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Grants Guide 2009, Part 2 of 7
Evaluation benefits both you and the grantor. You see your outcomes and measurable results, and your grantor sees how you accomplished your work, using the processes you chose.
Evaluation uses your objectives and methods to determine what works, what does not work and where changes need to be made. Through evaluation, you give attention to the project, but you also obtain evaluative feedback from such people as participants, instructors, supervisors, and others involved in the project, based on the objectives for them and the work or input they have done. Be careful, though, about receiving subjective or biased evaluations. Use the objectives and methods of the project to make a neutral evaluation of tangible outcomes that relate to the project.
Your grant may be the type that already has a built-in evaluation framework in which you gather certain information on a specific timeline, then submit the evaluation in a specified form. Following such a format is not only required, but also influences your future chances at grants with that grantor because past performance is usually tied to future grants.
The evaluation states who does the evaluating, how it is done, the criteria used, why those criteria measure the project, how the data is analyzed, and how the results influence changes or improvements in the project. The RFPs usually have specific requirements related to evaluation so be sure to meet the requirements. In some cases, you can use the help of someone outside your organization, such as an evaluator from a local university, who has the expertise to look at your project closely and honestly. Contract for those services and request money in your proposal for the person’s work. Doing this in your proposal shows you are concerned about the meeting objectives and doing so in an impartial manner. Your grantor may have advice about evaluators. Ask if having an outside evaluator is critical to getting the award.
There are some projects that will not need outside evaluation. These use assessment tools or tests to show the project’s progress. Check Google™ for appropriate testing materials and evaluations from suppliers. For some projects, your grantor may even allow a “do-it-yourself” evaluation.
Evaluations should be impersonal and objective, incorporating such things as pre- and post-testing, surveys, questionnaires, activity logs, case studies, and performance reports. But you can include the subjective side of evaluation in the form of photos, letters of commendation, testimonials, anecdotal stories, etc. because these describe the progress of people involved in the project.
Implement evaluation from the outset of your project. It shows how things were at the beginning and how they improved. Evaluation is not just for the “end” of the project because it is used to make changes in methods or processes as you go along.
Performance management is essential. You have been given money to solve a problem or create a solution. Your grantor wants to know that the money has been used wisely and correctly. The public, in the form of taxpayers or donors to private grantors, wants accountability and transparency. Your agency is really not the beneficiary of a grant, but the caretaker of the money. The grant is to accomplish a change, improve something, or solve a problem. There are government executives, law enforcement executives, project directors, grant administrators, program managers, program specialists, comptrollers, and inspector general personnel making sure that you follow the rules so that waste, fraud and abuse do not occur.
Giving wise advice on the subject of grant management is Wendi Gephart, a grants instructor with Grant Writing USA (www.grantwritingusa.com, (800) 814-8191), the nation’s prime provider of grant writing and grant management seminars.
Gephart says grant management focuses on three major areas: good and thorough communicating, documenting everything, and being a good steward.
All of this begins with the grant file. The file is a continuing process that includes a complete record of everything associated with the grant: the RFPs, the proposal and pre-submission forms, the award letter, the grant’s timeline for milestones and benchmarks, deadlines, cost principles, internal and external reports, inventories of supplies and equipment, personnel activities and responsibilities, job descriptions, time cards, vacation time schedules, volunteer time and its value, payroll information, correspondence, and the budget. Keep and maintain your grant file so that everything is within easy access, says Gephart. Even if you don’t land the particular grant you are seeking, the grant file can be beneficial the next time you start seeking another grant.
Even before your grant is awarded, start involving key players in your grant, said Gephart. Have the information technology department ready for such things as ordering computers and software. Have the facilities manager ready for offices, phones, desks and chairs. Have the human relations department ready for advertising for and hiring new positions. Have the business office ready to draw down on the cash needed to administer the impending grant. Get everyone to sign off that they agree to the objectives and plan of the grant, given its impending budget and resources. Anticipate any potential conflicts. Check potential sub-grantees or sub-recipients on www.epls.gov to see if they are excluded from doing business with the federal government. “Trust, but verify!” Gephart said. The website is maintained by the General Services Administra-tion to name parties prohibited from receiving federal contracts, certain subcontracts, or financial or non-financial assistance or benefits. If your project involves “partnering” with any others, research those “partners” on this website before working with them.
