E-017 Tackling Grant Compliance with Alexandra Rosenblatt and Lucy Morgan CPA
Episode Summary:
### Quick Episode Summary Grant Talks Podcast [#017]
*Intro ***.41***
* Fire Away Questions with Alexandra Rosenblatt and Lucy Morgan CPA***1:21***
* The Need for Legal Services with a Focus on Grants***4:35***
* Grant Best Practices: Building Relationships for Success***7:07***
* How Head Start Grants Transform Children-Supporting Compliance***9:36***
* Grant Documentation and Compliance- A Holistic Approach***15:09***
* Grant Surprises: More Compliance, Bigger Stakes***18:21***
* The Last Word with Alexandra Rosenblatt and Lucy Morgan CPA***20:04***
*Outro Audio GrantTalks Podcast with Lucy M. Morgan CPA ***21:13***
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Introducing Alexandra Rosenblatt from the Grants Counsel
Intro: 00:04
Welcome to the Grant Talks podcast with Lucy Morgan. Lucy is the CEO and director of MyFedTrainer.com a leading provider of grant management training and templates for federal grant recipients. This show is for grant professionals looking to gain confidence managing their grants. In an age of increasing complexity, you'll hear from leading professionals on the best practices surrounding grants, what's involved in successfully managing the grants lifecycle and how to make sure your grants are managed correctly. Now here's your host Lucy Morgan.
Lucy Morgan: 00:42
Welcome everyone to this conversation with Alexandra Rosenblatt. Alexandra is an attorney and the founder of the Grants Counsel, which provides training and legal services to nonprofit organizations and local governments that receive federal grants. She works with federal grantees throughout the grant life cycle, drafting and reviewing policies and procedures, advising on compliance and advocating for grantees in OIG investigations, agency appeals, federal court litigation, and other grant-related disputes. Alexandra also provides training on compliance and best practices. And I'm Lucy Morgan, your host for this session. Welcome, Alexandra.
Alexandra Rosenblatt: 01:20
Thank you. Glad to be here.
Fire Away Questions with Alexandra Rosenblatt and Lucy Morgan CPA
Lucy Morgan: 01:21
And I have a few fire-away questions to introduce you further to our audience. Are you ready?
Alexandra Rosenblatt: 01:27
I'm ready.
Lucy Morgan: 01:28
All right. You mentioned that you had been a vegetarian but couldn't give up the Alabama barbecue. At the risk of starting a social media war, what is your favorite barbecue restaurant and why?
Alexandra Rosenblatt: 01:39
Well, being from Alabama, there are so many options to choose from that I would be hesitant to pick an absolute favorite, but I certainly love Dreamland Barbecue, which is, of course, iconic, Golden Rule, Full Moon. There are so many options. Anyone traveling to Alabama, I would encourage them to stop in any barbecue if you eat meat.
Lucy Morgan: 02:01
You said you had moved from being a partner at a D.C. law firm to founding the Grants Counsel. What has surprised you, the most about that type of a life-changing decision?
Alexandra Rosenblatt: 02:13
I think what surprised me the most is the change in what my daily responsibilities were. So, I have always worked at law firms throughout my career and running your own business, as you know, you wear so many different hats and day to day you're dealing with lots of different things from IT to marketing and in addition to your legal work or your training work. So that was very eye-opening for me and I think it has made me a better advocate for my clients because I understand they're running a business too and I understand what their responsibilities are. I understand that the legal component may be only one of the many responsibilities that they have. And so, I have more empathy for when the legal issues may be put off or they may arrive to them late. Although I think that getting legal help early and often is the best policy, but I understand and can better advise them on both the business and the legal aspects of what they're going through.
Lucy Morgan: 03:20
So, it sounds like you've walked a mile in their shoes now.
Alexandra Rosenblatt: 03:23
Right. As a small business owner, I think we've walked a mile and many people's shoes probably.
Lucy Morgan: 03:29
What advice would you give someone who's thinking about a similar type of transformation? I run into people quite frequently who they may be thinking that they're at that point in their life where they're looking for that next chapter that might involve going out on their own as well.
