Accountability

Consider managing a grant for several hundreds of thousands of dollars over a period of 24 months whereby the grant outcomes require articulated and cohesive work to be accomplished by a collaborative party of entities. Who is held accountable? The Feds? The local fiduciary whom awarded the grant? Your boss? You? How about your front line staff? What about the local agencies and partners, cohorts and advocates? What components of the grant are clear and what is vague? Is there a contingency plan and systems in place to manage problems and stave off catastrophe?

For a time, common grant language included the phrase, “seamless and transparent services provided to the client”. Ok. But who is really responsible to make sure that happens? Maybe more importantly, who is responsible if the requirements of the grant are not met?
Currently, the White House would like to know who is ultimately responsible for the Gulf Oil Spill. We all would like to know the answer to that. Is it BP? Is it Transocean? Did components fail? Did systems fail? Accountability is obscure because right now; it can’t be explained 
 
“(May 14) -- President Barack Obama today slammed the companies involved in the Gulf of Mexico oil spill for the "ridiculous spectacle" of blaming one another for the catastrophe, promising tougher environmental requirements on the energy industry to prevent any more such disasters. “, By Doug Simpson and Lauren Frayer
And, some claim that offshore oil drilling is or is not regulated by our government and blame the President! Can you conclude, we really don’t know who to hold accountable for this disaster even though many private sector entities and perhaps several governments were and are involved? Yet, lives were forever lost and we don’t even know the scope of the environmental impact. Was there a system for accountability?   Is there one now? Not even now.
 
There is a system that defines, regulates and monitors accountability as it pertains to State and Federal Grants and it is the White House Office of Management and Budget, referred to as the OMB.
 
OMB's Mission
OMB's predominant mission is to assist the President in overseeing the preparation of the federal budget and to supervise its administration in Executive Branch agencies. In helping to formulate the President's spending plans, OMB evaluates the effectiveness of agency programs, policies, and procedures, assesses competing funding demands among agencies, and sets funding priorities. OMB ensures that agency reports, rules, testimony, and proposed legislation are consistent with the President's Budget and with Administration policies.
OMB Circulars

Working cooperatively with the grant-making agencies and the grantee community, the Office of Management and Budget (OMB) leads the development of government wide policy to assure that grants are managed properly and federal dollars are spent in accordance with applicable laws and regulations.

The Office of Management and Budget does not award grants. To find the information necessary to apply for a federal grant, consult the
Catalog of Federal Domestic Assistance (CFDA). The CFDA provides a short summary of each grant program, as well as contact information for federal agencies that award grants. Check the OMB Website for policy information or instructions issued by OMB, and links to the following circulars. FOR EXAMPLE:

OMB Circular A-21

This Circular establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project.

The principles are designed to provide that the federal government bears its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law. Agencies are not expected to place additional restrictions on individual items of cost. Provision for profit or other increment above cost is outside the scope of this Circular.
Your financial management system must provide for effective control over and accountability for all funds, property and other assets. It must also ensure that all assets are used for authorized purposes (40 CFR 30.21(b)(3))

H.R. 3763 - Corporate and Auditing Accountability, Responsibility,
and Transparency Act of 2002

(Rep. Oxley (R) Ohio and 30 cosponsors)
“The Administration supports House passage of H.R. 3763 as an important step toward improving corporate responsibility. The bill is consistent with the President's "Ten Point Plan" and is guided by the core principles of providing better information to investors, making corporate officers more accountable, and developing a stronger, more independent audit system.
The Administration endorses the creation of an independently-funded regulatory organization under the supervision of the Securities and Exchange Commission. The board would develop, monitor, and investigate standards of professional conduct, and enforce such standards, including sanctioning violations by individuals and firms, subject to full supervision and review by the SEC”…and so on.       For more light reading, just Google H.R. 3763

I submit for your consideration, when writing a grant and later – in managing your grant, make sure everyone associated with the grant, internally and externally knows who is accountable for what and how that is integrated into the process. It starts with a chain of command, or an organizational chart. It includes listing responsibilities and tasks attached to each whom is associated with the Grant’s Scope of Work. It aligns expectations. It calls out contingency plans and includes a continuous improvement process. You should include a roster of all personnel, and distribute to all personnel. Additionally, provide a detailed communications protocol. At the end of day…you are accountable.
 
For more information regarding Grants, Writing and Management, please contact:
 
Look for my next article in the series titled Budgets.
 

Scott Brown

BMC LLC

574-360-6969

sabrown4474@gmail.com 

Author: 
Scott Brown