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Navigating Federal Funding Shifts | Now is the Time!

Published
Apr 14, 2025
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This webinar explored strategies for managing federal funding efficiently with a focus on compliance.    


Transcript

Jennifer Butler: Great, thanks so much Bella. And hello everyone. Thank you guys for joining us today. As she said, I'm Jennifer Butler and I lead our government services team at EisnerAmper in advisory. I've spent over 20 years helping governments and nonprofits manage federal funding. So I'm going to take us through the presentation and I'll be starting and then we'll be hearing from Louise in just a little bit. All right, so up first I'm excited to spend some time with you today talking about how we can all navigate the evolving federal funding landscape. Right now we're seeing a real shift in the environment around federal grants. There's a really strong focus on accountability, transparency, and oversight, especially when it comes to how federal dollars are being spent. This means that grant recipients, like many of you are under increasing pressure to demonstrate not only compliance, but also effectiveness and efficiency. That shift is showing up in more rigorous audit activity, heightened scrutiny around allowable costs, and evolving policy interpretations that require all of us to stay sharp and stay flexible. These rules aren't necessarily new, but how they're being enforced is changing, and that's why this conversation today really matters.

So we've all been following these shifts in federal funding. So a couple of examples that have been in the news that might be impacting your organizations. For instance, the National Institutes of Health have experienced reductions in funding for programs and also a cap on indirect costs. The Environmental Protection Agency is seeing a shift in program priorities that have created some uncertainty for many of their new programs and for multi-year grants. Changes like these can affect your staffing plans, program progress, and your agency's ability to meet program objectives. These examples highlight why it's so critical to monitor both federal budget decisions and agency level guidance because these funding assumptions can shift quickly and dramatically and impact local planning and communities. So we'll walk you through some practical steps you can take to strengthen compliance, improve processes, and build internal resilience so your organization is prepared and responsive as these expectations continue to rise.

So with that in mind, we'll start with the foundation of grant management, which is compliance. So we'll start with setting the tone for everything of just why grant compliance really matters. At its core, compliance is about being proactive as much as possible and not reactive. So when we develop and document a strong internal monitoring and control framework, we're not just checking boxes. We're really building like an early warning system that helps us spot risks before they turn into real problems, and Louise is going to talk a lot about that. So a couple of main key areas of why compliance matters, maximizing impact, so proper stewardship of our public dollars, our grant funds facilitates the effective use of funds to support communities and programs Now more than ever, showing results and impact are really important. Another area is regulatory accountability. Increased federal oversight means that organizations must adhere to stricter compliance requirements.

Maybe there's more reporting that's going to be asked of you and you're going to want to be ready to avoid penalties and potential funding loss. A third area is public trust and transparency, efficient and compliant. Fund management builds confidence among stakeholders, funders, and the public, making sure that you're earning public trust through good stewardship of public funds. And also being very transparent. We often support transparency by creating public facing dashboards that track spending and progress with the projects in the communities that are funded. And then finally, compliance matters for long-term sustainability. So having strong financial and grant management practices positions our organizations for future funding and that organizational resilience. But being compliant doesn't mean being super rigid either. All of our organizations have to be nimble and making programmatic changes to adapt to these shifting federal priorities and funding availability, failure to adapt can lead to funding, shortfalls, compliance, penalties or potentially missed opportunities. So next we'll talk about a few key themes inside your organization.

So how do you know where your organization stands today? What risks are you facing? This is where a compliance and readiness assessment comes into play. It's like a grant management report card. So we're looking to identify gaps, whether they exist in process documentation, training, maybe financial controls, alignment with uniform guidance. You'd be surprised by what you can uncover when you step back and take a holistic look. A compliance and readiness assessment really sets the stage for improvement and gives you a roadmap for aligning your grant management efforts with current federal expectations. This is not something that you just do once and kind of put it on a shelf. This is something that you want to continuously do that you want to always be looking at compliance and readiness and doing these assessments. So here's six things that an assessment should cover. First, identify gaps in your current federal grant management processes and internal controls. The second one is ensuring policies align with grant compliance requirements like the Office of Management and Budgets, uniform guidance. We'll talk a little bit about this next.