Alexandra Rosenblatt: 03:44
I think that going out on your own is incredibly rewarding because you really have to trust yourself and you have to rely on yourself to make the decisions. And if you are in a...that can be very rewarding if you've made a decision and you see the benefits of it, and at the same time, if you have a decision that doesn't turn out, you have to summon up that resilience and move forward and make different decisions.
I also think it's helpful even though you have to trust yourself and you're going to be making most of the decisions to have a board of advisors or people who can support you because it can be somewhat isolating to be out on your own and just being able to have people that you can pick up the phone and reach out and have interaction with and get their advice is really invaluable I think.
The Need for Legal Services with a Focus on Grants
Lucy Morgan: 04:35
That's some great advice. And I have to say when I read your bio, my first thought was “Wow!” because your bio really hit all the buttons for the types of help that grant recipients need. What are some of the problems that you saw at various grant recipients that made you realize there was a need for legal services with a primary focus on grants?
Alexandra Rosenblatt: 04:55
Well, a couple of things. One, we're dealing mostly with nonprofit organizations or I do, who need not only legal help but also need affordable legal help. And that's one of the benefits that I think a solo practitioner can provide.
As far as problems, I think that there is somewhat of an inclination to kind of think about check the box when we are talking about compliance. “So I need this policy and procedure, so I'm going to put it in place and it's going to be the same as a policy and procedure I used in a previous organization or that I found that other organizations are using” instead of a more thoughtful approach to compliance so that you're really thinking about what works well for your organization, for the individuality of your organization. That is much stronger compliance because you're more likely to follow a policy and procedure that's tailored to your organization. You're more likely to self-monitor and catch issues before they come to an area where you may need legal help. So, I think that just creating a system that's tailored to the organization and that works well is something I think that I could see our field really progressing into more.
Lucy Morgan: 06:22
And that raises a good point. Sometimes I run into folks that they put together a policy or procedure and they checked the box but is it really what they're doing in real life, and sometimes that's where grant recipients get into trouble is that they don't really follow it. They just have it in writing.
Alexandra Rosenblatt: 06:39
Absolutely. And at that point, your policy and procedure can become a liability, frankly, because you may be applying to yourself standards that are more stringent than what is required. And that may be good, you may want to hold yourself to a higher standard, but the worst-case scenario is to have that policy and procedure and then not follow it because then you've created a potential finding where one might not have existed in the first place.
Grant Best Practices: Building Relationships for Success
Lucy Morgan: 07:07
That's a great point. As an organization starts looking at maybe they want to have the benefits of an attorney, what do you think some of the strongest benefits of getting an attorney involved in grant management really sooner rather than later, not waiting until everything's kind of blown up and now we're in a crisis mode?
Alexandra Rosenblatt: 07:25
Right. You've probably heard the phrase “penny wise and pound foolish.” And that I think is very applicable because often involving an attorney may seem like an added expense, but if you can get someone in at the beginning to kind of take stock of what's going on, advise you on how to proceed, you may be able to prevent a problem from really snowballing or for happening in the first place.
I think in general with grants, even if you're not talking about strictly legal issues, the worst thing you can do is have a problem and bury your head in the sand. And I think that's human nature to see if there's a problem, you know, it gets put to the bottom of your stack because I don't really know exactly what the next step is for that. So, you resist dealing with it, it produces anxiety. And that's an issue where if you get some outside help, someone who can come in and take a look, provides some concrete advice about how to handle it, it can really prevent the problem from snowballing.
Lucy Morgan: 08:29
And it's interesting, a lot of our listeners are involved in healthcare fields and with HHS giving out so many grants, not just in healthcare but in other important areas, we stress to people the importance of building relationships, say with a family practitioner before you get sick. So not always running to the emergency room because you have no relationship. And it would seem to me that building that relationship before the houses on fire is a good thing. Also, for legal services, you already have someone who's a trusted advocate or advisor.
