The Conundrums of Monitoring, Compliance, and Risk of Grant Funding
Written by: Erica Preston
Alright everyone – it’s time to tell a story to make some points. Hang in there with me…
Let’s say I’m going on a trip. A big trip. An impactful goal on my community is going to be accomplished once I get to Point B.
I tell my boss. “Oh, that’s great that you’re going to Point B. Can you take this brick with you? Don’t forget to fill in your timesheet.”
My boss tells the client. “She’s going to Point B? How exciting!”
My boss turns to me and asks, “Would it be too much to ask if you could take this book to my friend who lives there? And don’t forget that monthly report.”
Our client then tells one of her clients about my trip who replies, “If she’s taking the book, can she take pictures of all the stops she makes? This trip will definitely require a quarterly performance report.”
News travels to the clients’ funder. “Wow. She’s going to make it to Point B? That’s rare and amazing! We need to know at least ten more things about every day of this journey.”
Word continues to spread about my upcoming journey. In the meantime, I’m working out what tools and resources I need for my trip to Point B — a place not many people make it to. I’m getting excited about sharing the results of my adventure. My goal is to make it easier for the next person to make it from Point A to Point B, and maybe learn how to go beyond Point B to Point C.
My resources are limited. I only have a short period of time to make the trip on a budget that doesn’t even cover baggage fees. That’s right, one carry-on and one personal item!
A couple of days before I depart, I meet with my boss to review my project, schedule, and a coverage plan for when I’m out. I walk in to find several boxes of items from the clients, funders, and people I’ve never even heard of. Here’s our exchange…
My boss asks me, “So, you ready?”
I reply, “Yes, here’s what I’ve got outlined.” We discuss the project and schedule and budget.
My boss says, “This sounds great. However, we do have a few additional requests for you.” My boss goes over all the reporting and documentation that I’ll have to do.
I respond, “This additional work will take considerably more time. I don’t know if I can keep to the schedule. And, if I don’t stick to the schedule, I may not even make it to Point B.”
Unsympathetic, my boss replies, “You’re just going to have to figure it out. All these requirements are allowable under our terms and conditions. By the way, you will also need to take these items with you.”
I look over at the boxes and voice my concerns to my boss, “Did you ask for any more money? The budget doesn’t cover baggage fees. Plus, the list of new reporting requirements and the camera means I’m going to have to lug a laptop with me instead of just my phone. You do realize that I have to bring my medicine, toothbrush, and perhaps a few changes of clothes, right? I’m not a robot. What will happen if I don’t make it to Point B?”
Hope you’ve enjoyed this little story which illustrates how I’ve been wrapping my head around some of the conundrums of monitoring, compliance, and risk. Don’t get me wrong, I believe in compliance. I want to know that my grant dollars are being spent in accordance with the rules. That said, something has to give in terms of doing ev-ry-thing.
This means that when the grants community says that risk-based approaches to monitoring are best, we need to figure out how to stop the trickle down of requirements. In my story, I’m left with so many requirements and boxes to carry that I have doubts that I’m ever going to get to Point B.
That’s because everyone in the funding chain passed-through the requirements and baggage without any awareness that a trade-off will have to be made. We need to get to the point where compliance is so easy that it doesn’t create more burdens — burdens that will that prevent the accomplishment of the grant-funded project. More likely, we need to accept the risk that maybe not all compliance is absolutely necessary for the journey to finish. How many Point B’s haven’t been reached because a grant recipient hasn’t been able to manage the compliance requirements?
It also means that there is a paradox with the drive to cleaner, more complete data from all things grants. Most of the data that we can, or already, collect is centered around compliance information. A grants officer may make an informed, reasonable decision to not collect a piece of compliance information to help support the performance of the grant-funded activity. But is that grants officer going to be supported in that decision by their agency leaders, who are being held accountable by Congress, OMB, GAO, and their IG? Not likely.
Noncompliance is bad news because the risk for most government officials has no reward. Ergo, collecting everything becomes necessary all the way down the grant funding chain to the beneficiary.
Those of you who are in the middle of this — the people who monitor grants at the Federal and pass-through levels — can make a start. You can build monitoring plans that use different risk factors and then follow them. This will allow you and your teams to document decisions and observations when a compliance factor wasn’t met, why, and if it caused risk to the project. The raw data in the system may indicate that there’s a problem. But you can at least create a story that provides context for that grant and program.
These are the stories that are going to illustrate that we can let some of the compliance go. And if that happens, maybe we can achieve the vision of performance over compliance.
