise administered Federal awards during such audit period, provided that each such audit must encompass the financial statements and schedule of expenditures of Federal awards for each such department, agency, and other organizational unit, which must be considered to be a non-Federal entity. The financial statements and schedule of expenditures of Federal awards must be for the same audit period. The grantee is responsible for follow-up and corrective action on all audit findings. As part of this responsibility, the grantee must prepare a summary schedule of prior audit findings and a corrective action plan for current year audit findings.

Audits of Individual Grant Awards. Auditors at all levels of Government perform audits of individual grant awards.  At the Federal level, 2 CFR 200.503(i0 allows a Federal agency, Inspectors General, or GAO to conduct or arrange for additional audits to carry out its responsibility under Federal statutes or regulations.  Grantee cannot constrain, in any manner, a Federal audit except the Federal auditors must plan the audit to not be duplicative of other audits of Federal awards.  State and local auditors perform individual grant audits under various.  If Federal funds are used for subawards, the state and local auditor could perform individual audits of subawards to meet it responsibility to monitor subrecipients as required under 2 CFR 200.331.  The audits can be interim (during the course of the grant award) or a final audit (as part of the close-out process).  Usually the audit objectives are:

• To determine whether costs claimed are reasonable, allocable, and allowable in accordance with the grant
  terms and conditions.
• To determine whether costs claimed are reasonable, allocable, and allowable in accordance with the grant
  terms and conditions

Some of the findings that can result from individual grant audits are:

• No or inadequate oversight by grantee;
• No or inadequate grantee/implementer accounting system;
• No knowledge of financial/administrative requirements by grantee/implementer;
• Noncompliance by grantee/implementer with financial reporting requirements;
• Unsupported advance payment requests; and
• Improper sub-awards and/or sub-contract awards and oversight.

Programmatic Audits of Grant Operations.  As part of their oversight responsibilities, auditors at all level perform internal audits of the operations for the agency or organization to which they are assigned.  One of the audits that can be performed are audits of the agency’s grant administration program.  The objective of these audits is to determine whether the agency’s grant administration program complies with Federal regulations and agency guidance.  Usually the findings and recommendations from these audits deal with the lack of resources or policies and procedures within the agency to properly administer grants.

Today’s the day! It’s been a long time coming but today is the day that all the revisions to the Office of Management and Budget’s uniform guidance (2 C.F.R. Part 200) issued on Aug. 13 become effective. So what does that mean? Awards issued from today forward, or modifications to existing awards, must follow the provisions in the revised guidance. However, if you have an existing federal award prior to today, you would still comply with the provisions of the traditional uniform guidance.

Hopefully, applicants for and recipients of grants and cooperative agreements have reviewed the changes to the uniform guidance to determine how to plan for them and how to best update their internal policies and procedures. Because many of the citations have changed in the revised guidance due to the addition of new provisions, your current policies for awards going forward may now be out-of-date and would require adjustments.

In addition, we recommend that entities applying for awards that they have sought in the past to thoroughly read the notice of funding opportunity to determine if there are any changes compared to previous years. Along those lines, once receiving an award, it will be critical that they understand the terms and conditions of the award to ensure that they maintain compliance with applicable requirements.

And as we have explained in previous articles, make sure you know which version of the guidance applies to your award. For example, while the closeout provision in the revised guidance allows recipients 120 days to submit closeout documentation, recipients who have existing awards dated prior to today must still follow the traditional uniform guidance, which requires that these documents be submitted within 90 days.

Thompson Grants has now posted the complete version of the revised uniform guidance here. We also will maintain the traditional uniform guidance on the Grants Compliance Expert site for older awards. Further, we are making available a print version of the revised guidance — 2 CFR 200 Uniform Guidance: 2020 Revisions Edition — for $49, which can be purchased here. For a rundown of all the resources Thompson Grants is making available related to the revised guidance, check out our 2020 Uniform Guidance Changes Info Center.

These are definitely exciting times in the grants world! We look forward to this new era in grants administration!

And so it begins…

The Environment Protection Agency (EPA) became the first federal awarding agency to issue updates to its exceptions to the revised version of the uniform guidance by issuing an interim final rule in today’s Federal Register. Federal agencies may request Office of Management and Budget (OMB) approval for such exceptions as they pertain to awards issued by these agencies.

