Grant policies and administration processes are the written procedures that guide how federal funds are managed day to day. They help ensure consistency, accountability, and compliance with the internal control requirements outlined in 2 CFR Part 200.
Over time, however, these documented procedures can fall out of sync with how work is actually performed. Staff turnover, new systems, and operational changes often happen faster than policy manuals are updated. January is an ideal time to confirm that grant policies and administrative processes still reflect current practices—and continue to support effective internal controls.
Most policy-related findings aren’t the result of poor oversight. More often, they occur because operational processes evolve while written procedures remain unchanged.
Auditors frequently identify issues when:
- Staff follow a process that differs from what’s documented
- Procedures reference systems or roles that no longer exist
- Policies describe controls that are no longer practical or consistently applied
An annual review helps close that gap by ensuring grant administration processes align with how internal control requirements are being met in practice.
Rather than rewriting an entire grant policy manual, focus on administration processes that typically receive higher scrutiny under Uniform Guidance, including:
- Cash management procedures
Procurement and vendor selection processes
- Time and effort or payroll documentation workflows
- Subrecipient monitoring activities
If the documented steps in these areas no longer match current operations, updates should be prioritized to maintain compliance and reduce audit risk.
Even when policies and procedures remain appropriate, documenting that a review occurred is essential. A short memo, checklist, or sign-off record demonstrates active oversight and reinforces that grant administration processes are being intentionally maintained to support internal control compliance.
This documentation can be just as important as the policies themselves when auditors evaluate how an organization manages federal awards.
