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Compliance in the
Midst of Chaos:
Managing your federal award when
everything is
Learning Objectives
Managing your federal award when everything is urgent:
 Introduce management tools for determining true “urgency” in project management
 “Triage” of requests
 System Implementation
 Review regulatory options and supplements that streamline project management
 2 CFR 200’s Fixed Amount Award (FAA)
 10% “de minimus” for indirect cost
 Discuss “rescue” techniques for overburdened projects experiencing ongoing chaos
 Vin Diesel model
 Angelina Jolie model
 Liam Neeson model
 007 model
Determining
“Urgency”
“Triage”
Commonly used medial term with grant-
management (or project management) applicability
─ Ignores non-critical “deadlines”
─ Considers core issue and ability to resolve
─ Question to ponder when all things equal: “what is the
consequence of inaction”
Triage in Grant Management
Creating
Systems/Processes
“Systems/Processes”
Development of a consistent, documented and repeated
method for responding to events or implementing activities:
─Systems should eventually become invisible, it just
becomes “the way we do things”
─True systems are taught and re-taught so that everyone
understands what happens and when
─Systems do not have to be complicated, they can be as
simple as a checklist, template or chain of communication
“Systems/Processes”
 Regulatory connection to the establishment of
“systems” is “internal controls”
 Your internal controls should check whether or not
your “systems” are consistently applied
 Examples of systems: files for your grant records;
methodology for monitoring sub-grantees;
procurement process
____ Current mission / vision / values statements
____ Board member recruitment system
____ Board member orientation system
____ Board development and training strategies
____ Attendance policies
____ Membership and term limitation policies
____ Organizational chart
____ Chair and officer job descriptions
____ Committee charters
____ Board operations and policy manual
____ Chief executive performance review process
____ Board self-evaluation process
____ Board calendar with meetings, events, activities and updates
____ (Other items:)
BOARD OF DIRECTORS
Recommended “Systems” Check:
Recommended “Systems” Check:
____ Current strategic plan
____ Diversity plan (for Board and staff)
____ Marketing plan
____ Fundraising / Development plan
____ Board and committee work plans (with objectives and timelines)
____ Yearly operations plan, including staff work plans
____ (Other items:)
PLANNING
____ Valid methods to assess client needs (focus groups, surveys, etc.)
____ Established service outcomes to match client needs
____ Established target indicators for each outcome
____ Data collection methods for each target indicator
____ (Other items:)
PROGRAM AND OUTCOMES EVALUATION
____ Client program records
____ Volunteer records
____ Personnel records
____ Financial records
____ Donor and contributor contract records
____ Mailing lists
____ Work flow descriptions for each major operational activity
____ Operations manual containing work flow descriptions
____ Inventory of computer hardware, software, peripherals, etc.
____ Procedures for each major function to maintain computer systems
____ Regular backups of computer disks (one copy stored offsite)
____ Disaster recovery plan (one copy stored offsite)
____ (Other items:)
Recommended “Systems” Check:
INFORMATION MANAGEMENT
____ Board-adopted fiscal policies
____ Board-approved fiscal year budget
____ Financial procedures / internal controls manual
____ Inventory system
____ Depreciation schedules
____ Cash flow analysis system
____ Partial or full accrual accounting system
____ Monthly financial statements with balance sheet
____ Yearly audit or outside review
____ Program analysis system
____ Tax and other reporting schedules
____ Payroll record system
____ (Other items:)
FINANCES
Recommended “Systems” Check:
Systems/Processes
“Grant managers, stay in your lane!”
Systems/Processes
 Grant management is directly connected (but not always
engaged in) organizational systems
 2 CFR 200.303 (a) Internal controls require that your
organization “establish and maintain effective internal controls
over the Federal award that provide reasonable assurance that
the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms
and conditions of the Federal award.”
