Risky Business: Making Sure You Measure Up to New Federal Accountability Measures
When it comes to writing and managing federal grants, accountability is more important than ever. In December of 2013, the US Office of Management and Budget (OMB) issued new and comprehensive grant reform rules that consolidate award requirements previously found in eight separate OMB circulars. The result is a formidable document entitled 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The new rules took effect upon federal awards made after December 26, 2014.
For organizations seeking grants, the revisions represent a greater emphasis on performance indicators and fiscal expenditures.
Among the changes that federal agencies are required to make when scrutinizing applicants is an increased emphasis on risk assessment. Federal agencies are required to run a risk assessment on every awardee prior to the offer of an award. Risk ratings will be partially based on an applicant’s past performance, which includes delivering on promised objectives. The days of unrealistic projections are over. It is more important than ever to craft objectives in an ambitious and attainable manner.
But what does that mean? Objectives should be realistic but challenging. In terms of being realistic, goals, objectives, measurement tools, and milestones should be clear and based on real data that has been run by your organization. For example, do not say you can serve 1,000 students when you know that only 300 are annually served. In terms of developing challenging objectives, organizations should be mindful of going above and beyond typical business pursuits.
In the new environment, it is a true balancing act to create the Need Statement. We are often tempted to make ourselves look as pitiful as possible to express a desperate need for grant funding. However, it is important not to appear as if we are doing so poorly that we cannot programmatically or fiscally manage the grant. Build the argument with current data and evidence and include citations. Focusing on the needs of people is more compelling than focusing on the needs of your organization. Be sure to emphasize that there are tangible solutions to each of the problems described.
The Need Statement is not the place to discuss administrative turnover or other administrative difficulties. Those problems will not be resolved with grant funding and it raises a red flag in terms of an organization’s stability. Do not spend too much time discussing budget problems, especially issues with state funding. While budget issues may have a very real impact on an organization, grant funding will not solve these problems, and funders are not interested in filling a hole left by budget cuts. Overemphasizing budget deficits may also call into question an organization’s ability to fiscally manage or programmatically sustain the project.
Throughout your proposal, be sure to emphasize your strengths as an applicant. This includes detailing your past experiences, such as managing federal grant awards or other large grant-funded projects or contracts. Talk up your experiences as a partner on other grant projects to demonstrate that you are a strong and responsible collaborator. Discuss the collective experience of your finance staff and your ability to prudently manage your own organizational budget.
Federal grant reform has created a new world of accountability measures. The key to securing an award is to communicate that although your needs are great, your organization has definitive solutions and the ability to meet performance measures and financial expectations.
About the Author: Barbara Norris Coates is Grant Development Consultant from La Grange Highlands, Illinois. She specializes in higher education.