One of the third things that your assessment should cover is making sure that you have developed and documented internal monitoring and control framework to detect those risks early. So again, Louise is going to talk about that in detail. The fourth thing is assessing the long-term viability of funding sources by analyzing policy trends and your federal budget priorities. Number five is evaluate the risk of program discontinuation or shifting priorities in the federal funding landscape. This will help you proactively plan for alternative funding sources and program sustainability. This is really important right now you really need to evaluate the risk of your main funding sources and have a really good understanding of that flow of federal dollars. And then number six, when you're passing your funds down to a subrecipient, you still bear all the responsibility and risk of non-compliance to make sure that you're doing an assessment and reviewing those sub-recipient monitoring practices for compliance with the pass through funding requirements. So I had mentioned the OM B'S uniform guidance, so we're going to go and spend just a few minutes talking a little bit about that.

So definitely one of the things when we're talking about grant compliance is understanding the federal regulations and the key uniform guidance areas. I'm going to point these out because these are some of the most either misunderstood or they're the areas where we see the most audit findings, and these are the places where you want to make sure that you've got really sound practices because you don't want to be failing on a report card or making the news because of mismanagement of federal dollars. So understanding uniform guidance is not just the job of your compliance officer, your organization, everyone involved in grant management needs a working knowledge of these rules. So I've got the most critical areas here. So allowable costs what you can charge and can't charge to your grant. So you have to make sure that you understand what administrative expenses mean, what percentage of your grant can be spent on that, that you're properly tracking and documenting travel or even things like indirect.

We've seen quite a few changes to indirect costs, both in uniform guidance and also in some federal directives that have recently come out. Another critical area is procurement, making sure that your bidding processes are fair, competitive, compliant. This is usually the number one audit finding, and so having written documented procurement standards and then making sure that everyone that's involved in procurement understands what the process is and that we're keeping all of those papers and all of that documentation in our grant files. The third one's financial management. So you need systems in place to manage your cashflow, document those expenses and the reporting that comes with it. Then finally, program income. Knowing how to treat the income that's generated through grant activities so that it's used according to the grant terms. And let's not forget the regulations get updated. So we've had some recent updates to the OMB two CFR 200 where uniform guidance lives and just making sure that we're following those that we're taking attending training sessions when you can. So there's a lot of great information out there about changes to uniform guidance. So make sure that you're taking advantage of that.

Alright, let's talk about we've got all of these changes. So how do we build capacity within our organization? How do we foster that continuous improvement? So with all the changes that are being enacted or suggested, some of the things that we're hearing might come, the best advice is to be prepared. So be proactive with your teams, be proactive with your federal program officers and be proactive in your understanding of any risks you want your team to be the most prepared. You want to be able to tell a really great story about your programs and outcomes. So starting with building capacity and workforce expertise, again, make sure that we're getting that ongoing grant compliance training, both your staff and your leadership as the standards evolve. The second one is collaboration. So grant compliance isn't siloed, it isn't the responsibility of one person. It is definitely a cross-functional collaborative effort.

So different areas of your organization are all going to be involved. Finance, program management, it, your legal teams, especially with a lot of these different changes in federal funding ships and priorities, you're going to want to go back to contracts and agreements that you have. So just make sure that you don't feel like you have to burden this all alone, that you're going to want to involve others in your organization. And then the final thing related to workforce expertise is make sure to partner with your federal agencies. Reach out, make sure that you have relationships with your program officers and industry experts to stay ahead of those regulatory updates. And now thinking about how do we apply this? How do we embrace continuous improvement and create that culture of continuous improvement? One of the things that I would definitely suggest is conducting evaluations of your current programs to assess their program efficiency and effectiveness.

So have your results ready, have a report card, have done that work ahead of time to say, Hey, this is the grant that we have, these were the expectations, these were the key performance indicators. This is how we're doing on our budget and our spending. Have those results ready to share with your leadership, with your board, with your political representatives, with your program officer. You want to have that in your back pocket. So if there's a conversation about your grant or it's effectiveness or how you're spending your money, that you've got that information ready. Also, gather stakeholder feedback to refine your processes and improve your outcomes. Ask how you can make changes to the program to deliver better.

