Grant policies should not sit untouched until an audit or a regulatory change forces an update. This article explains when to review your written procedures, what events should trigger revisions, and how regular policy reviews help strengthen compliance before issues arise.
After several weeks of discussing the proposed Uniform Guidance changes, one question keeps coming up: "Should we start updating our policies now?" The answer is a little more nuanced than a simple yes or no.
If the proposed regulations are not yet final, you probably do not want to rewrite every policy in your manual. At the same time, waiting until the final rule is issued before looking at your policies is also a missed opportunity.
Policy reviews are about much more than regulatory updates. They are about making sure your written procedures continue to reflect how your organization actually manages federal awards.
Many organizations only look at their grant policies after an audit finding, a monitoring visit, or a major staffing change. Ideally, policies should be reviewed on a regular schedule, even if nothing significant has changed.
An annual review gives your team the opportunity to confirm that procedures are still accurate, responsibilities are clearly assigned, references to regulations remain current, and documentation requirements still reflect daily practice. Regular reviews also make future updates much easier because you are making smaller adjustments over time instead of rewriting entire sections.
A scheduled annual review is a good foundation, but certain events should prompt an earlier review. Examples include:
- New or revised federal regulations
- Changes to your Notice of Award requirements
- New grant management software or financial systems
- Staff turnover affecting grant responsibilities
- Audit findings or monitoring recommendations
- Significant organizational restructuring
Any time your processes change, your written procedures should be evaluated to determine whether they still describe how work is actually being performed.
Start with accuracy. Ask yourself whether someone unfamiliar with the process could follow the written procedure successfully.
Next, verify that responsibilities are clearly assigned. Avoid language like "the organization will..." if it never explains who is responsible for completing the task. Then, review any citations to regulations, thresholds, or agency guidance to make sure they remain current.
Finally, compare the written procedure to what employees actually do. One of the most common compliance issues is not having poor policies. It is having policies that no longer match day to day operations.
The proposed 2026 Uniform Guidance updates are still moving through the rulemaking process, and that means there is time to prepare without making unnecessary changes too early.
Now is an excellent opportunity to identify outdated procedures, clarify responsibilities, strengthen documentation, and make notes about areas that may need revisions once the final rule is published. Organizations that review policies regularly tend to spend less time reacting to changes because they already have a structured process for keeping documentation current.