Gephart says grant managers must follow the law, the regulations and the grant agreement terms and conditions. She adds that it is far easier to negotiate with the grantor BEFORE anything is signed. If there are any conflicts or items that must be negotiated, contact the grant program officer and discuss how to work out the conflict.
Federal grants require following the specific Administrative Rules applicable such as 2 Code of federal Regulations (CFR) Part 215 for educational institutions and non-profit organizations, and A-102 for state and local government and Indian tribes. These provide the structure within which the federal grant must operate, says Gephart. Non-compliance can result in such penalties as temporary withholding of cash payments from the awarding agency, disallowing all or part of the cost of the action not in compliance, wholly or partially suspending the award, terminating the award, or even criminal liability in cases of fraud. The agency might also be debarred from any further grants. Such debarments are listed at www.epls.gov, which is the Excluded Parties List System, noting who is debarred from doing business with the federal government, including grants.
Cost principles for your federal grant can be found at 2 CFR Part 220 for educational institutions, 2 CFR Part 225 for state and local government and Indian tribes; and 2 CFR Part 230 for non-profit organizations. Gephart says remember the acronym “AARN” as your guide to cost principles: Allowable, Allocable, Reasonable, and Necessary. That means, allowable cost under the cost principles, allocable to the grant, reasonable to the prudent person, and necessary to accomplish the grant’s objectives. Be specific, detailing exactly what is to be purchased, why, and its function in the project. There might be a limit on the amount recoverable as indirect cost. Be sure to pass all the “AARN” principles, says Gephart.
Be clear on the differences between direct costs and indirect costs, she advises. Direct costs are usually those that are specific to a particular final cost objective such as compensation of employees, costs of materials, capital expenditures, travel expenses, or other items directly related to the grant’s project. Indirect costs might include something that benefits more than one cost objective. They usually cannot be identified with a particular final cost objective.
According to Gephart, grant management requires monitoring for conflicts of interest among participants, oversight, having different people do orders and payments for those orders, and including at least one other person in the chain between ordering and paying for something so that the opportunity for misuse of funds or fraud is lessened.
Establish who does what and how accountability is maintained. Evaluate and control all activities and keep internal and external reports timely and thorough. She likens internal control to a “culture” rather than an “annual project activity.” Everyone must be responsible for compliance and the procedures involved in being responsible and good stewards of the grant money.
Obstacles to compliance include not having enough resources in personnel or not sharing responsibilities, having poorly defined roles and responsibilities, having poor supervision, not doing checks and balances, and treating the money as though it’s “free” or “easy” money. “It’s money you have to work to keep,” Gephart says. Do monitoring and verifications regularly to help assure grant compliance. As requirements change or as updates occur, review your grant rules and be sure everything is in compliance. Be sure your resources are adequate. Define roles and responsibilities. Have a sound management system. Reinforce the importance of grant compliance and internal controls. Non-compliance can range from fraud, and internal non-compliance (ignoring the rules because they “don’t apply here”), to substandard performance (incompetence), unintentional non-compliance, and detrimental reliance on other information or sources. Regardless of the level of non-compliance, though, responsibility must be taken for the consequences. Avoid the problem by having a sound management system, advises Gephart.
Know how long you are required to maintain grant-related records and documents pertinent to your grant. Know how often you are required to report on the project. Keep records and documentation in your grant file and monitor any sub-recipients for the same information and reports so that all your audit requirements are met, says Gephart. Create work plans and timetables for all the key participants to track responsibilities and keep everyone on schedule. Reminders of due dates and reports are necessary on each work plan. Don’t forget to track such things as non-salaried personnel time and effort that occurs during the grant project, having the non-salaried person and the supervisor sign and date the report. Their monthly time sheets are also a part of your grant file and your reports. And, besides the personnel activity, keep track of supply inventory so that there are timely expenditures of grant funds and so that compliance and programming elements are coordinated. Says Gephart, “Even if the grantor doesn’t require quarterly reporting, all grant-funded projects should report internally, on a quarterly basis, to gauge progress and maintain budgetary control.” For example, she adds, “federal regulations stipulate than an inventory be taken every two years. But why wait if you can account for it easily every time a purchase is made, and it is accounted for quarterly?”