We talked a little bit about this already. Adapt to that. Grant compliance, be as proactive as you can rather than reactive what's coming, what have we heard about or start thinking about what those potential changes you'll need to make. So thinking back to the example I gave about capping indirect costs, if you might be affected by that, how are you going to have to update program delivery, update your budget, update your process. You might have updates to systems, and then how are you going to fill that gap with other funding if you've got a limit on indirect costs now that you weren't anticipating? And then finally, benchmark against other peer organizations to identify grant management best practices in areas for improvement. What are other organizations like yours doing? One of the best things that you can do is reach out to a similar organization, let 'em know, be vulnerable and say, Hey, this is what I'm experiencing. How are you guys handling this?

All right, so how are we going to adapt to all this change? The reality is that the change is here. All of these funding priorities are shifting. There's a lot of different compliance expectations. So waiting for certainty is not an option. I know that there has been a lot of uncertainty recently, but we have to adapt. And so there's some risks to taking a wait and see approach. So if you don't act, you could have potential funding disruptions and compliance pitfalls. You could be under increased scrutiny and we've got evolving audit requirements. And also if you delay, if you take a wait and see approach, you could potentially miss out on opportunities. So as we see federal funding program priorities that are moving and shifting, you want to make sure that you're tracking those so that you're not missing out on some other opportunities. So we definitely want to be proactive to take steps now.

So assess impact. So again, identify how the policies are going to affect your current and future grants scenario planning. So sometimes we do a lot of this already. Maybe we're standing kind of that water cooler talk or we're doing a lot of the what if our program is affected by a change in indirect costs. What if this program is delayed for six months while we wait for further guidance? What are we going to do? So develop those interim strategies for funding shifts and compliance updates, maybe new reporting, and definitely engage leadership. So this is leadership of your organization, these are your stakeholders, your sub-recipients. These are things like making sure your political representatives are informed and aligned, aligned with potential impacts that they have an understanding of how some of these changes could impact the services that you deliver to your state or your communities or your nonprofit.

And then finally, just stay informed. There's a lot out there. And so you make sure that you've got your trusted resources that you're monitoring those regulatory updates. Participate in policy discussions. If there's an opportunity for public comment, take the opportunity. So in addition to a lot of the government websites like the Office of Management and Budget, there's several national associations that provide really valuable guidance and content organizations like the National Grants Management Association, the Association of Governmental Accountants, or the National Association of State Budget Officers. So there's a lot of great resources out there. Make sure if you're not a member of those and it's an organization that sounds like something you're doing, join an organization and make sure that you're getting the most up to date information. Alright, I think we're ready for our first polling question.

Okay, perfect. So what is your organization's biggest challenge in federal grant management? Is it regulatory compliance and policy changes? Implementing the program is your biggest challenge fraud prevention and detection, or is it workforce expertise? So the poll will be open for 60 seconds, so go ahead and make sure that you're reading the question, you're entering your response. And while we wait for those answers to come through, I will address a question that came through the q and a. So if there's one thing I could do right now, what should it be? That's a great question. The one thing that you should do is that rapid compliance and readiness assessment. So definitely focus on the assessment of your federal programs with everything that's happening, you need to know where you stand before you can move forward. So look at your federal programs. That's the one place. So look at understanding your exposure under current funding streams, policy changes, prioritize any training, technology updates, make sure you understand how your sub-recipients are doing, and then think of it as kind of taking the pulse of your grant program. I talked a little bit about a report card. It's really the best first move that you can make is taking a look at your federal programs and the risks there.

A question. Fantastic. So what is your organization's biggest challenge? Oh, I'm not sure if those are the right answers. It looks like all of the above. Oh, there we go. There we go. It looks like more than half of you are on regulatory compliance and policy changes. Very difficult to track. And then also workforce expertise, the change in our workforce as well. So fantastic. Alright, with that I'm going to turn it over to Mike's going to take us through internal controls and risk management. So over to you Louise.

