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All Grantee Meeting

Compliance Synergy

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You do not climb a mountain like Everest by trying to race ahead on your own, or by competing with your comrades. You do it slowly and carefully, by unselfish teamwork. We could never have made it alone. We needed a great team.

-Tenzing Norgay

(first along with Edmund Hillary to reach the Mount Everest summit)

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Learning Objectives

• To establish a common understanding of what compliance is, why it is a challenge, why it is a good investment, and what its goal is.

• To identify key concepts and strategies for compliance as a team effort

• To understand potential roles of various individuals to ensure compliance and the importance of utilizing a team-based approach to compliance

• To understand the challenges of compliance and some of the resources it requires

• To understand the negative impact resulting from non-compliance and the practices that cause non-compliance

• To understand best practices, strategies, and ideas related to team based-compliance

• To answer questions related to team-based compliance

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Definition of Compliance (Source: Nemertes Research, 2008)

Compliance is the establishment, enforcement and monitoring of controls (technical, operational, management and compensating) that verify and validate that internal and external requirements are being met.

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Definition of Synergy (Source: www.dictionary.com)

The interaction of elements that when combined produce a total effect that is greater than the sum of the individual elements, contributions, etc.

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Components of Compliance

• Requirements – Law, Regulation, OMB Circulars, Grant Terms and Conditions, Grant Application

• Internal Controls – Policies, processes, procedures, tools, segregation of duties, etc. to ensure compliance

• Change – Organizational change, approved grant changes, changes to grant requirements, other changes outside your control

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The Problem of Compliance

Grantees face an increasingly large list of compliance requirements that must be adhered to. Compliance is not just a one-time exercise; rather, compliance requires a continuous effort. The complexity and multi-layered requirements of funding sources require a team-based approach, utilizing staff and other resources from many work areas of an organization.

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Looking at Return on Investment

There are costs associated both with compliance and non-compliance. The cost of investing your resources in compliance up-front is far less than the cost of resolving and recovering from compliance issues and problems later.

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The Goal:

To achieve continuous compliance with all requirements, resulting in allowable activities, practices and expenditures, through an approach that is:

– Proactive– Efficient– Effective– System/process driven– Thorough– Unified with grant requirements– Fully integrated into your organization, recognizing the

necessity of the team approach

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Key Concepts and Strategies

• Commitment – An overall organizational commitment to compliance. Compliance is seen as crucial to your organization’s success

• Intentionality – Compliance usually doesn’t happen by accident• Compliance management – Compliance must be ensured through

communication and teamwork between all appropriate parties• Staff/Volunteer Development – Each staff person and volunteer

must have the appropriate level of knowledge to carry out functions compliantly

• Work is appropriately structured with:– Systems– Internal Controls– Written Policies and Procedures – Write P&P so that when they are

followed, they will only yield compliant costs and practices.

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Key Concepts and Strategies

• Ownership – Everyone understands that they have a role or duty in ensuring compliance

• Continuous – Acceptance of compliance as a regular, day-to-day part of doing business, and integration of it into all activities

• Recordkeeping – Appropriate documentation is critical (if it’s not documented, it didn’t happen)

• Disclosure – Prompt disclosure of non-compliance will prevent problems from snowballing. Disclose problems to appropriate staff in your organization and OneStar

• Communication – Communicate challenges within your organization and to grantors, peers, training/technical assistance providers, and others. Always ask for help!

• Recognition of the need for a team-based approach and intentionally working together to achieve compliance

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Key Concepts and StrategiesSource (7 Keys to Building Great Work Teams, Zoglio)http://www.stickyminds.com/sitewide.asp?Function=edetail&ObjectType=ART&ObjectId=2769

• Employ 7 Keys to Building Great Work Teams to your compliance efforts:– Commitment– Contribution– Communication– Cooperation

• F.A.C.T.S. model of effective team member behaviors– Follow-through– Accuracy– Creativity– Timeliness– Spirit

– Conflict Management– Change Management– Connections

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Sample Responsibilities

• Executive Director/Executive Management– Set the tone in the organization regarding the importance of compliance and

its commitment to it– Ensure the availability of resources for compliance

• Program Director– Overall knowledge of grant requirements– Communication to all other stakeholders regarding requirements (better to

communicate too much than too little)– Internal monitoring/auditing to ensure compliance– Create processes, policies, procedures, tools to ensure compliance