Alexandra Rosenblatt: 09:00
Absolutely. And I think that that same concept that you would apply to your program officers, you're laying that foundation because if you gain their trust, then you, you know, get the benefit of the doubt. You appear competent and confident, you're putting your best foot forward and sometimes an attorney laying an eye on your policies and procedures, helping you with reporting, if that's something that you're self-reporting, if that's something that you're faced with doing can really help maintain that trust and that competence.
How Head Start Grants Transform Children-Supporting Compliance
Lucy Morgan: 09:36
So, what about law and compliance attracted you to the world of grants?
Alexandra Rosenblatt: 09:40
So, most of my clients are involved in the Head Start Program and that was a program that really captured my heart. It's one of my favorite grant federal grant programs. The work that they are doing is so important in providing services to children that are age zero to five and their families, and also is transformative because those early years are so important and it provides services not only to the children but also to the families. So, we're talking about having a lifelong impact. And so, I really wanted to work with that program and to help clients not only stay compliant but also to advocate for them where they may need advocacy. So that is how I initially got into federal grants.
Lucy Morgan: 10:35
In your presentation at the National Grant Management Association conference, you talked about getting started in managing federal awards. What are some of the common issues that you see with organizations that maybe they're new to federal grants?
Alexandra Rosenblatt: 10:50
So often I think that we see that somebody who's new maybe isn't quite prepared for the highly regulated atmosphere of federal grants and they may have received grants before or they may have been doing their mission. But when you put that in the federal grant world and all of the regulations that you have to comply with, it's so important to develop that infrastructure for compliance. So, you not only have your written policies and procedures, but you also have trained your staff, you are implementing your policies and procedures, and you're doing some self-monitoring. That's kind of the cycle that I think of when I think of a system for compliance. And another thing that I often see is inadequate documentation. You've probably heard somebody say, "If you didn't take a picture, it didn't happen." I say for federal grants, if there's no documentation, it didn't happen.
So, I encourage people when they're receiving federal grants and they're getting into that system always to be asking themselves two questions. One, am I complying with what the requirement is? And two, if a reviewer walks into my office and says, "Show me how you complied," I need to be able to show them a document that says, "This is how I did it." As an example, my Head Start clients, any contract that involves the exchange of personally-identifiable information has to be reviewed annually. You don't have to make changes, but you have to review it. That's something that somebody may be doing, but they may not be creating a record or keeping documentation that they're doing that. And that's the second piece that you really need so that if the reviewer comes in, if the question comes up, you can be prepared to produce something, showing them a log and notation, something to say that you have complied.
Lucy Morgan: 12:56
And that's really a great point. I love that you've simplified that down to really two areas. I see that a lot in working with clients over suspension and debarment. They may very well be looking up those contractors to make sure they aren't suspended or debarred, but that's where it stops. They forget that piece of documentation or they think just because they have that in the contract provisions that the person is self-certifying that they're not suspended or debarred that that's enough, that they can just stop there. So that whole issue of documentation, I think, is often under talked about in the grant community of just how important it is, not just to do it, but also to be able to prove that you did it.
Alexandra Rosenblatt: 13:36
Right. I always say “Hope for the best and plan for the worst.” So, you want that piece of paper, that email, that follow-up call. A lot of...I'm sure that you hear this too...federal grantees will say, "Well, my program officer told me this," and lo and behold, they're taking a different approach later on and we say, "Is it anywhere in writing?" That documentation also extends to you if you have a call and somebody is telling you something from the federal government at a minimum, email them a summary, "This is what you've told me," so that we have, again, documentation to support what we're doing.
Lucy Morgan: 14:19
I just had that conversation with someone yesterday after a presentation and she was saying the federal agency was telling them not to worry about something that they thought maybe they should be worried about. And I said, "Well if they're telling you not to worry about it, you can't make them worry about it." But I said, "If I'm going rely on that, I want to make sure I've got something in writing that says, 'This is our conversation and this is why we're not going down this path.'" Because unfortunately, the person who's going to come in and audit you is not that program person at the funder that you just talked to who said it was all okay.
Alexandra Rosenblatt: 14:52
Exactly. There can be changeover, there can be changeover in administrations and then there's a different interpretation or a different policy and you're going to be left holding the bag, essentially. So, the important thing is to get that in the documentation.
