How Technical Assistance Strengthens Grant Programs

Technical Assistance strengthens grant programs by transforming oversight from a reactive, punitive process into a proactive partnership that bridges the gap between complex regulatory compliance and high-impact programmatic success. Providing Technical Assistance (TA) has a rich and important history in the monitoring of grant-funded programs. When the Uniform Guidance—the overarching set of regulations governing federally funded grants—was adopted in 2014, it made TA mandatory. However, following the surge of grant funding during the COVID-19 pandemic, the regulations were changed to recommend TA rather than mandating it.

Defining Technical Assistance

While the Uniform Guidance does not define TA, the Government Accountability Office (GAO) does. The GAO defines Technical Assistance as programs, activities, and services provided by federal agencies (and presumably pass-through agencies as well) to strengthen the capacity of grant recipients and to improve the performance of grant functions.

According to the GAO, TA is designed to improve:

• grant outcomes

• grant management

• grantee compliance

• project monitoring

• project evaluation, and

• interactions with stakeholders.

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The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards—known as the Uniform Guidance—is a primary reference for TA as it applies to federally funded grant programs (and in state-funded programs where the language has been adopted by state governments, as in Illinois). That reference does not include a formal definition, nor is one provided elsewhere in 2 CFR Part 200. Additionally, the reference appears in the section covering Sub-recipient Monitoring, making it easy to conflate the two practices (rather than seeing them as complementary parts of an ongoing oversight process).

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What Technical Assistance Looks Like

At the Vander Weele Group, we believe that the best TA is informed by robust monitoring reviews. “Effective monitoring identifies what’s missing in a system, program, or individual practice; effective Technical Assistance teaches grantees and service providers how to address those problems,” explains the Vander Weele Group’s Jessica Coonrod, who manages the Illinois Early Intervention Technical Assistance and Monitoring Program (EITAM). (The program supports the Illinois Early Intervention Program in serving more than 25,000 children under age three with developmental delays or disabilities annually.

The form that effective TA takes can vary: “Sometimes it means providing instructions on practical ways to implement a policy. Other times, it’s about encouraging the use of best practices that may not be mandatory but are proven to strengthen performance.” Coonrod explains that when her EITAM Monitors engage in TA conversations, they help EI service providers, agencies, and Child and Family Connections offices align their practices with both EI standards and the goals of the program.

These two aspects of TA—addressing compliance issues and promoting best practices—are the foundation of a good TA program. But what does this look like in practice? While the way in which TA is provided differs between programs, the essential principles of effective TA remain the same whether applied to grantees, subgrantees, or service providers undergoing fiscal or programmatic monitoring reviews.

Addressing Non-Compliance

1. Ground Findings in Compliance Standards The first step to addressing non-compliance is to identify findings of non-compliance as measured against legal, regulatory, and policy standards and provide evidence supporting those findings. As we’ve discussed in previous articles, there’s a difference between not implementing a best practice versus failing to meet a legal or regulatory requirement. Issuing a finding for the former would be arbitrary and unfair to grantees or service providers because a best practice is not mandatory; the latter is objective and provides a concrete starting point for correcting the problem. To ensure impartiality, monitors should cite the documented standard a grantee or provider has failed to meet and explain in detail the incident of non-compliance. This should include what files or field conditions were used to make the determination.
   

2. Discover the Root Cause of Non-Compliance To help grantees and service providers become compliant, it is important to first establish what factors are causing them to be non-compliant. In many cases, non-compliance isn’t deliberate or malicious. Frequently, it’s rooted in a lack of knowledge or factors outside their control. Using the EITAM as an example, Monitor Charlotte McAneney says, “The devil is in the details. Many providers or agencies have a handle on the main idea behind a policy or procedure but fail to implement the more intricate pieces. Sometimes, it stems from not fully understanding the intention behind a requirement. Other times, it’s because rule changes haven’t been effectively communicated.”

   
   

   Confusion over rules changes has been especially prevalent since the start of the COVID-19 pandemic, where, for example, policies regarding shifts to offsite service delivery practices caused confusion among agencies and service providers. “For example, we still receive regular questions about live video visits and the use of phone consultations to support families,” says Coonrod. “These practices were born out of the pandemic but are currently still available, so we’ve had to fold them into the guidance we provide.”
   

