Congratulations! You have written a successful project proposal and your grant funding has been awarded. In addition to meeting the stated project goals and objectives, it is also important to ensure that your finances are fully compliant with the objectives outlined in OMB’s Uniform Grant Guidance (UGG). UGG applies to all non-federal entities receiving federal awards, providing a government-wide framework for grants management. Key sections of UGG cover pre-award activities, procurement, cost principals, time and effort reporting, subrecipient monitoring, and travel. In order to demonstrate compliance, the guidance places an emphasis on having documented policies and procedures.
Understanding the difference between policies and procedures and knowing which sections require documentation will help your organization stay in compliance and maintain strong internal controls to guard against abuse and fraud.
What is the difference between Policies and Procedures?
- Policies are broad statements which describe organizational goals and provide formal guidance for the organization. Policies are developed by leadership and often require adoption by a governing body, such as a board or steering committee.
- Procedures are the step by step instructions that ensure that the goals set forth in the policies are met. Changes in procedures must be internally reviewed by the appropriate staff and board members. Written procedures are also used to train new staff.
How do we know which sections require written procedures and which sections require written policies? The language in Title 2 Part 200 of the Code of Federal Regulations outlines which policies and procedures must be written:
- Procedures:
- Written Cash Management Procedure – § 200.302(b)(6) & § 200.305
- Written Allowability Procedures – § 200.302(b)(7)
- Written Procurement Procedures – § 200.319(c)
- Time and Effort Records: § 200.430.
- Policies:
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- Written Conflicts of Interest Policy – § 200.318(c)
- Written Travel Policy – § 200.474(b)
Although we highlighted a few of key requirements contained in UGG, it’s important that any organization using federal grant funding understands the guidance completely. If you need help reviewing your policies and procedures from the standpoint of compliance with the regulations New Growth Can help. We can review and inventory your current policies and procedures to ensure they are aligned to UGG and state standards and can also work with you to examine your fiscal policies and procedures more holistically, making sure they’re effective and reasonable for your organization. Contact Kaci Roach, our Director of Partnerships, for more information.