When the uniform guidance was first issued in December 2013, 28 grantmaking federal agencies and offices revised their agency regulations, most of which are now contained in Part 2 of the Code of Federal Regulations, and adopted the uniform guidance either “as is” or with approved exemptions. At least 18 agencies issued exceptions, which is covered in Tab 900 of the Single Audit Information Service, a part of the Thompson Grants 360 package.

OMB’s revised uniform guidance issued Aug. 13, which becomes effective for new awards and modifications to existing awards issued on or after Nov. 12, states at §200.110(a) that the standards in the uniform guidance “become effective once implemented by federal awarding agencies or when any future amendment to this part becomes final.” Therefore, awarding agencies, between now and Nov. 12, must address their regulations to adopt the revised version. For those agencies that adopted the uniform guidance with no exceptions, there’s little they have to do. For other agencies with current exceptions, or those planning to add additional exceptions, they will have more work in updating their regulations.

In its revisions, which become effective Nov. 12, EPA will delete current regulations at 2 C.F.R. §§1500.17-1500.19, and redesignate the current provisions at 2 C.F.R. §§1500.1-1500.16 to §§1500.2-1500.17. It is revising §1500.1 to clarifying that allowable participant support costs may include rebates or other subsidies provided to program participants or program beneficiaries when authorized by the statutory authority for the financial assistance program. It is maintaining current language stating that this provision applies to subsidies used for purchase and installation of commercially available, standard (“off the shelf”) pollution control equipment or low emission vehicles under the Diesel Emission Reduction Act program or other programs when the program participant rather than the recipient owns the equipment.

Among the other updated provisions included in its revised exceptions, EPA states that the uniform guidance subrecipient monitoring and management requirements do not apply to transactions entered into with borrowers by recipients of Clean Water State Revolving Fund (CWSRF) capitalization grants and Drinking Water State Revolving Fund (DWSRF) capitalization grants; recipients may add all program income to their EPA funds for use under the purposes and conditions of the assistance agreement even if program income exceeds the amount anticipated at time of award; and borrowers under EPA assistance programs for capitalization of revolving loan funds are not subject to the limitation on consultant fee costs.

Expect to see more of these type Federal Register issuances in the coming days as agencies update their regulations. More information on the EPA interim final rule will be included in an article next week on the Grants Compliance Expert website. There’s a lot to accomplish between now and Nov. 12.

Join us for our following Federal Grants Forums:
Virtual Federal Grants Forum | October 7-9, 2020
Revised Uniform Guidance Town Hall | October 29, 2020

We here at Thompson Grants were honored to be among the panelist presenting at the National Grants Management Association’s special webinar last week discussing revisions to Office of Management and Budget’s (OMB) uniform guidance. In case you missed it, we provided information to help clarify the effective date under OMB’s Aug. 13 final guidance announcing the revisions.

Transitioning to new regulations can be confusing, but we’ll try to simplify it here as best as we can. Provisions in the revised guidance become effective for new awards and modifications to existing awards issued on or after Nov. 12, 2020, except for two new provisions in the guidance at §200.116 and §200.340, which became effective immediately. Therefore, existing awards will continue to follow the current uniform guidance as addressed in their award terms and conditions.

What are the two provisions that became effective as of Aug. 13? The provision at §200.216, often referred among the webinar panelists as the “Huawei ban,” states that “recipients and subrecipients are prohibited from obligating or expending loan or grant funds to: (1) procure or obtain; (2) extend or renew a contract to procure or obtain; or (3) enter into a contract (or extend or renew a contract) to procure or obtain equipment, services or systems that use(s) covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.” Many of the “covered” companies are Chinese firms, including Huawei Technologies Company. The termination provision at §200.340 now eliminates the current “for cause” reason for termination and replaces it with one stating that an award may be terminated “if an award no longer effectuates the program goals or agency priorities.”

The webinar panel addressed many of the new provisions in the guidance, including topics ranging from the new “Huawei ban”, the de-emphasis of nonbinding guidance (§200.105), the new program planning and design provision at §200.202, changes to performance measurement (§200.301), changes to the period of performance (§200.309), determining recipient risk, changes to the micro-purchase threshold (§200.320(a)), closeout reporting changes (§200.344), and the expanded applicability of the de minimis indirect cost rate (§200.414(f)). The majority of attendee questions following the panel discussion focused on the often-confusing topic of indirect cost rates.