• Programmatic Staff– Overall knowledge of grant requirements– Accurate recordkeeping– Supervision of members to ensure activities are allowable

• Employees of Program Sites– Aware of unallowable activities– Accurate recordkeeping of time worked on the grant– Supervision of program participants to ensure activities are allowable

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Sample Responsibilities

• Program Participants– Aware of prohibited activities– Accurate recordkeeping including activities and timesheets

• Fiscal/Payroll Staff– Understands Generally Accepted Accounting Principles– Thorough grasp of Code of Federal Regulations, OMB Circulars, and Grant

Award– Understands programmatic purposes of the grant– Regularly communicates with program staff– Accurate recordkeeping– Create processes, policies, procedures, tools to ensure compliance

• Internal Audit– Internal monitoring/audit to ensure compliance

• Volunteers– Submit documentation to substantiate volunteer contribution

• Contractors– Adhere to specifications provided by your organization

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Resources

• Time of staff and others must be invested

• Money for appropriate staffing, supplies, software, etc

• Some short-term programmatic impact may have to be sacrificed in order to ensure compliance.

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The Cost of Non-Compliance (Negative Impact)

• The time of staff, volunteers, and other stakeholders is wasted

• Organizations must use unrestricted money to pay back disallowed costs

• Negative publicity• Reduced or denied future funding• Decrease in long-term impact and ability to

provide services

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Things to Avoid

• Different parties not knowing what the other is doing (siloed operations)

• Processes not documented in writing• New staff not trained• Expecting compliance to “just happen”• Thinking of compliance at the last minute• Unfamiliarity with grant requirements• Taking the role of grant compliance solely onto

yourself• Keeping weak areas “under wraps” instead of

disclosing and getting help

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Ideas/Best Practices• Create a Compliance Committee• Hold monthly compliance trainings for staff and others involved with grants• Periodic Newsletter on compliance issues and changes• Allow and require staff to take time to read and absorb compliance

requirements, including OMB Circulars, Federal Regulations, grant terms and conditions (block off time on your calendar)

• Outside Training:– Management Concepts: www.managementconcepts.com– Thompson and Thompson Interactive: www.thompson.com and

www.thompsoninteractive.com – Funder-Sponsored Training– Management Support Organizations and Associations

• Create processes and tools to automate, streamline, and simplify compliance• Borrow processes and tools, but be sure they make sense for your

organization (modify when necessary)• Use as much software functionality as possible, helping to ensure accuracy

and efficiency

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Ideas/Best Practices

• Perform internal auditing/monitoring and checks to ensure that processes are being followed appropriately

• Kickoff Meeting held at the beginning of a grant to ensure that all appropriate parties are knowledgeable about grant requirements. Copies of the grant application, award, budget, etc are provided.

• Training for new staff• Staff attrition plan-create a roadmap of how compliance will be ensured in

times of vacancy and how new hires will be brought up to speed with compliance-related knowledge.

• Create a compliance Standard of Conduct for those involved with your grants

• Determine your biggest risks and ensure your policies and procedures are written to mitigate these risks

• Work with other organizations to obtain and provide assistance with difficult issues

• Talk with your funder about difficult compliance issues, and ask for training/technical assistance

• Have a staff member specialized in compliance

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Let’s Hear from You

• Best Practices

• Successes

• Things you wish you would have done

Questions?

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A Story of Four People

There once were four people named Everybody, Somebody, Anybody and Nobody.

An important job had to be done, and Everybody was sure that Somebody would do it.

Anybody could have done it but Nobody did it.

Somebody got angry about that, because it was Everybody's job.

Everybody thought Anybody could do it and that Somebody would do it.

But Nobody realized that Everybody thought Somebody would do it.

It ended up that Everybody blamed Somebody when Nobody did what Anybody could have done. 

-Author Unknown

Contact

Jerry BertrandSenior Grants Officer

OneStar Foundation

jerry@onestarfoundation.org

(512) 287-2030

Chris RileySenior Grants Officer

OneStar Foundation

chrisr@onestarfoundation.org

(512)287-2061

www.onestarfoundation.org23

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OneStarFoundation.org