Starting with the End in Mind
How a focus on compliance can improve your grant writing and implementation
If you are a Chief Financial Officer, Grant Administrator, or Grant Accountant, here’s a fun game: using the board below, mark off a square each time you ask or are asked one of the following questions about a grant program. How long till you get BINGO? A month? A week? Less?
The days of Health Center staff are so busy, full, and varied that I feel like we can develop an Etch-a-Sketch memory after every grant application submission- we shake our heads for a second and it all disappears as we scurry to the next fire to put out. This creates those exciting (read: terrifying) moments when a Notice of Award shows up in your inbox and the 120-day timer to implement a new grant program has begun!
As our Health Centers grow in terms of size, budgets, and number of programs or services offered, it can be easy to start getting lax or complacent with our grant applications, grant management, and grant compliance. Do we really need another meeting to discuss a grant application that only exists in the abstract future when we have real, concrete problems facing us here and now?
Short Answer: Yes.
Taking a compliance-centric perspective on grant application development is just as important as focusing on compliance during Service Area Competitions, On Site Visits, and audits; but here is the kicker, focusing on elements of grant compliance can also solve one of the most frequently cited concerns in employee satisfaction surveys: lack of communication.
No doubt, the struggle is real. It is hard enough to coordinate three or four schedules to get the C-suite together when a supplemental grant funding opportunity with a short deadline drops in your inbox. By the time directors, supervisors, or even board members are added to the mix, developing a proper project management plan is nearly impossible. That being said, making sure the right people are involved early in the application process will pay dividends in the long run. So let’s look at a few common non-compliance concerns and see how to prevent them and – more interestingly- what other benefits the Health Center reaps.
As was stated before, once the Notice of Award finds its way to your inbox, HRSA has started the 120-day timer for the new grant program to be up and running. Take this and marry it to the fact that the vast majority of grant funds are spent on personnel costs, and what do you get? You get your first progress report to HRSA explaining the grant program is not off the ground because recruitment efforts are still under way.
While this may be a genuine issue in today’s tight labor market, having your Human Resources Director/VP in the room early on in the process can alleviate a lot of stress. Much of the heavy lifting for new positions can be planned, or even executed, prior to the application even being submitted. Job descriptions, wage ranges, organizational chart updates, recruiting strategies, etc. can all be done, at least in draft form, well before the anticipated award date. With these administrative tasks locked, loaded, and ready to go, the recruitment and hiring process can start the same day the award notice is received.
A new vehicle for community outreach or patient transportation. A new software for tracking quality metrics. New dental or imaging equipment. What do these all have in common? They all likely exceed the micro-purchase limits per 45 CFR 75. What does that mean? It means you will need to go through a more formal procurement process. A quick Google search might be enough to get a ballpark cost for your grant application; however, any purchase over $10,000 made with Federal funds needs more formal documentation, including a sufficient number of quotes, estimates, or bids from qualified suppliers.
From vehicle shortages to ever-tightening labor markets, acquiring equipment or getting an estimate for anything related to skilled trades like plumbing, electrical, or HVAC takes significantly longer on this side of the public health crisis. Having your resident procurement expert, if it isn’t the COO or CFO, involved in the application again will take a lot of strain off your mind once that award notice arrives. Even if the award notice never comes, scheduling or acquiring the procurement documentation does not cost anything but some time and will provide information you will more than likely need within the next year.
Data Reporting and Performance Monitoring
Most people are familiar with the common aphorism about the problem with assuming, but when it comes to monitoring and measuring the performance metrics of your grant objectives, it is doubly true.
No CEO/Project Director wants to get a notification from HRSA saying their Progress Report, Budget Period Renewal, or Non-Compete Continuation is due and hearing from their Quality Improvement, clinical, or case worker staff that little-to-no data has been collected. It is not a fun place to be, and having the right people involved in the application process can easily prevent this (nightmare) scenario.
So many of our managerial decisions involve Information Technology since healthcare is moving ever more rapidly into a digital environment. If your IT director/CIO is not involved in your grant application processes, you are asking for trouble. Do not assume that your Electronic Health Record or Practice Management Software can track the specific metrics you have in mind. Do not assume someone somewhere in the organization has a spreadsheet buried deep in the bowels of their hard drive with the data neatly tracked and ready to submit to HRSA. You are just as obligated to make sure the performance data you are reporting for a small supplemental grant is true and accurate as you are your UDS data submission. Your IT professional must know what data the software that they are responsible for is expected to collect and report. They should also coordinate with the appropriate staff shortly after the grant program has started to ensure data integrity and accuracy. As an aside, this is also one of the strongest arguments for an in-house IT professional.
Boots on the Ground
Finally, it cannot be overstated how valuable it is to get the perspective of front-line employees. Before submitting your grant application, get feedback from the staff that will be doing the work. They will know if your goals are feasible, if your timelines are reasonable, and if the project is even possible.
If you are starting a completely new program, connect with a sister Health Center who already has that program and see if you can talk to their staff for an hour. One of the most common forms of hubris among management is to assume we know how every workflow or process really works; however, our mission as Health Centers is to carry out grant objectives in culturally sensitive ways. Your CFO would also encourage you to carry out your objectives in efficient, cost-conscious ways too. Your front-line staff will invariably have granular, seemingly esoteric, knowledge that will allow you to avoid a landmine once your program is up and running- whether it’s something about an unspoken cultural rule in a particular community or knowing exactly who to contact in a partner organization to get a quick and accurate response.
Getting the right people involved early in the grant process can help avoid not only non-compliance with your grant terms, but it can help you avoid costly mistakes, delays, and more importantly, staff disgruntlement.
Good employees generally do not mind working in a “crunch time” mentality when deadlines are tight; however, repeatedly sending urgent requests that could have been avoided with more forethought wears staff down and makes them feel like they are left in the dark and not trusted. If your staff are talented and smart enough to fix the issues of a hastily put together grant application after-the-fact, then they are talented and smart enough to contribute to a well thought out grant application before-the-fact.
Again, I recognize that finding the time and scheduling availability for all of these staff to meet for an extended period of time can be challenging. However, you can be creative- well before the submission due date, have just the C-suite put together a proposal with questions and concerns and email it to the appropriate staff for their review and input. Then the executives can reconvene, address issues or ask additional questions, and then submit a grant application with peace of mind. Trust me, your sleep is a little sweeter knowing that if you wake up to an award notice in your email tomorrow morning, you and your staff are well prepared to implement an effective, efficient, and compliant grant program.
Director of Healthcare Finance and Compliance