In relation to the discussion on effective dates, one attendee asked whether a recipient organization should wait until Nov. 12 to update its procurement policies and procedures to comply with the new procurement thresholds under the revised guidance. In response to the question, panelist Scott Scheffler, partner with Feldesman Tucker Leifer Fidell LLP, advised that a recipient should go ahead and “get ready” to update their policies and procedures now so that they are prepared for awards received after Nov. 12. We agree; this is definitely good advice. Don’t wait until the last minute to prepare for these changes. Understand now how they will affect your organization and plan to update your internal documents accordingly.

Join us for our following Federal Grants Forums:
Virtual Federal Grants Forum  |  October 7-9, 2020
Revised Uniform Guidance Town Hall  |  October 29, 2020

We expected it would happen sometime this month, and now it’s official. The Office of Management and Budget (OMB) is set to publish its final revisions to the uniform guidance in the Federal Register on Thursday. A lengthy inspection document – over 300 pages long – is available here.

After scanning through OMB’s response to more than 1,200 comments submitted on the proposed revisions issued in January, it appears that OMB opted to maintain its proposed language in many cases but made numerous clarifications to better address its intent throughout the revised guidance.

However, one of the more interesting final revisions relates to a new requirement at §200.414(h) for nonfederal entities to post their negotiated indirect cost rate to a public website. There was a lot of concern about this proposed provision, particularly from tribal organizations, based on privacy and competitive reasons and concerns about comparing rates. OMB has now exempted tribal entities from the requirement and listed details about what exact information grantees must provide (i.e., federally negotiated indirect rate, distribution base and rate type).

OMB also has put off a requirement in the proposed rule at §200.513(a)(3)(ii) to evaluate this year’s audits for a governmentwide single audit quality initiative, as the COVID-19 pandemic is creating many difficulties in performing audits this year. The provision is maintained; it just doesn’t state which year to begin the initiative. OMB also made some key adjustments in the final revisions under the procurement provision to increase clarity.

Although the provision numbers in Subpart C (pre-award) will now change, once the revised guidance is effective, because OMB added a new §200.202 and pushed subsequent Subpart C (pre-award) provisions forward, it has now retained §200.309 (which was proposed for deletion), therefore the numbering system in Subpart D (post-award) remains consistent to the current form, thereby assisting grantees who would’ve had to change their internal policies to reflect the new provision numbers in Subpart D.

The final guidance is slated to go into effect three months after it is posted in the Federal Register (i.e., agencies must implement them in their regulations around Nov. 13). Grantee organizations should get up to speed now so that they are prepared for these changes, and be aware if their awarding agency receives an exception to these provisions in their agency implementation of the revised guidance.

And as always, check with Thompson Grants to get informed on the guidance revisions through our training offerings and publication updates. How big are these changes? As they said in the movie “Spinal Tap”, “This one goes to 11!”

Join us for our following Federal Grants Forums:
Nonprofit Finance & Grants Summit  |  September 14-16, 2020
Virtual Federal Grants Forum  |  October 7-9, 2020

Learn more at http://grants.thompson.com/conferences.aspx.

Pay Attention to the Why, Not the How

The sun rises. The sun sets. Agencies evolve. Processes change. Program missions are affected by any number of variables. This constant change and course adjustment, obviously, will always require systems and IT tools to grow and change to remain efficient and effective. Application modernization presents its own unique challenges to any agency making widespread changes, but those systems are designed to help internal staff execute their mission and perform interagency tasks. However, we’re talking about grants today. And when you try to modernize your grants management system, things get a little more…complicated.

Changing the grants process in any government agency has impacts far beyond the Department, the program offices, and the regions. Grant systems touch so many different pieces of an agency’s mission, entirely different agencies, the public, Congress, financial systems… the list goes on. Factoring in all of the interfaces, cross-agency collaboration, inter-government communication, legislative compliance, it’s not surprising that these initiatives either never get off the ground or fail entirely. It’s completely understandable that agencies find it an overwhelming endeavor just trying to account for all the things that need to be considered to ensure success.

