Lessons learned from a grant audit
Grant writing classes are a great way to learn how to create a competitive application. Most people who write grants have never attended a class and “don’t know what they don’t know”. So those who have attended a class are typically more successful. Once you have submitted and been awarded a grant the next step in the learning curve is even more valuable than a grant writing class. Much can be learned in the grants management phase.
Every grant gets audited. Most are audited by the police department accountant who reviews the income and expenses and assures for the department that the grant was expended within the rules of the grant funder. The audited report of the grant then becomes part of the formal annual financial audit history of the department.
Sometimes the grant maker completes a full audit of the grants awarded to the community. The US Department of Justice Office of Inspector General Audit division has recently completed full scale programmatic audits of several awarded JAG Grants in several cities.
The results of these audit reports offer clarity from the side of the award agency and offer a window to the grant process which most police departments never get to see. The audits included a review of a city’s management of the JAG grant related to allowable costs, grant drawdown process, supplanting, grant expenditure process, matching costs compliance, property compliance, program income, program progress reports, reporting requirements, program income, financial and progress reports, program performance and accomplishments and monitoring of any sub-recipients.
The audit deficiencies found in the audit are all preventable issues if you develop your grant project, its budget, the outcomes, evaluation and management plan incompliance with the Federal Financial Guide and other core rules, policies and regulations concerning grants.
Financial and Administrative Management Deficits found:
• charged $2,513 in unallowable costs to grant funds
• spent $55,825 in grant funds on property items that the police department plans to keep in storage until needed;
• did not maintain property records on all accountable property items bought with DOJ funds and the available records did not indicate the source of the funds used to acquire the items;
• did not spend $56,376 in grant funds from the FYs 2006 and 2007 Byrne JAG grants before those grants expired; and
• did not monitor and had no procedures for monitoring sub-recipients to ensure they met or will meet the programmatic requirements of the grants;
Program Management Deficits found:
•did not meet or could not show that it met grant goals and objectives;
•did not monitor and had no procedures for monitoring sub-recipients to ensure they met or will meet the programmatic requirements of the grants
All of these deficits can be avoided by assuring the use of and understanding of the 2011 Financial Guide published by the Office of Justice. You must also understand and be able to apply the contents of the following documents in the development and management of your grant with the following documents: OMB Circulars, Other Requirements, Standard Forms & Instructions, and FFATA Subawards Reporting.
These documents apply to all Department of Justice law enforcement grants. You may also find these resources here. Complete JAG programmatic guidelines are available here.
The proactive police department and the educated grant writer will carefully review these documents PRIOR to creating a grant application and use the knowledge gained for the development of a grant, its program approach, goals and objectives and the budget. Allowable costs, property management, records management, sub-recipient management are addressed in these documents.
Grants are contracts which need to be managed fully to avoid deficits in a full federal audit. Currently there is an uptick in the number of audits being completed by the Department of Justice. Every police department with grants should assure that their grant writers, grant project managers, financial personnel and administration have copies of these resources and fully understand the requirements.
Grant audits review whether the department used the funds for costs which are allowable, supported, and in accordance with applicable laws, regulations, guidelines, and terms and conditions. An audit also reviews whether the department met or was meeting the goals outlined in the grant program and application as well as timely and accurate spending was accomplished. Areas tested within an audit may include internal financial controls, grant draw downs, supplanting, expenditures, property management, program income, financial and programmatic progress report compliance, program performance and accomplishments and monitoring of proper sub-recipients.
Audit deficits all have to be addressed once identified. This process can cost a department time, resources and sometimes cash reimbursements. Protect your department from this experience and assure that your department has a complete knowledge of grant requirements prior to submitting a grant application.
Once you have determined if your department is working to assure that all of these grant management requirements are being met, you may want to do an internal review to assure that the department’s policy and procedures comply with these requirements as well. Some departments may need to tweak these policies and procedures to assure grant compliance. For example, a department may want to make sure that property items bought with DOJ funds are systematically recorded to identify the grant and fund source for the purchase. A department may also want to explore their data collection and aggregation processes to assure grant reporting compliance for programmatic outcomes of the grants and to track their performance in reporting and filing all required documents. A review of all internal policy, procedures and management of grant sub-recipients which rigorously meet the DOJ requirements can help prevent audit deficits.
Prevention is the best practice for prevention of costly errors in grant management. Obtain and use the documents suggested in this article. So who was it who said “grants are free money?”