January is a natural reset point for many organizations. Budgets are finalized, new grants may be starting, staff roles shift, and reporting cycles from the prior year are closing out. That makes it an ideal time to step back and confirm that grant policies and procedures still reflect how work is actually being done.
Reviewing grant documentation early in the year helps identify misalignment before it becomes a compliance issue. It’s far easier to address outdated language or unclear steps now than during an audit, monitoring review, or period of increased grant activity.
When procedures evolve without corresponding updates, organizations may still be doing good work—but lack the documentation to support it. Auditors don’t just assess outcomes; they look for consistency between written policies and actual practice. January provides a practical checkpoint to realign the two.
Policies establish expectations and define how an organization adheres to federal grant requirements, including those in 2 CFR Part 200. Procedures, on the other hand, describe the specific steps staff follow to carry out those expectations.
When policies and procedures are reviewed in isolation, inconsistencies often emerge. A policy may require a control that no longer fits the workflow, or procedures may rely on systems or approvals that have changed over time. When those gaps exist, auditors are more likely to flag findings—even when staff are acting in good faith.
Reviewing policies and procedures together helps ensure clarity, reinforces accountability, and reduces confusion for staff responsible for day-to-day grant administration.
A policy review does not need to be a full rewrite of the grant manual. The most effective reviews focus on areas that carry higher compliance risk or receive consistent audit attention, such as:
- Financial management and cash handling
- Procurement and vendor selection
- Subrecipient monitoring activities
- Record retention and documentation practices
Clear, accurate policies support staff and make compliance easier—not harder—especially as new grants, reporting deadlines, and operational demands increase throughout the year.
Small, targeted updates in these areas can significantly reduce risk while keeping documentation usable and relevant.
Even when policies and procedures remain appropriate, documenting that a review occurred is important. A short memo, checklist, or sign-off record demonstrates active oversight and shows that grant documentation is being intentionally maintained.
This type of documentation reinforces compliance expectations and provides valuable context if questions arise later in the year.
Starting the year with a focused policy and procedure review sets a strong foundation for consistent grant administration—and helps teams move forward with clarity and confidence.