Louise Gannuch: Great, thanks Jen. Let's get over here. So my name is Louise Gannuch and I'm a partner in EisnerAmper's Risk and Compliance Services practice area. I primarily focus on providing internal audit and anti-fraud waste and abuse services to clients in various industries. But I've worked a lot with clients in the public sector the last 17 years. In these upcoming sections, I'm going to spend some time talking through internal controls, technology, automation, and then fraud mitigation. So we have another critical strategic measure here is strengthening internal controls and risk management practices. If you are experiencing any reductions in staff or maybe with your funding now is not the time to reduce your risk management efforts. Similarly, if maybe oversight is shifting from one area to another, you don't want to reduce your overall risk management efforts. Often in the public sector we see funding challenges and we see cutbacks that are needed, but reducing risk management can have a really negative ripple effect. So some of the key areas that we should be focusing on when we're strengthening internal controls and risk management, start with really establishing your clear oversight roles and the responsibilities throughout the grant management process. So that could be your financial management, risk management, any of the monitoring and those qa QC roles. Defining roles and responsibilities really helps reduce duplication of efforts and just some of those inefficiencies that happen when we have those disorganized structures or hierarchies. The main thing, what we're trying to establish there is just the value that comes with clarity.

Another item we want to develop standardized reporting and documentation procedures, and that's again for helping with tracking grant compliance, standardized or uniform systems, whether it's your processes, your documentation, it helps with compliance, but it also streamlines processes, again, reduces confusion and it can help you with better decision making. Another part of strengthening overall risk management is with conducting regular training in all of those key areas. So fraud prevention, procurement, like Jennifer mentioned, allowable costs. Some of those best practices that we're talking about in grant management, the way we think about training is it's part of our overall culture, right? You're empowering your employees with knowledge through training and culture is really a significant driver of behavior. And so it impacts effective risk mitigation and training becomes a component to all of that. This last one, so I'm an internal auditor. I'm always going to shout for internal audits because we want to be proactive.

It would be great if we could perform an internal audit, an audit for all the grants, all the programs, all the things. But if you have high risk funds or perhaps there's an area that you know is of higher risk, maybe for you that's procurement, maybe that's allowable costs. Those could be areas where you perform focused internal audits. Internal audits have they bring objectivity and they bring independence for your operational and compliance risks with federal funds. When you accept them, you are accepting that you will establish and maintain internal controls. The OMB uniform guidance was recently updated and it now includes that you have to document internal controls before it was established and maintain, but document was added as well as maintaining controls related to cybersecurity and then other measures to essentially safeguard information. Internal controls are going to provide you with reasonable assurance that you are managing the awards in compliance with the constitution, your federal statutes and regulations, and then any of the terms and conditions of the award. An important thing here to note is that award conditions aren't necessarily universal. So it is really important that you understand the specifics of the awards terms and conditions. Sometimes we see if there is a history of compliance issues, you might have different terms. If there's any questions about the ability to meet specific performance goals, maybe the terms and conditions are a little different. So really make sure you're not just breezing through those.

The uniform guidance details that internal controls should not must align with the guidance in the standards for internal control in the federal government. So that's fondly called the Green Book, and that's issued by the Comptroller General of the United States or the internal control integrated framework, which is issued by the committee of sponsoring organizations of the Treadaway Commission, which is also known as cso. And so these are leading internal control frameworks and great resources for you if you're looking to either establish, maintain, or evaluate an effective control environment. So here we have a visual representation of the two frameworks that I just mentioned. It is important here to know that this isn't a one size fits all. That's not what internal controls are. And so when you go through these frameworks, you have to consider multiple factors when you are developing or you're assessing your internal controls.

So you could look at your objectives of the program, the regulatory environment that can vary widely size or the organization or the grant, your risk tolerance monitoring activities, it controls compliance requirements, everything can kind of expand. And COSO identifies 17 principles that are related to five components of internal control. And then what the green book does is it adapts these to the government environment. If you're not familiar, the green book is available online for free. You can just do a quick search and it'll walk you through the different components. If one of the components here in the cube or the principles is not effective, or if your components aren't integrated and kind of operating together, then that will potentially result in ineffective control system. So another thing to note there, the level of documentation that you maintain related to internal controls, which you now must maintain, that also varies on complexity.