Systems/Processes
 Grant managers help the
entire organization apply the
regulations and Standards
for Internal Control in the
Federal Government is a part
of that
 Grant managers have a
perspective that differs from,
but compliments leadership
and program management
Useful tools for “systems” check:
• http://managementhelp.org/organizationalperformance/nonprofits/system
s-checklist.htm
• http://www.gao.gov/assets/670/665712.pdf
• https://www.mango.org.uk/guide/healthcheck
Regulatory Tools to
help with managing
“chaos”
OMB “Super Circular”
• Developed by the COFAR- Council
on Financial Assistance Reform
beginning in 2011
• COFAR established by Obama
Administration with intention of
enhancing transparency of Federal
spending and advancing efforts to
detect and remediate fraud, waste
and abuse in Federal programs
Super Circular…
• Incorporates OMB Circulars A-21, A-87, A-110, A-122, A-
89, A-102, A-133 and A-50
• For states, tribes, colleges & universities, hospitals and
non-profit organizations
• Applicable to Federal agencies 12/26/13; non-Federal
entities 12/26/14
“Super "Circular does/states…
The intent of the new guidelines
is to do the following:
• consolidate existing
regulations,
• streamline processes,
• harmonize rules and
regulations that seemed
contradictory; and,
• simplify.
2 CFR 200
Two “new” regulations for easier grant-
management:
1. Fixed Amount Award
2. Ten percent (10%) de minimus cost for indirect
expenses
2 CFR 200.201:
• Introduces the “new” awarding instrument: Fixed
Amount Award(FAA)
• FAA require no governmental review of actual costs
incurred before completion of the award
• FAA may be used if the project scope is specific and
if adequate cost, historical, or unit pricing data is
available to establish a fixed amount award with
assurance that there will be no increment above
actual cost
• Introduces an option for applying a standard 10% of
modified total direct costs to new awards to cover
indirect expenses
• If used, it must be applied to all federal awards until the
organization pursues a Negotiated Indirect Cost Rate
Agreement (NICRA)
• Helpful for smaller organization with no NICRA and
multiple awards
2 CFR 200.414:
Regulatory tools to help manage chaos
Grant management tools can drive solutions to chaos
when used as a part of overall project management:
 Regulations are sometimes the only solution
 COFAR considered “real life” experiences of grant
management professionals when drafting 2 CFR 200, so
regulations may capture an organizational problem others
have already conquered
The union of Grant
Management & Project
Management:
Action Hero Inspired “Solutions”
Angelina Jolie Model: Be Adaptable
Address problems by:
 Changing to meet the needs of
the individual and
circumstances
 Remaining nimble in decision-
making with limited inherit
bureaucracy
 Requires autonomy
Vin Diesel Model: Strategy & Team Work
Address problems by:
 Playing to the strengths of your
team
 Engaging multiple “voices” in
decision making
 Gathering facts and creating a plan
before taking any action
007 Model: Classic & Decisive
Address a problem by:
 Making a decision and taking action. Period.
 Requires unilateral authority
Liam Neeson Model: “I have a particular
set of skills”
Addresses a problem by:
 Cultivating a level of expertise
in one field
 Creating a model based on
acquired expertise
 Consistently applying the model
Which “action hero” could best resolve the
“chaos” using which grant management tool?
Scenario 1:
For your small nonprofit organization, your newly hired program
director has been asked to wear many hats. In addition to his/her
project management duties, they also serve as a compliance officer,
grants manager and H.R. director. After all, there are only five people
on staff.
While reviewing your largest project’s financial records, the new
program director notices that several payments have been directed to a
member of your board of directors for sole source consulting services.
There are no invoices, consulting contracts or even a statement of work
to support the payment. How would you address this problem?
“Action Hero” inspired solutions:
A. Be Adaptable
B. Apply Strategy &
Teamwork
C. Be Classic & Decisive
D. Apply a particular set of
skills
Scenario 2:
One of your project managers has sent 15 emails in the past 24 hours
because he/she is concerned about having enough money available for
payroll. It seems that one of his/her funders did not send additional funds
for completed program activities on a grant with established milestones.
He/she is frantic and does not understand why the funder has not sent
money for the completed activities. Now, he/she will need an advance to
cover expenses for an upcoming training conference in addition to the
money needed to cover payroll.
You pull the grant and financial records for the project. After reviewing
everything, you note that the project never requested an additional
obligation of funds including a request for an advance as permitted in the
grant agreement. A programmatic report was submitted to the funder. But,
a financial report showing that the first milestone was met, and requesting
the tranche of funds for meeting the milestone, was not submitted. The
grant agreement requires both for payment. How would you address this
problem?
Which “action hero” could best resolve the
“chaos” using which grant management tool?
“Action Hero” inspired solutions:
A. Be Adaptable
B. Apply Strategy &
Teamwork
C. Be Classic & Decisive
D. Apply a particular set of
skills
Need more information?
