Contributed by our Director of Grants & Compliance, Victoria Hougham
You’ve just received a Federal funding award. Congratulations! But, what now?
As a Federal grant award recipient you are required to follow all statutory and regulatory requirements. Understanding all of the grant compliance requirements and navigating the many systems can be confusing. While each award is different, there are many similarities in the post-award process we discuss below:
STEP 1: Review the Notice of Award and all Terms and Special Conditions
Most importantly, when you receive a Notice of Award (NoA) do not immediately begin working on the project. There are still many steps to take before you can begin spending. Carefully review the NoA and any terms and special conditions that come with it. This sets you nicely on the path of achieving grant compliance. A NoA is legally binding so be sure you understand everything and are prepared to meet all conditions before accepting the award or incurring expenses. Once you accept you are legally obligated to carry out all terms and conditions.
The NoA will have the name and contact information for your primary programmatic and financial contacts, often called a variation of contracting officer (CO), program manager (PM), or grants management officer (GMO). In many cases the program officer will have an orientation call with you to review everything prior to signing. Ask any questions you may have at this time.
STEP 2: Accept the Award and Meet Requests
In order to accept the award follow the instructions provided which are specific to your award. Most awards require a signature or initialed pages from the grantee’s dedicated representative- this person is called the Authorized Organizational Representative (AOR).
In some cases the awarding agency will request adjustments to the budget or changes to the scope of the award. At times this will happen prior to award if the total funding level needs to be adjusted. Focus on making sure that these changes are both feasible for your program and completed within the time frame provided.
STEP 3: Acknowledge the Waiting Period
In most cases receiving and accepting the grant does not authorize you to begin work on the project. Additional internal review and processing needs to happen. You will be notified by the CO/PM/GMO when you can begin incurring costs on the project.
STEP 4: Begin Internal System Planning
While you cannot begin project work or incur project expenses prior to notification from the agency, you can use this time to update your administrative and grant team systems. All Federal agencies use different platforms where you share performance metrics, report financial performance, and draw down funds. For example HHS uses the Payment Management System (PMS) and the Department of Justice uses the Grant Payment Request System (GPRS).
Assign roles and responsibilities to the administrative staff who will be responsible for managing the award funds, and check that their contact information is correct in each platform. Finally, be sure your accounting team and accounting software are ready to handle and navigate the complex financial responsibilities of grant funding. Have your accounting team create a grant compliance checklist based on the OMB Uniform Guidance and the special conditions defined in your award. Also confirm that your indirect cost rate is usable for the beginning of the grant until you can renew it.
STEP 5: Communicate with Approved Project Partners
Once you’ve accepted the award you’ll want to let any key project partners know that you have received and accepted the award. However, at times the awarding agency will request changes to your named subrecipients and contractors (including budgetary changes or even a new project partner). So, be sure that you’ve already confirmed with your primary agency contact that the named partners are or will be approved before telling them.
While you should not sign any contracts or subawards until the award approval process is complete, you can begin conversations with approved key partners to make certain they are ready to commence work when you have final approval you anticipate to have.
In most cases you cannot begin billing the project for work spent during this time, unless you have specific authorization from the awarding agency. Check that your subrecipients and contractors know this as well.
STEP 6: Get Started!
Finally! Your project budget and deliverables have been approved and you are ready to begin working on the project. At this point you can work with the PO/GMO to finalize any subawards and contracts, move forward with hiring, and begin charging time to the grant. At this time, start measuring your grant compliance and do not stop until the grant is complete. For ideas on how to navigate the post-award project period see “Setting up Your Internal Accounting Systems for Federal Awards” and “Understanding your Federal Grant Budget and Making Sure You Operate by it.”