Maintaining good documentation in your grant file throughout the grant will make closing and auditing the grant a snap. The audits required must be prepared according to the form and timeline required by your grantor, and must show the prudent use of the money. That “prudence” applies to the fiscal control and fund accounting procedures used, in accord with the activities that conform to the goals and requirements of your project. Gephart adds that the American Recovery and Reinvestment Act of 2009 will see more public dissemination of reports on funds, including grants, so be sure to purge any Social Security numbers, names or other personal information from reports and audits before they are posted to websites that will be accessible to anyone. Discuss this with your grantor’s contact to be sure you follow any special requirements.
At the end of the grant, keep all records for the time required by your grant. Some federal grants require keeping everything for three years unless there has been an audit or another requirement applies. Determine what applies to your grant. Be sure to follow what might be applicable about returning any equipment purchased during the grant.
The federal Funding Accountability and Transparency Act of 2006 requires the establishing of a searchable awards website listing the name of the entity receiving the award, the award amount, the transaction type, the CFDA number, program source, location of the entity and location of the performance, and other relevant information—with all data required to be available within 30 days of the award. Progress is being made on this requirement, but it is possible that some information may take to 2010, particularly if a project involves subcontractors or sub-grantees, Gephart said.
Also new in the federal grant management world is the move toward standardization of progress reports. The Performance Progress Report SF-PPR designates the awarding agency, the recipient, the project or grant period, performance narrative, and other information. Likewise, the federal Financial Report is replacing many other forms previously associated with managing federal grants.
“Surprise is bad! Communication good!” says Gephart. Remember the keys to good grant management: communicate, document everything, and be a good steward of the grant money.
YOUR GRANT RESEARCH GUIDE
By law, this is designated to be the main clearinghouse for all federal grants. The reality is that it has taken a bit longer than anticipated to get all those grants into this website, but progress has been fairly quick. This should be your first choice when beginning your research for a federal grant. Billions of dollars of grant money appear on this website. Use the website to set your preferences and determine your eligibility for grants, and download the resources and helps for your research in funding, managing and monitoring the availability of future grants. There are links to state, territory and outlying area websites, too.
A website has been established to track much of the information about The American Recovery and Reinvestment Act of 2009 (ARRA), including money available under the law. At present, about $4 billion is designated for crime control and improvements in criminal justice. In keeping with the goal of the ARRA, the projects funded under it are supposed to create or preserve jobs, reduce pollution, stimulate the economy and be “transparent” to the public so that taxpayers can see exactly where their money is going and how it is being spent. The website cross-references by category, geographical area and federal agency (such as Department of Justice or Department of Homeland Security). Information is provided about funds already paid for projects, and what monies are still available. Among the projects that can be funded with ARRA funds are those of law enforcement, prosecution and court programs, corrections, drug treatment, technology and victim/witness programs. The website also has a link to subscribe to updates—a wise choice given that the ARRA is relatively new and that changes and updates will probably be many as the law evolves. Because the website changes often, it is wise to check it regularly to determine what funds become available, and what is being updated or honed. At press time, 20 states, territories and the District of Columbia have received ARRA funds for projects that will maintain or increase public safety.
The Department of Homeland Security (DHS) has billions of dollars available for grants, particularly as they apply to projects for preparedness, response, equipment, training, exercises, and administration. The areas for programs include the state Homeland Security Program, Urban Areas Security Initiative, Metropolitan Medical Response System, Operation Stonegarden (U.S. land borders), the Citizen Corps Program, and others. There are links to the FEMA-directed projects for port security, critical infrastructure protection, regional/local mass transit system security, and equipment and training for first responders. On this website, you can learn your state’s Homeland Security contacts, and information about Homeland Security grants.
Most of the federal Emergency Management Agency’s focus is on disaster-specific grants, but other grant opportunities exist, too, for such matters as environmental and historical preservation, hazard-related grants, non-disaster programs, and repetitive flood claims programs. About $3 billion is being offered in 2009 for preparedness program grants.
