What Should Federal Grant Recipients Be Doing Before the July 13 Comment Deadline?
Jun 30
/
Rachel Werner
The proposed updates to the Uniform Guidance have sparked plenty of discussion since they were released. While the public comment period remains open through July 13th, many organizations are asking the same question: What should we be doing now?
The good news is that this is an opportunity to prepare, not panic.
Because the proposed revisions have not been finalized, organizations should continue following the current Uniform Guidance requirements. At the same time, this is an ideal opportunity to review existing processes, identify potential areas of impact, and begin conversations that can make future implementation much smoother if changes are adopted.
The good news is that this is an opportunity to prepare, not panic.
Because the proposed revisions have not been finalized, organizations should continue following the current Uniform Guidance requirements. At the same time, this is an ideal opportunity to review existing processes, identify potential areas of impact, and begin conversations that can make future implementation much smoother if changes are adopted.
Do you need to change your policies right now?
No. Until any revisions become final and an effective date is established, organizations should continue operating under the current Uniform Guidance requirements.
That does not mean this time should be spent waiting. Instead, use it to evaluate whether your written policies and procedures accurately reflect how your organization operates today. Many organizations discover during these reviews that their documentation needs updating regardless of whether new regulations are adopted.
Reviewing policies now can also make future updates easier because you'll already understand where improvements may be needed.
That does not mean this time should be spent waiting. Instead, use it to evaluate whether your written policies and procedures accurately reflect how your organization operates today. Many organizations discover during these reviews that their documentation needs updating regardless of whether new regulations are adopted.
Reviewing policies now can also make future updates easier because you'll already understand where improvements may be needed.
Who should be involved in reviewing the proposed changes?
Federal grant compliance is rarely the responsibility of one department.
Consider bringing together representatives from grants administration, finance, procurement, program management, leadership, and anyone responsible for compliance activities. Each group may identify different operational questions or implementation challenges that deserve attention.
Having these conversations now also helps build a shared understanding of how potential changes could affect day to day operations across the organization.
Consider bringing together representatives from grants administration, finance, procurement, program management, leadership, and anyone responsible for compliance activities. Each group may identify different operational questions or implementation challenges that deserve attention.
Having these conversations now also helps build a shared understanding of how potential changes could affect day to day operations across the organization.
What questions should your team be asking?
Rather than focusing only on what may change, focus on how your organization currently operates. Ask questions such as:
These discussions often uncover opportunities to strengthen compliance, even if the final regulations differ from the current proposal.
- Do our written procedures accurately reflect our current practices?
- Are there proposed changes that could highlight specific deficiencies in our existing processes, policies, and/or operations?
- Are there areas where additional staff training may be needed?
- Would any proposed revisions affect procurement, financial management, or subrecipient oversight?
- Are we relying too heavily on institutional knowledge instead of documented procedures?
These discussions often uncover opportunities to strengthen compliance, even if the final regulations differ from the current proposal.
Should your organization submit comments?
Not every organization will choose to participate in the public comment process, but many have valuable experience that can contribute to the conversation.
If your organization has identified practical implementation concerns, areas that need clarification, or unintended consequences, consider discussing whether submitting comments would be appropriate. Feedback based on real world experience can help improve the final guidance and provide valuable perspective for policymakers.
If comments are submitted, they should represent your organization's official position and be coordinated through the appropriate leadership.
If your organization has identified practical implementation concerns, areas that need clarification, or unintended consequences, consider discussing whether submitting comments would be appropriate. Feedback based on real world experience can help improve the final guidance and provide valuable perspective for policymakers.
If comments are submitted, they should represent your organization's official position and be coordinated through the appropriate leadership.
How can you make the most of this time?
The period between a proposed rule and a final rule gives organizations something that is often in short supply: time to prepare. Continue following the current Uniform Guidance, stay informed as developments occur, review your policies and procedures, identify training needs, and document any questions your team has along the way.
Preparation does not require making immediate operational changes. Instead, it means understanding what may be ahead so your organization is ready to respond thoughtfully when final guidance is issued.
Organizations that use this time wisely will be better positioned to adapt with confidence while maintaining strong compliance throughout the transition.
Preparation does not require making immediate operational changes. Instead, it means understanding what may be ahead so your organization is ready to respond thoughtfully when final guidance is issued.
Organizations that use this time wisely will be better positioned to adapt with confidence while maintaining strong compliance throughout the transition.
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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.