Grant Documentation and Compliance- A Holistic Approach
Lucy Morgan: 15:09
So, what are some steps that grant recipients can take to make sure that these kinds of issues that come up don't actually hit them in the real world?
Alexandra Rosenblatt: 15:18
I think that it's important to think about compliance holistically and that means a couple of things. One, kind of the cycle that I was talking about earlier, not just having the policies and procedures, but making sure that you've trained your staff on them, that you are keeping that documentation that shows that you're doing it and that you're self-monitoring. You are doing your own audits. And audit kind of sounds like a big and scary word, but it can be as simple as just checking if we have to have staff with certain qualifications every once in a while. And on a kind of regular basis, we check to make sure that recently hired staff have those qualifications. And if we find a problem, then we do something about it. So that's why it's a cycle is that you are constantly tweaking your policies and procedures or your forms so that they really accurately reflect what you're doing and also so that they are working the most effective way that they can.
I also think it's important too when I say think about compliance holistically to do cross-training. It's very important that the fiscal requirements not only reside with the CFO and the finance team, but there may also be programmatic people who need to understand the reasons why we're filling out time and effort reporting or why we're making certain decisions and why it has to be billed or invoiced a certain way. Keeping those, and cross-training not only prevents a situation where if somebody retires or there's turnover in staff and all of a sudden you lose all that capacity, but also it prevents...I think it's better to prevent errors from occurring. If you have everybody keyed into the issues, they may not be able to cite you the rule and all of that, but at least they know the issue so they can raise it to somebody who can cite the rule and go to the research and figure it out.
Lucy Morgan: 17:24
And for those of you working on the finance side of the house with the change where internal controls are now everyone's responsibility, I just want to remind them that communication is one of the core components of internal controls. So, anything that we can do to increase communication between the program folks, the finance folks, HR, procurement, everybody else is really just strengthening internal controls as well.
Alexandra Rosenblatt: 17:48
That's a great point. And I also think it's helpful when you are going to talk to the federal government or your program officer that everybody has some awareness. So, you don't ever have a conversation where you have an employee saying something and that has to be walked back or that so at least that employee knows, hmm, what I'm saying here may have a fiscal component. Let me get that person involved or I do know something about the rules. It just helps present, again, a competent front and it helps build trust.
Grant Surprises: More Compliance, Bigger Stakes
Lucy Morgan: 18:21
So, looking back, what do you think has been your biggest surprise about working directly with grant recipients?
Alexandra Rosenblatt: 18:28
I think that I always knew the meaningful work that they have done and that it is an extremely highly regulated environment. But I have been surprised about how high the stakes can be. In Head Start, we have recently gone through a change where grants used to be indefinite in nature and they've changed to being five-year grants and you may have to recompete for your grant again. So, it really takes compliance to a whole new level when you know that this organization that's been around for 50 years can have a single issue and then have to recompete for a grant or potentially be faced with termination. It is so important for grantees to really take compliance seriously so that they continue to do the good work that they do.
Lucy Morgan: 19:28
And I just want to reinforce that again so strongly because oftentimes we think about compliance as a bunch of rules and it's like the compliance police or the grant police are making us do all this stuff. If you think about it, why we do compliance is so that the people that we intend to help are going to be helped. And you keep that forefront in your mind and you think of whoever the client is, whether it's helping the little children and helping their parents, whoever that is, the importance of that all rests on that balance of our hearts and our heads to make sure that those programs stay in compliance.
Alexandra Rosenblatt: 20:02
That's a great way to put it.
The Last Word with Alexandra Rosenblatt and Lucy Morgan CPA
Lucy Morgan: 20:04
Well, thank you, Alexandra. I want to thank you for participating in this. I'd like to give you that last word if there are any final words of advice you'd like to impart to some of our listeners.
Alexandra Rosenblatt: 20:14
I think just to take an honest evaluation of your team where you have great capacity, where you may lack capacity, and then to address those issues. Not to hide from your weaknesses, but to confront that head-on. That may be as simple as sitting down, making a list of next steps, and then following through with it so it doesn't seem so overwhelming, but really tackling those problems before they become nightmares is so important.