Feel free to email or Skype me:
• Skype: Atoundra
• Email: alawson@pactworld.org
Thank you

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Managing Chaos with Systems and Regulations

  • 1. Compliance in the Midst of Chaos: Managing your federal award when everything is
  • 2. Learning Objectives Managing your federal award when everything is urgent:  Introduce management tools for determining true “urgency” in project management  “Triage” of requests  System Implementation  Review regulatory options and supplements that streamline project management  2 CFR 200’s Fixed Amount Award (FAA)  10% “de minimus” for indirect cost  Discuss “rescue” techniques for overburdened projects experiencing ongoing chaos  Vin Diesel model  Angelina Jolie model  Liam Neeson model  007 model
  • 4.
  • 5. “Triage” Commonly used medial term with grant- management (or project management) applicability ─ Ignores non-critical “deadlines” ─ Considers core issue and ability to resolve ─ Question to ponder when all things equal: “what is the consequence of inaction”
  • 6. Triage in Grant Management
  • 8. “Systems/Processes” Development of a consistent, documented and repeated method for responding to events or implementing activities: ─Systems should eventually become invisible, it just becomes “the way we do things” ─True systems are taught and re-taught so that everyone understands what happens and when ─Systems do not have to be complicated, they can be as simple as a checklist, template or chain of communication
  • 9. “Systems/Processes”  Regulatory connection to the establishment of “systems” is “internal controls”  Your internal controls should check whether or not your “systems” are consistently applied  Examples of systems: files for your grant records; methodology for monitoring sub-grantees; procurement process
  • 10. ____ Current mission / vision / values statements ____ Board member recruitment system ____ Board member orientation system ____ Board development and training strategies ____ Attendance policies ____ Membership and term limitation policies ____ Organizational chart ____ Chair and officer job descriptions ____ Committee charters ____ Board operations and policy manual ____ Chief executive performance review process ____ Board self-evaluation process ____ Board calendar with meetings, events, activities and updates ____ (Other items:) BOARD OF DIRECTORS Recommended “Systems” Check:
  • 11. Recommended “Systems” Check: ____ Current strategic plan ____ Diversity plan (for Board and staff) ____ Marketing plan ____ Fundraising / Development plan ____ Board and committee work plans (with objectives and timelines) ____ Yearly operations plan, including staff work plans ____ (Other items:) PLANNING ____ Valid methods to assess client needs (focus groups, surveys, etc.) ____ Established service outcomes to match client needs ____ Established target indicators for each outcome ____ Data collection methods for each target indicator ____ (Other items:) PROGRAM AND OUTCOMES EVALUATION
  • 12. ____ Client program records ____ Volunteer records ____ Personnel records ____ Financial records ____ Donor and contributor contract records ____ Mailing lists ____ Work flow descriptions for each major operational activity ____ Operations manual containing work flow descriptions ____ Inventory of computer hardware, software, peripherals, etc. ____ Procedures for each major function to maintain computer systems ____ Regular backups of computer disks (one copy stored offsite) ____ Disaster recovery plan (one copy stored offsite) ____ (Other items:) Recommended “Systems” Check: INFORMATION MANAGEMENT
  • 13. ____ Board-adopted fiscal policies ____ Board-approved fiscal year budget ____ Financial procedures / internal controls manual ____ Inventory system ____ Depreciation schedules ____ Cash flow analysis system ____ Partial or full accrual accounting system ____ Monthly financial statements with balance sheet ____ Yearly audit or outside review ____ Program analysis system ____ Tax and other reporting schedules ____ Payroll record system ____ (Other items:) FINANCES Recommended “Systems” Check:
  • 15. Systems/Processes  Grant management is directly connected (but not always engaged in) organizational systems  2 CFR 200.303 (a) Internal controls require that your organization “establish and maintain effective internal controls over the Federal award that provide reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
  • 16. Systems/Processes  Grant managers help the entire organization apply the regulations and Standards for Internal Control in the Federal Government is a part of that  Grant managers have a perspective that differs from, but compliments leadership and program management
  • 17. Useful tools for “systems” check: • http://managementhelp.org/organizationalperformance/nonprofits/system s-checklist.htm • http://www.gao.gov/assets/670/665712.pdf • https://www.mango.org.uk/guide/healthcheck
  • 18. Regulatory Tools to help with managing “chaos”
  • 19. OMB “Super Circular” • Developed by the COFAR- Council on Financial Assistance Reform beginning in 2011 • COFAR established by Obama Administration with intention of enhancing transparency of Federal spending and advancing efforts to detect and remediate fraud, waste and abuse in Federal programs
  • 20. Super Circular… • Incorporates OMB Circulars A-21, A-87, A-110, A-122, A- 89, A-102, A-133 and A-50 • For states, tribes, colleges & universities, hospitals and non-profit organizations • Applicable to Federal agencies 12/26/13; non-Federal entities 12/26/14
  • 21. “Super "Circular does/states… The intent of the new guidelines is to do the following: • consolidate existing regulations, • streamline processes, • harmonize rules and regulations that seemed contradictory; and, • simplify.