Documentation of internal controls. We see that in handbooks. We see that in policies and procedures, maybe your code of ethics, your conflict of interest, you have a procurement policy, your performance reports, your cyber supreme agreements, your contracts, your record retention policy, all the things, but they all vary and are entity specific, right? But we see where these typically are capturing our internal controls. And then like Jennifer mentioned earlier, the risk of inaction can be severe, compliance is critical, and there are serious risks associated with non-compliance. We can see additional conditions that get imposed. There could be payments that get withheld, costs can be disallowed either in part or full. And even awards could be terminated or suspended.

So if we know we want to strengthen our internal controls, it's really important to understand what controls are and then their limitations. Internal controls are geared toward objectives. They are a process. It's a tool that helps you achieve your desired outcomes and they are affected by people. So they're not just policies and procedures that just sit up on a shelf and collect dust and they have to be adaptable to the structure. And then the key one here is that they only provide reasonable assurance. Implementing internal controls won't make your organization or your agency bulletproof, but they are part of the daily activities and they are really very important for successful brand management. And then there are limitations, right? So factors like errors, we could have collusion if there's the ability to override management, can override controls, those all can impact your established controls. So it's very important that you're aware of the limitations. So as you design or you are evaluating, you can consider your residual risks and then any of those compensating controls that you want to build in. And then also we have to think about internal controls from a cost versus benefit as well. You can implement the most robust internal control framework, but if it's hindering you to achieve the program objectives, you really need to take a step back and apply some thoughtful consideration.

This next slide here we have a summary of the different types of controls. And so these kind of summarize the different ways that they will intersect. So if we think about a whistleblower hotline that is a detective entity level, semi automated control, if we think about an automated process level, corrective control, you could see that in say a grant management system where there's an automatic of a transaction, the system prevents submission. If an expense exceeds a budget limit, that would be an example bringing those three together. And I'm emphasizing kind of all of these foundational concepts because internal controls are important not only to address compliance requirements and requirements of federal awards, but understanding internal controls plays a really important part in the ability to evaluate for process efficiencies. It helps you identify fraud risks and then performing an internal control analysis.

If you have a mature program, maybe you already have controls established, you might want to consider performing an internal control analysis. This can help you identify any gaps. And again, this could be an area where you don't have to look at everything in the whole universe, but you can focus on specific areas. Maybe for your organization you've noticed that one area is struggling a bit, so you want to dive to understand a bit more. But before you assess the effectiveness of internal controls, you really need to make sure you understand your objectives because we evaluate risks to objectives and internal control analysis can be a really great and valuable tool part of that current state assessment.

Okay, so switching gears here a little bit, but still very much related to what we're talking about is the strategic measure of investing in technology and process improvements and through the entire grant management process. And that helps with better data management, compliance tracking reporting and real time decision making. Managing federal funds efficiently requires streamlined processes and investments, but the degree can vary. So some of the ways we work with our clients in this space is kind of moving from disconnected systems into one grant management system. And this can be really helpful because it can ensure consistency among multiple funding sources. You can implement dashboards for some of those real-time insights and it can help with more timely reporting. If you haven't dived into technology investments and you're not really sure where to get started, a good place to start is by looking at and assessing your current processes, identify what's inefficient in those, what's posing your biggest risks, look at what's a nice to have versus a must, and then you go through the process of identifying the right technology solution. Again, this is not one size fits all, so there's really time and effort involved in this process, so you want to make sure you get the right people involved. That's an important part of this.

You also want to make sure when you make an investment, you are managing the change and then you want to continue to optimize automation and process improvements are whenever they occur, they likely change the way that team members are doing their job or they're doing tasks. And so we have to go back to thinking about the way that processes are documented, how our teams are understanding these changes through training. Everything that we're talking about is really integrated. So here we have another poll question. Does your organization currently use automation tools for grant management? We have a yes. B, no, and C and not sure.

So we'll give everyone some time to respond and I'm just going to look through some questions here. Okay, so one here, our policies need to be updated. How do we do this efficiently? It's a fair question. I would say if you're doing a complete overhaul, I would really start with identifying the team that's going to manage this process and have a governance structure around that policy environment. So this team usually is driving this whole entire process and they're documenting the decisions that make that way into the policy and making sure that they're complying with uniform guidance. As Jennifer mentioned, a lot of these are approached with teams and then also standardized templates are going to be going to be your friend here. So it looks like we have a decent mix based on the responses.