Lucy Morgan: 20:42
Well, thank you for that insight. If someone would like to find out more about you, how should they get in touch?
Alexandra Rosenblatt: 20:47
I can be reached at alexandra@grantscouncil. That's the GrantsCounsel.com.
Lucy Morgan: 21:00
Thank you so much for participating in this Grant Talks podcast. Listeners, if you'd like to get all the episodes, go out to GrantTalks.com, and thank you for tuning in.
Outro Audio GrantTalks Podcast with Lucy M. Morgan CPA
Outro: 21:13
To learn more about how MyFedTrainer.com makes grant management more manageable, visit MyFedTrainer.com. That's MyFedTrainere.com. You'll find all the Grant Talks episodes at GrantTalks.com. That's GrantTalks.com.
More About Alexandra Rosenblatt, Esq.:
Alexandra Rosenblatt, Esq. is the founder of Grants Counsel, which provides training and legal services to nonprofit organizations and local governments that receive federal grants. Alexandra works with federal grantees throughout the grant lifecycle: drafting and reviewing policies and procedures, advising on compliance, and advocating for grantees in OIG investigations, agency appeals, federal court litigation, and other grant-related disputes. Alexandra also provides training on compliance and best practices.
More About Lucy Morgan CPA:
Lucy M. Morgan is a CPA, MBA, GPA approved trainer, speaker, and author of 3 books including “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200.” As a leading authority on federal grant management for nonprofits, institutions of higher education and state, local and tribal governments she has written over 250 articles on grant management topics featured in LinkedIn, various publications and on the MyFedTrainer.com blog.
She is a sought-after presenter at national conferences sponsored by organizations such as the Grant Professional Association (GPA), National Grant Management Association (NGMA) and American Institute of Certified Public Accountants (AICPA).
Lucy is also a highly regarded trainer whose techniques and teaching style come from real-world experience. Having faced many of the same challenges her audiences have endured, Lucy understands that what looks good on paper may not always work in the real world. Because she has been there, she provides people of all professional backgrounds with practical tools to advance their careers and make a bigger difference in the world. She can be reached at [email protected].
>>Hear more about Lucy's story in Episode #004
More Resources for Grant Professionals
Thanks for checking out the Grant Talks podcast!
In this episode of Grant Talks, we talked about a subject that you may want to know more about:
So...as promised I want to share some resources that may help you on YOUR grant journey.
I spoke recently at a national conference that was packed with nonprofit organizations doing tons of amazing work.
- Helping kids, expanding opportunities for homeless veterans, improving healthcare outcomes…the list goes on and on.
One of the things I shared was how much of federal funding is lost to waste, fraud and abuse of taxpayer funds.
Estimates vary, but many sources estimate the waste fraud and abuse to be in the range of 20-24% of the roughly $700 billion (with a B) in grant funds are squandered each year.
It’s shocking!
Think of internal controls like a shield to stop federal funds from being siphoned off to waste, fraud, and abuse.
The goal to ensure the funds are used to help the people the grant was supposed to help.
I mean, isn’t making a difference in the world why we got into grant management? 😊
Feeling a little confused about what you can do?
That’s why I put together this simple checklist on the basics of internal controls.
I hope this easy to follow checklist will keep you on the journey to more federal grants and better grant management.
This checklist helps you focus on the best practices for preventing, detecting, and deterring waste and fraud of grant funds.
And that’s not just my opinion… 😊 these are common anti-fraud strategies from the Association of Certified Fraud Examiners (ACFE)
See how you compare:
- 5 components of strong internal controls
- A common-sense look at the differences between waste, fraud, and abuse.
- 18 best practices for reducing your risks for waste and fraud destroying trust in your organization and more…
These resources are designed for grant managers, just like you, and I hope that you will find them valuable on your grant journey.
P.S. If you’d like to learn more about why internal controls matter to BOTH program staff and finance folks, check out my article at https://blog.myfedtrainer.com/internal-control-case-study-employee-uses-city-card-for-91000-in-personal-purchases/