3. Provide Targeted Resources and Collaborative Feedback

   
   

   When grantees and providers have the power to address the factors contributing to non-compliance, skilled TA practitioners offer a variety of resources and ideas for addressing the problem. Such resources may include detailed instructions, templates, or guidance documents that instruct a grantee or provider on how to achieve compliance. For instance, at the Vander Weele Group, when appropriate to do so, if we identify a finding for which a grantee does not have proper documentation, we might suggest other forms of documentation they can submit to substantiate or remove a questionable cost. For example, in fiscal monitoring, sometimes grantees do not have adequate Time and Effort Documentation but can substantiate the expenditure with payroll and time sheet documentation. Targeted TA allows the monitors to substantiate the cost while removing the burden on the grantee to have to refund the state due to inadequate documentation. While the questioned cost is removed, the finding and subsequent corrective action plan remain to ensure that the grantee updates their policies and procedures to mitigate future documentation findings. We also inform grantees of the areas of non-compliance in advance of a final monitoring report so that they have time to address areas of concern. Another example of resources that can help grant recipients become compliant are guidance documents indicating which expenditures are allowable and which are not according to the requirements of the grant, and/or what type of documentation is required to support expenditures. This can be particularly helpful in large construction projects, for example, where contractors and subcontractors may not be as familiar with the requirements for tracking expenditures from grant funds.

   
   

   Addressing systemic causes is more difficult, but depending on the structure of the program, it may still be possible. Certain programs allow TA practitioners to share their observations—and sometimes, as in Illinois’s Early Intervention Program, direct feedback from providers—with state agencies and governing bodies. “If someone tells us that a certain policy is worded in a confusing manner, or there are obstacles to implementation, we can communicate that to the state. It gives providers a chance to be heard and to shape requirements collaboratively,” explains Coonrod.

Addressing Best Practices

Grantees and providers should only face non-compliance findings when they violate official, documented standards; however, providing Technical Assistance (TA) that incorporates best practices is highly valuable. Some program officers prefer TA to be consigned only to compliance, while others encourage discussions with providers and grantees about obstacles to accomplishing the goals for which the program or grant was intended, along with possible solutions. This type of TA, while not related to compliance findings in monitoring reviews, is part of a two-way conversation that can drastically improve program management practices, performance, and outcomes.

Addressing best practices is frequently most valuable to small agencies, new service providers, or first-time grantees, especially those receiving an influx of new funds. Offering guidance on capacity-building helps them get off on the right foot and promotes long-term success, particularly in the organizations closest to the problems the grant programs are designed to solve.

Ask the Experts: 4 Tips for Providing Top Tier Technical Assistance

Whether you’re looking into TA for the first time or working to improve existing services, there are ways to maximize benefits at every level of the grant program. We asked experts across the Vander Weele Group to share their strategies for offering high quality TA.

1. Define TA Clearly and Collaboratively Among Stakeholders EITAM Monitor Charlotte McAneney advises, “Consider what you hope to achieve, and use that as your starting point to create consensus. Ensure that all parties who will be impacted by or involved in the TA process have a hand in structuring it. Finally, communicate clearly and consistently so that everyone, including leadership, is on the same page.”
   

2. Explain the Rules, Don’t Interpret Them One of the biggest potential pitfalls of TA is presenting your interpretation of a policy or rule as fact. McAneney says, “Providing good Technical Assistance means not interpreting any policy or procedure in your own voice. It’s especially tempting when there’s something you perceive to be common sense that isn’t in the written document, but remember that even a small inference can have a snowball effect.” It is very important to clearly distinguish between what a policy or procedure actually says—a mandatory legal citation—and an opinion or helpful recommendation.
   

3. Include Field Experts on your Technical Assistance Team

   While the Uniform Guidance isn’t prescriptive concerning what expertise a TA provider needs, the Vander Weele Group firmly believes in engaging people with firsthand experience of the systems in which they’re working. “For example,” Coonrod says, “our team is comprised of professionals that have held a variety of roles in the EI system: parents of children who have used EI services, service coordinators and CFC managers, EI direct service and evaluation providers, even administrators of Early Childhood Programs. The breadth and depth of their experience provides us with a comprehensive understanding of the many integral applications of policy and their impacts at all levels of the system.” Having such a team ensures TA is grounded in addressing real-world challenges.
   

4. Approach Providers with Empathy

   As a TA provider, it is most helpful to approach each practitioner as if their practice were your own. Poor past experiences with auditors, monitors, and TA providers can leave a bad taste in a practitioner’s mouth. Early Childhood Education Monitoring Program Manager Laura Abbruzzese observes, “It can be uncomfortable, intimidating, even invasive to have someone from outside your organization or practice, who may not know you or your work personally, checking to see if all your I’s are dotted and your T’s are crossed. But it can also be an incredible opportunity—a chance to gather meaningful information that highlights successes and effective strategies and captures areas for improvement.” Framing TA as an opportunity for providers and grantees to improve their practices with support changes the dynamic from adversarial to collaborative.

Conclusion

TA is a powerful tool for enhancing all levels of a grant program. Vander Weele Group President and CEO Maribeth Vander Weele says, “Technical Assistance is vital to helping grant programs thrive. It’s one of the few proactive and non-punitive tools we have for ensuring these programs continuously improve.” Integrating effective TA into grants monitoring transforms oversight from a punitive exercise into a collaborative partnership that empowers grants programs to achieve their missions. Contact the Vander Weele Group today to partner with our team of practitioners for your organization’s technical assistance and training needs.