All right, so the next topic here has been talked about quite frequently over the past months in the media, probably more so than I've heard in quite some time, but preventing and detecting fraud, waste and abuse has been a priority and we see it continuing to be a priority. And so as we think about long-term sustainability and responding to increased or the shifting responsibilities, we wanted to make sure that we spent some time talking about fraud and not just fraud, but waste and abuse as well. Improper payments and fraud risks. Those are often prevented in the same way. And the distinction or the classification if you will, really comes back to intent. And that helps us differentiate between fraud and non fraud acts.

So there are generally two ways to approach fraud. You can be proactive where you are assessing risk, you are implementing preventive and detective controls, you perform continuous monitoring, and then you're leveraging technology throughout that entire process and you're really in the fight against fraud or you can be reactive and then you just figure it out. We want to be proactive. If your organization is reactive though, there are things you can do to move to being more proactive. So if we want to be proactive in our anti-fraud approach, we need to be thinking about fraud in the context of prevention, detection and response. Fraud is an area where you have to be strategic and you're actively assessing and managing your fraud risks. So we have three areas here. The first with prevention, so that focuses on lowering the likelihood of fraud occurring. You have detection, which is your effective fraud monitoring processes, and so that's really making sure that fraud when it occurs, it can be reliably and rapidly detected. And then response is what you do once you've been compromised.

One of the key fraud prevention tools that we have is the fraud risk assessment. So I want to spend some time talking through this. It's a structured process and there's some steps here. So we have to identify, analyze, respond, and then we monitor the high level steps that occur throughout. The fraud risk assessment really begins with understanding your current environment. You can conduct structured or unstructured interviews, brainstorming sessions, we've done surveys. You do that with varying levels of employees and different stakeholders and that helps you understand the landscape. Then you follow that by identifying ways in which internal and external fraud could occur. You probably spend most of your time here because you're thinking about not only known fraud but also hypothetical risks, and then you go through the process of categorizing them. So you look at incentives, opportunities, rationalizations, which is all based on the fraud triangle, and that essentially looks at factors that have to be present for fraud to occur. Once you have your risks, you assess the likelihood and impact of each identified scheme, and then you go through the process of ranking them here. If you have budget or resource constraints, the fraud risk assessment can also be a really great tool to help you hone in on those key areas because you're already going through the process of ranking schemes.

You also go through the process of evaluating your current controls that are addressing the risks that you have identified, and then you design a response to those risks to either prevent or mitigate each risk. One of the things with fraud risk assessments, I found having a facilitator can be helpful and again, is making sure someone's driving the process. And then you also want to have people who are knowledgeable, what we talked about, internal controls and then just inherent and residual risks. And then lastly, as shown in the monitor quadrant, this is not a one-time activity. So if you have controls that maybe you're getting eliminated due to restructuring or downsizing, these could come to light in the fraud risk assessment.

There could also be opportunities for collusion, right? If controls change over time and it changes a process, you might not know that your control is not performing as you intended it to. So overall, fraud risk assessments can add a lot of value to an organization, but they don't eliminate all fraud because you can't. And then as you go through the fraud risk assessment process, you also have to keep in mind the balance between the fraud loss that might occur and then the cost of the control. So here we have some best practice preventive controls. These are just examples. So what your entity does or your program might not work for another. There's just a couple I want to highlight here. So the first being the segregation of duties. Often we think about segregation of duties in terms of roles and responsibilities. So we see them documented in a policy or a procedure, but it's important to evaluate segregation of duties and systems as well because a lot of times lack of controls and segregation of duties in systems can contribute to fraud because it directly relates to opportunity, which is part of the fraud triangle of the three factors there.

Opportunity is something you have the most influence over because you can implement controls to reduce opportunity.