The Transportation Security Administration focuses most of its grants on projects to enhance safety and security of intercity buses, transit systems, ferry systems, mass transit, commercial trucking, freight railroad, and other forms of the nation’s transportation. The website recently underwent some changes to make it more interactive.
The Catalog of federal Domestic Assistance has been a strong database for federal grant programs available to state and local governments, tribal governments, domestic public and quasi-public groups, and private profit and non-profit groups and individuals. But with the growth of www.grants.gov, it is probable that the website will not be as widely used as it once was. It is being improved and may still include a user’s guide, search features, links to other federal websites, and tips about available grant assistance such as how to write grant proposals. It has an archive of 2008 grant activity.
This website will benefit you if your project relates to safe transportation of hazardous materials. Funds available can benefit state, territorial, tribal or local hazmat emergency planning and training. There are also links for conferences, training and meetings offered by the US Department of Transportation. Current and historical grants are archived for easy reference.
The U.S. Department of Agriculture has a Rural Development Program to fund projects in rural areas in facilities, equipment, housing, utilities and business. There are also links to loans and grants, cooperative grants, community facilities loans and grants, telecommunications loans and grants, and community development programs, all as they relate to rural settings and rural development.
The Office of Justice Programs in the U.S. Department of Justice has grant money for a variety of projects in training, crime prevention and emergency management. There are also links to past projects funding through the OJP—something of value to you if you want to see trends and how to prepare a successful project and application. New to the website are links specifically for the American Recovery and Reinvestment Act of 2009, and its grant opportunities.
This White House website for the Office of National Drug Control Policy describes an overview of funding opportunities for law enforcement training and technical assistance, equipment procurement and other programs especially targeted to reduction of drug abuse. Information on workshops and materials is also included.
The U.S. Government Printing Office disseminates information from the legislative, executive and judicial branches of the government, and offers a guide to those branches. The website has a link to a list of official federal resources that can be useful when you need background information about goals and purposes of federal agencies or when you need to check such references as the Congressional Record, Congressional bills, the Code of federal Regulations, conference committee reports, the Federal Register and other government publications.
This website has an easy-to-navigate, alphabetical list of government benefits, grants and financial aid. It is designed particularly for the general public, but it can be valuable in grant research and learning the nature of the assistance available for a project.
The U.S. Department of Housing and Urban Development website has a grants page with information about current grant opportunities. It links to www.grants.gov for applications for the grants.
The Health Resources and Services Administration of the U.S. Department of Health and Human Services website has a grant policy statement, current and archived grant opportunities, and a form for e-mail updates of new grants through the HRSA.
Home to the Internet presence of the Justice Technology Information Network, this website is valuable for technology information, and search and topic lists for grants and their links in equipment, testing, evaluation and technology improvements.
The Library of Congress is a concise reference tool for not only federal grant research and information, but also general resources and information.
The National Public Safety Telecommunications Council (NPSTC) is a federation of organizations for public safety and interoperability of communications. The website has information on broadband, software-defined radio, re-banding, and technical education.
This free resource guide for federal and other government grants and loans provides information by name, subject, applicant type or agency type. It also has tips for successful grant writing.
Primarily for non-profit organizations, this website can be helpful if your project will see your agency partnering with a non-profit. The website also has helps for locating donated and discounted technology products.
The Public Safety Foundation of America provides grants for such public safety functions as planning, equipment procurement, and training.
This University of California, Los Angeles Office of Contract and Grant Administration website has an alphabetical list of links to foundations and organizations that provide project grants.
This website focuses on potential private grantors and also includes information about in-person grant writing courses and seminars, and webinars. It also has an archive of previous courses and seminars.
This website of the Hawthorn Institute has information about available grants and the process of successfully applying for grants. While much of the information centers on Missouri and the region around it, the website has value beyond that geographic area in providing information about upcoming grant writing and grant management seminars.
This website is the Justice Information Sharing Practitioners’ Network, which seeks to enhance education of those serving in criminal justice and public safety. The organization lists seminars and webinars, some of which relate to grant writing.
The National White Collar Crime Center focuses on prevention, investigation and prosecution of high-tech crime. Its website lists seminars, some of which are grants related.
This company is a leader in courses about grant writing and grant management. The website also contains information about how to host one of their grant seminars.
Published in Law and Order, Sep 2009
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