  • 22. 2 CFR 200 Two “new” regulations for easier grant- management: 1. Fixed Amount Award 2. Ten percent (10%) de minimus cost for indirect expenses
  • 23. 2 CFR 200.201: • Introduces the “new” awarding instrument: Fixed Amount Award(FAA) • FAA require no governmental review of actual costs incurred before completion of the award • FAA may be used if the project scope is specific and if adequate cost, historical, or unit pricing data is available to establish a fixed amount award with assurance that there will be no increment above actual cost
  • 24. • Introduces an option for applying a standard 10% of modified total direct costs to new awards to cover indirect expenses • If used, it must be applied to all federal awards until the organization pursues a Negotiated Indirect Cost Rate Agreement (NICRA) • Helpful for smaller organization with no NICRA and multiple awards 2 CFR 200.414:
  • 25. Regulatory tools to help manage chaos Grant management tools can drive solutions to chaos when used as a part of overall project management:  Regulations are sometimes the only solution  COFAR considered “real life” experiences of grant management professionals when drafting 2 CFR 200, so regulations may capture an organizational problem others have already conquered
  • 26. The union of Grant Management & Project Management: Action Hero Inspired “Solutions”
  • 27. Angelina Jolie Model: Be Adaptable Address problems by:  Changing to meet the needs of the individual and circumstances  Remaining nimble in decision- making with limited inherit bureaucracy  Requires autonomy
  • 28. Vin Diesel Model: Strategy & Team Work Address problems by:  Playing to the strengths of your team  Engaging multiple “voices” in decision making  Gathering facts and creating a plan before taking any action
  • 29. 007 Model: Classic & Decisive Address a problem by:  Making a decision and taking action. Period.  Requires unilateral authority
  • 30. Liam Neeson Model: “I have a particular set of skills” Addresses a problem by:  Cultivating a level of expertise in one field  Creating a model based on acquired expertise  Consistently applying the model
  • 31. Which “action hero” could best resolve the “chaos” using which grant management tool? Scenario 1: For your small nonprofit organization, your newly hired program director has been asked to wear many hats. In addition to his/her project management duties, they also serve as a compliance officer, grants manager and H.R. director. After all, there are only five people on staff. While reviewing your largest project’s financial records, the new program director notices that several payments have been directed to a member of your board of directors for sole source consulting services. There are no invoices, consulting contracts or even a statement of work to support the payment. How would you address this problem?
  • 32. “Action Hero” inspired solutions: A. Be Adaptable B. Apply Strategy & Teamwork C. Be Classic & Decisive D. Apply a particular set of skills
  • 33. Scenario 2: One of your project managers has sent 15 emails in the past 24 hours because he/she is concerned about having enough money available for payroll. It seems that one of his/her funders did not send additional funds for completed program activities on a grant with established milestones. He/she is frantic and does not understand why the funder has not sent money for the completed activities. Now, he/she will need an advance to cover expenses for an upcoming training conference in addition to the money needed to cover payroll. You pull the grant and financial records for the project. After reviewing everything, you note that the project never requested an additional obligation of funds including a request for an advance as permitted in the grant agreement. A programmatic report was submitted to the funder. But, a financial report showing that the first milestone was met, and requesting the tranche of funds for meeting the milestone, was not submitted. The grant agreement requires both for payment. How would you address this problem? Which “action hero” could best resolve the “chaos” using which grant management tool?
  • 34. “Action Hero” inspired solutions: A. Be Adaptable B. Apply Strategy & Teamwork C. Be Classic & Decisive D. Apply a particular set of skills
  • 35. Need more information? Feel free to email or Skype me: • Skype: Atoundra • Email: alawson@pactworld.org Thank you