Refreshing Grant Policies and Administration Processes: What to Review Each Year
Jan 20
/
Rachel Werner
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.
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.
Why Grant Policies Drift Out of Alignment
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:
An annual review helps close that gap by ensuring grant administration processes align with how internal control requirements are being met in practice.
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.
Where to Focus Your Annual Review
Rather than rewriting an entire grant policy manual, focus on administration processes that typically receive higher scrutiny under Uniform Guidance, including:
If the documented steps in these areas no longer match current operations, updates should be prioritized to maintain compliance and reduce audit risk.
- 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.
Document the Review—Even If Nothing Changes
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.
This documentation can be just as important as the policies themselves when auditors evaluate how an organization manages federal awards.
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Martha A Moore, MPA, DTM, CNAP, has been working in the accounting industry for over 35 years. Over that time, she has worked in the Grants Management area for 20 years. She has recently received the Certified Nonprofit Accounting Professional (CNAP) credentials. Martha’s expertise in grants management field is in the post-award/closing/audit areas, while serving as an advisor to preaward budgeting and program narrative. Thanks to her many years in the accounting/grants management industry, Martha has the ability to zoom out and holistically see the big picture and how external funding can be crafted for effective and efficient use. She believes in team approach with both finance and program team at the table to ensure a clear and comprehensive award application, with the end goal being grant awards. Martha also has extensive experience in subaward management from a university to a local nonprofit organization. Martha is a public speaker and trainer, thanks to her many years (20+) in Toastmasters International. She earned the highest designation, Distinguished Toastmaster, and puts those skills to use daily. Martha’s niche’ is the desire to see local nonprofits (BIPOC startups to mature nonprofits) succeed in securing funding to fulfill community gaps in partnership with the philanthropists, private sectors, local, state, and federal governments.