Federal grant management comes with high stakes and complex regulations. Misallocated funds, missed deadlines, or not having adequate compliance oversight can put your agency under additional scrutiny. So how do you navigate these challenges? With robust internal controls.

Internal controls are more than just compliance measures; they’re the foundation of successful grant management. They ensure proper use of funds, regulatory compliance, and efficient achievement of program objectives.

WHAT ARE INTERNAL CONTROLS IN FEDERAL GRANTS?

Internal controls form a comprehensive framework designed to ensure appropriate management of funds, promote accurate reporting, and maintain compliance. When it comes to federal grants, these frameworks ensure you stay aligned with grant terms and obligations.

Federal government agencies must follow the guidelines for internal controls described in the Standards of Internal Control in the Federal Government, commonly referred to as the “Green Book”. The Green Book is maintained by the U.S. Government Accountability Office (GAO).

A typical internal controls framework consists of five key components. Each of these five components contains several elements, with a total of 17 elements in all:

1. Control Environment

• • Demonstrate commitment to integrity and ethical values
  • Exercise oversight responsibility
  • Establish structure, responsibility, and authority
  • Demonstrate commitment to compliance
  • Enforce accountability

2. Risk Assessment

• • Define objectives and risk tolerances
  • Identify, analyze, and respond to risks
  • Assess fraud risk
  • Identify, analyze, and respond to change

3. Control Activities

• • Design control activities
  • Design activities for the information system
  • Implement control activities

4. Communication Systems

• • Use qualify information
  • Communicate internally
  • Communicate externally

5. Monitoring

• • Perform monitoring activities
  • Evaluate issues and remediate deficiencies

A full breakdown of these controls can be found in the Green Book, but below, we summarize the key insights from each element of the internal control framework.

1. CONTROL ENVIRONMENT

The control environment sets the tone within your agency, fostering a culture where everyone understands and values compliance. It’s the foundation upon which all other components of internal control are built.

Leadership plays a crucial role in shaping this environment. Leaders must demonstrate a personal commitment to integrity and ethical values through their actions and decisions. This includes actively participating in grant management processes and visibly prioritizing compliance.

This commitment cascades through the agency in several ways:

• Shaping human resource policies to reinforce control objectives
• Influencing the overall structure to support accountability at all levels
• Establishing clear lines of authority and responsibility

A strong control environment, driven by committed leadership, creates an agency where ethical behavior and effective grant management are expected and valued. This sets the stage for stronger internal controls overall and ultimately leads to more impactful grant outcomes.

2. RISK ASSESSMENT

Risk assessment involves systematically identifying, analyzing, and preparing for potential issues, obstacles, or events that could affect your agency’s ability to effectively manage its grant portfolio. Note that these risks may be internal or external, and that risk assessments aim to serve as a platform for the agency to build risk management frameworks.

The assessment process typically involves:

• Identification: Examine your agency’s overall risk profile and organizational structure to uncover potential risks. Define risk tolerance levels.
• Analysis: Evaluate each risk’s likelihood and determine its impact on grant programs. Pay attention to the different types of fraud risk, from fraudulent financial reporting to misappropriation of assets.
• Prioritization: Rank risks to determine which require immediate attention.
• Response planning: Develop strategies to proactively address high-priority risks.
• Monitoring and review: Regularly reassess risks, involving both internal and external resources in this process.

This systematic assessment creates a more resilient grant management process, helping your agency navigate challenges and achieve its intended outcomes.

3. CONTROL ACTIVITIES

Control activities are specific policies and procedures implemented to mitigate risks and ensure grant compliance and effectiveness. These activities occur throughout the organization, at all levels and in all functions.

Common control activities related to grant management include:

• Designing control activities, such as authorization procedures for grant disbursements
• Regular reconciliations of grant accounts with organizational financial records
• Implementing control activities through policies, for example, establishing documentation systems to track program outcomes and grant deliverables

Leadership plays a key role by allocating resources strategically for these control activities. This might involve investing in grant management software or hiring dedicated grant compliance personnel.

The key is to design control activities that directly address the risks identified in your assessment while supporting efficient operations and mission fulfillment.

Effective control activities help ensure that grant funds are used as intended, program objectives are met, and your agency maintains its reputation for responsible stewardship of taxpayer dollars.

4. COMMUNICATION SYSTEMS

Efficient communication ensures that critical information about grants is accurately identified, effectively captured, and clearly communicated both internally and externally. By prioritizing it, you can enhance compliance with grant regulations, improve program outcomes, and foster a culture of transparency and accountability.

Effective communication systems typically include:

• Regular updates: Hold regular meetings to keep all stakeholders informed about the status of your agency’s grant portfolio.
• Standardized reporting: Develop clear templates for reports to ensure consistency and completeness in your communications with grant recipients.
• Information sharing: Implement systems to quickly share changes in grant requirements or organizational policies with all relevant team members.
• Open dialogues: Create communication channels for staff to discuss grant management challenges openly. Leaders should respond promptly to reported issues, fostering a culture of transparency and continuous improvement.

By prioritizing effective communication, you ensure that everyone involved in the grant management program has the information they need when they need it. This supports compliance, enhances overall grant performance, and enables timely decision-making and problem-solving.

5. MONITORING

Monitoring involves ongoing assessment of your control system’s quality, allowing for timely adjustments. It ensures that the internal control system continues to operate effectively over time.

Effective monitoring typically includes a mix of ongoing evaluations and separate assessments, such as:

• Conducting regular internal audits of grant processes
• Performing annual assessments of the overall control system
• Establishing plans to remediate any internal control deficiencies identified

This proactive approach helps identify and address issues before they become significant problems, supporting long-term grant management success and ensuring the control system remains relevant and effective.

STRENGTHEN YOUR GRANT MANAGEMENT WITH CUSTOM INTERNAL CONTROLS

Effective internal controls are a powerful tool for federal grant management. They provide the structure and insight needed to navigate complex regulations and to ensure that funds are disbursed and monitored efficiently. Together, that’s central to ensuring any grant program––regardless of the agency administering it––is primed for success.

For the best results, bring in an external vendor that’s well-equipped to help you navigate the complex requirements your agency faces. Not sure where to start? Mercadien can help.

Our federal government team can help you assess your current system, and design and implement new controls. With experience working with agencies including the SBA, DHHS, and HRSA, our professionals bring in-depth knowledge of federal financial management. We are a U.S. General Services Administration (GSA) approved vendor (Contract #47QRAA21D00A7) and are classified as a Small Business.

Contact us today to learn more about how we can support your agency in building a more effective approach to federal grant management.

DISCLAIMER: This advisory resource is for general information purposes only. It does not constitute business or tax advice and may not be used and relied upon as a substitute for business or tax advice regarding a specific issue or problem. Advice should be obtained from a qualified accountant, tax practitioner or attorney licensed to practice in the jurisdiction where that advice is sought.