At the Vander Weele Group, we believe that Federal grants oversight can and should go beyond “check the box” compliance. While there’s no arguing that compliance is important, it doesn’t exist for its own sake; the point is to ensure that grant funds are used appropriately and effectively to improve lives. To truly understand whether a grant program is successful, you need to ask whether its goals are being achieved and what is (or isn’t) contributing to meeting those objectives.
We’ve talked previously about what this approach to grants oversight—which we call Meaningful Monitoring—looks like and how you can implement it. In this article, we take a look at how Meaningful Monitoring impacts a critical but frequently overlooked aspect of a program’s operations: stakeholder morale.
Setting the Stage: Stakeholder Stress
Imagine being the leader of a non-profit organization and receiving a large Federal or state grant award. Excitement abounds; with this new stream of funding, you can meet so many needs and serve communities in life-changing ways. You race to get up and running: building your operations plan, hiring employees, and announcing the program to the public.
Time passes. Challenges arise. Thanks to your expertise—whether in organizational leadership or the services your non-profit offers—that isn’t a problem. What is a problem is the fine print of your grant agreement: Federal and state requirements that are referenced, but never explained, and legal citations without accompanying guidance or training resources. Just as you realize how much you don’t know, you receive notice that the agency that awarded you the grant funds is sending in Monitors.
Now, let’s switch roles. This time, you’re the program manager for the pass-through agency responsible for the grants. You’re responsible for designing or soliciting the development of a monitoring program. The possibilities for what oversight looks like are endless. What’s the best way to ensure compliance, support grantee goals, and confirm the objectives of the grant program are being achieved?
Enter: Meaningful Monitoring. This unique approach to oversight not only enhances program compliance and performance, but improves stakeholder morale by:
fostering robust communication between pass-through entities, subrecipients, and grantees;
capturing front-line intelligence that reveals hidden obstacles to success;
highlighting effective measures to achieve program goals; and
promoting training, technical assistance, and non-punitive plans for improvement.
Four Meaningful Monitoring Tactics that Boost Stakeholder Morale
1. Provide ongoing compliance and monitoring-related training to subrecipients and grantees.
Fear of the unknown is a familiar stressor, but one that’s easily remedied. Laying out expectations clearly and arming stakeholders with the knowledge they need to be successful builds trust and confidence, especially for new grantees or subrecipients.
We recommend offering a series of compliance trainings on important topics such as reporting requirements, procurement rules, allowable expense categories, internal controls, reporting, and privacy and data protection requirements. Additionally, outline the monitoring review process well in advance; provide a step-by-step roadmap (with dates and timeframes, when possible) as well as any meeting agendas, questions to be asked, and document requests. Finally, consider setting up a resource library that subrecipients and grantees can reference as needed and providing templates that streamline information gathering.
2. Ask meaningful questions that not only align with compliance requirements, but also the goals of the grant program.
It’s easy to ask a yes or no question, such as, “Do you have a documented internal controls policy?” (and you should). It’s much more meaningful to ask an open-ended question, such as, “How effectively do your internal controls address the requirements laid out in Federal regulations? What concerns do you have about current internal controls? Have you identified any gaps that could compromise the program’s integrity?”
This approach opens the door for grantees and subrecipients to share information that might not otherwise have come to light, including systemic barriers to success. It demonstrates that Monitors aren’t detached fault-finders looking for ways to punish well-meaning grant recipients; they’re there to provide support for achieving program goals and they care about the organizations they’re reviewing and the people served by the grant program. It also helps shape grantee behavior: what you measure is what they’ll focus on, so make sure every standard is set with an eye towards serving the grant’s purpose or preventing fraud.
3. Document and share subrecipient/grantee successes and feedback.
Looking for what’s wrong can often blind us to what’s right and drag morale down in the process. When conducting monitoring reviews, don’t only hunt for non-compliance or suboptimal performance—find out what’s working well and call attention to it. In addition to providing a more balanced picture of a program’s operations and bolstering employees’ confidence, you can use what you learn to help other subrecipients and grantees improve their practices.
Just as Monitors provide program feedback, we encourage them to solicit it, particularly when it comes to policies, program management, and the monitoring process itself. Policy makers and program offices sometimes make decisions in a vacuum, and uniformed mandates from above can create more problems than they solve. Ask grantees about the impacts of specific policies, and the real-world circumstances that make them difficult to implement, or suggest a need to revise them. Find out what support the program office can offer to make grantees’ jobs easier and improve compliance and performance. Finally, survey them about their monitoring review experience and take note of suggestions or requests that can improve the process in the future.
4. Clearly differentiate between requirements and best practices; issue any findings accordingly.
As we’ve discussed in past articles, there’s a big difference between a regulatory requirement and a best practice: only one is a legitimate basis for a monitoring finding. While Monitors can and should share best practices with grantees and subrecipients, ideally through formal technical assistance (barring any restrictions laid out by the pass-through agency), Monitors should never treat best practices as mandatory. All monitoring findings should be rooted in specific legal requirements, regulations, or the terms and conditions of the grant award. In essence, if you can’t provide a citation, you don’t have grounds for a formal finding.
Unless the agency responsible for the funding says otherwise, you can always include a section in your monitoring report that documents any concerns which don’t merit a finding, along with suggested steps for addressing them. Taking a “just the facts” approach to monitoring findings ensures that the standards are clear and objective. It also increases grantees’ confidence in the fairness of the process and allows them to effectively prioritize any corrective actions, making the best use of their limited time and resources.
Overwhelmed? We can help!
The Vander Weele Group provides turn-key oversight solutions for federal and state grant programs. We specialize in monitoring large-scale programs nationwide, combining grants monitoring expertise with industry-specific program experience. The firm offers traditional fiscal and compliance reviews, programmatic monitoring, risk assessments, internal control reviews, data analytics to detect fraud, best practice recommendations, and technical assistance for grantees.
To consult a grants oversight expert, call 773-929-3030 or email us at info@vanderweelegroup.com.
For more grants monitoring, oversight, and technical assistance resources, visit our Resource Library.