Over the last decade, I’ve watched departments go from automating a paper-based grants process to moving to an outcomes’ driven process, and now they’re turning their eye towards reporting and telling their story. Each of those evolutions in grants management presented a new set of unforeseen challenges that had to be overcome. Whether they were people, process, or technology- hopefully, you can benefit from how the government reacted and solved these new problems.

To identify not only the challenges but also the opportunities that can be maximized through intelligent modernization of grants, let’s go through some of the easiest ways to stay in front of potential gotchas, identify good milestones to review existing process and optimize, and learn from some of our Federal friends.

We’ll start early in the lifecycle with pre-award functions, move through award, and then into post-award.

Policy/Intake

• Ensure that your process and desired system outcomes are meeting all of your new grants forward legislative requirements. Think about the DATA acts’ required elements now, rather than try to scramble to get them in the post-award phase. Doing it now will save you the pain of trying to reconcile it on the fly.
• Remain open to adjusting review processes and procedures that are obsolete, wasteful, and cumbersome. For example, a particular federal agency recently invested $15M towards automating parts of their review process, only to see it go to waste because program staff refused to accept digital information and insisted on original, raw data files from their application kits. This led to tremendous reviewer burden and untold dollars in paper processing. The exact thing they were working to move away from.

Award

• Be mindful that using a standard Notice of Grant Award is far easier and likely more familiar to your grantees/recipients. Agencies seem to love to design specific NGAs for their programs, but often don’t recognize that they require broader testing, development efforts, and work against the data standardization efforts related to grants management. Annual reporting can be negatively affected.
• Try not to ignore or trivialize the opportunity you have in front of you. Now is the time to not just modernize a system to perform tasks, but also to think about getting innovative with your existing workflows and processes. Take care to be mindful that you aren’t replicating the same processes simply because that’s “How the system does it now.” Rebuilding what already exists is not modernization, it’s just duplication.
• A conversation to have early with your PMs and your Program folks is one that reinforces an approach that’s driven by: “Not How, but Why?” Staying attached to the “how” paper moves through the system will only lead to the replication of the same process you’re struggling with now. Rather think of, “Why are we moving it that way? What story are we trying to tell?”

Post Award/Analytics/Reporting

• Carry that “Why vs How?” mindset into your Post Award thinking. Just because you want every piece of information that you can conjure up, doesn’t mean you should be collecting it from recipients. Ask yourselves, “Why are you asking for it and what does it add to your program’s impact story?”
• Make sure you can get the right data out, at the right time, to tell the story you want to tell.

People

• Throughout the process, don’t let the technology get in the way of people. Too many agencies have failed, some multiple times, at trying to modernize their grants system(s) and continually ignored the grant and program staff or failed to garner their input all together. Grants should live in OCFO, not OCIO. Additionally, grant and program staff are the front lines of programmatic mission and delivering change to the American taxpayer. They want to be efficient and impactful, so make sure you let them tell their story. Because their story makes your story resonate better when the public comes asking.

Technology

• Be mindful of technological direction. For years, the government was run on large, monolithic systems with millions of lines of code. Staff expects the same experience that they get in their own interactions with technology. Highly flexible, dynamic tools allow for better announcements, faster awards, and deeper insight into program performance. If you need to change the data elements you’re collecting on a form, or back out a review step in the award process, think about how long you can wait for that change to be made. Take the opportunity now to leverage these dynamic tools that weren’t so widely adopted when your system originally came online. Building flexibility in the design will allow for changes to be made dynamically, without impacting all of the other functions and parts of the system that your staff needs to do the program’s work.

Process

• Be mindful of staying flexible as you define your business processes and workflows. Try to consider building them with an eye on being able to adjust those workflows and processes a year, three years, five years down the road. The Grants process and Program are fluid. Their needs are influenced by a range of things- whether its program realignment to another OPDIV, new legislation, an internal reorgs, or a change in appropriation. Point being, those processes need to be flexible to accommodate those changes. As you establish your requirements, make sure they can be configured, NOT customized. Configured! Think through what things could ever need to change on the fly to make that work in another office, or with a different staff, or even under a different announcement. Reusability adds efficiency.

Need help modernizing your Grants Management system, email Jason McGill at Grants@reisystems.com