Wrap it Up – Grant Closeouts
Today I had the opportunity to preview some of the initial work for our upcoming FAPIIS webinar. It’s exciting to work on something new and informative. Then my brain went on a bit of a “why” tangent. I know that these new requirements stem from Section 872 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009.
But really – why?
Yes, FAPIIS stands for the Federal Awardee Performance and Integrity Information System. We want the assurance that Federal funds invested in grants perform and are managed by good people. We even think that past performance should matter. However, we should also keep in mind that our system of government is designed to be reactive.
So what was Congress reacting to when it instructed the Executive Branch to implement FAPIIS? Passed the DATA Act? Introduced the Grants Oversight and New Efficiency Act (GONE) Act? Perhaps some of the members read reports from the GAO detailing the need to improve the grants closeout process. And those members want these issues fixed.
I believe that with smart planning, agencies and recipients alike can improve the reporting and tracking of Federal funds going forward. But we also need to look at our past and current grants portfolios to make improvements now, especially with regards to closeouts. We need to wrap it up. Let’s review a few steps you can take.
- Review the Uniform Guidance on closeouts. The Uniform Guidance’s section on closeout spells out the responsibilities and requirements for Federal awarding agencies and pass-through entities. Between this section and the award agreement itself, you can make an administrative checklist for the award based on your role.
- Budget for “after the grant” activities. Recipients and subrecipients should ensure that they have sufficient resources in place for reporting and accounting that takes place within 90 -180 days of an award’s end. Some research grants may have long-term tracking and evaluation requirements for particular objectives or outcomes. Make a project plan and identify the estimated costs for these activities. Then work with your leadership to ensure that the associated funding is in place.Federal awarding agencies need to also plan and cost closeout activities for each grant program. While grant program managers and officers may not lobby directly for funding, they can document post-grant responsibilities and estimate the funding needed for corresponding activities and systems. This information could inform administration budget requests.
- Share the news that “it’s” over. Rather than viewing closeouts solely as an administrative burden, seize the opportunity to let your stakeholders know that you ended something successfully. You could make your final report public with appropriate revisions. You could report that you completed all closeout requirements on time as part of any past performance statements for future grants. You could feed in the success stories from grant A into the proposal for grant B, and the next phase of your long-term project.
Keep in mind that every closeout completed quickly and efficiently will have an impact on your time and resources. It means fewer reports long after the last drawdown. In some cases it could mean avoiding continued bank fees for grant-specific accounts with no expected revenue.
If we as a community improve just this one aspect of grants management, maybe Congress won’t notice so many discrepancies during its oversight. Maybe that results in fewer new laws and regulations on grants administration.
We all need to remember that we all benefit from the transparency that the completion of closeouts, FAPIIS reporting, and all of the other Uniform Guidance changes brings.