The next one I want to touch on is surprise audits. Don't necessarily see this one as often, but it is a great prevention control because it can give you valid insight into the day-to-day. A best practice here, you want to make sure that it's known throughout your organization that you conduct surprise audits. So maybe that's during onboarding or just reminders that go out, even if you end up not doing them as frequently as you'd like to. It does deter wrongdoing to a certain extent. Okay, so we have another poll question here. Does your organization perform a fraud risk assessment? We've got some options for everyone respond to, and I'll look at the questions, see if we have any that are coming through.

Okay, this is kind of more of a comment question. If surprise audits are going to upset employees that that's valid, I think employees might be frustrated, but you have to have a culture of transparency and accountability. So if there's a lack of trust in your organization, it could feel like a punishment, but you really need to frame them in just a normal part of your organization. And it's positive. We are improving processes, we're not trying to catch people, we're auditing processes, not people. Another consideration here if you don't want to upset people is just really look at what departments you do it to. If you continue to conduct surprise audits in one area, then it probably will make some people upset.

So some considerations there. And I think with all audits, even if they are planned, we always want to make sure we have the expectation that anyone who's conducting an audit is professional and ultimately supporting our organizational objectives. All right, so we'll give everyone some more time to respond. All right, so it looks like we have a bit of a spread again, but the most is yes annually with periodic updates. So that, that's great to hear. All right, so now we're moving into detective control examples. Detective controls are controls that help limit the duration of a potential issue. I'll just highlight a couple here in the interest of time. The whistleblower hotline is really your number one for detection, the Association of Certified Fraud Examiners. They are a global anti-fraud organization, and they report that tips are the most common detection method. So if you don't have a mechanism, whether that's an online form or a phone number, an email, make sure you are evaluating so that you can implement one.

Some of the other controls here, so we have automated risk scoring, data analytics and mining, realtime monitoring. Those have all been great, getting more traction in the public sector, and often these types of controls are going to require more of an investment. And in the current environment, artificial intelligence or AI has been really changing the landscape. If you're interested in delving into more about how fraud and AI intersect, I do have another webinar available on demand on the Eisner website. You can search for if you're interested in viewing that. But one of the main things with investments in technology, because it's so data focused, you need to have data integrity, you have to have security over data. Data quality is very important. And then your overall governance over data. Data management is another area where you have to continuously evaluate to make sure you're reflecting changes.

Okay, so our last part of the layered anti-fraud approach is the fraud response plan. Fraud is going to happen whether it's happening right now or it's happening in the future, it's going to happen. Your fraud response plan defines how you will respond to suspicions of fraud. The focus really is on minimizing losses and you are maximizing your potential for success. I have some of the key steps here to consider, but one of the key things I do want to point out is that the plan doesn't outline how an investigation is conducted in every detail. Since every fraud is different, that's not really the purpose of a fraud response plan.

With disciplinary procedures, you want to really make sure those are consistent based on severity. And so make sure you're involving legal and hr, that's a team teams that need to be involved in this plan. And then lastly, with all things evaluated, right, it's a fraud happens. See how your plan worked, adjust where needed and make sure again, you're involving legal in the process. Because really when fraud happens, it's so chaotic. And so the fraud response plan is really designed to reduce some of that confusion because it does provide some clarity. Alright, so here we have our last poll question. What is your organization's top priority for federal funding management in the next year?

Eager to see where this one lands based on our audience feedback. Really, no right or wrong answer. Lemme just give everyone some time to respond. I'll look at some questions. I, someone commented, I'm surprised the mandating of documenting internal controls wasn't mandated beforehand. Interesting. Yes, that is interesting. You would think if you're establishing and maintaining them, you should be documenting them, but at least it's updated now. I, all right, so here we have front runner is compliance readiness, great, and efficiency through technology and automation. Great. So all good answers, and like I said, no right or wrong there.

So we've covered a lot of different strategic measures here and really focused on efficiency and compliance, but the key thing here is really about being adaptable and proactive. So maybe your organization is a status quo, there hasn't been any changes, or maybe you've had tons of changes from your personnel to your processes responsibilities, and you're not really sure where to begin in either way. We really encourage our clients and just everyone to be proactive in assessing grant management processes and just being flexible with change. We know that many organizations are just doing more with less. If you don't have that capacity to perform a federal funding risk assessment like Jennifer or the fraud risk assessment or an internal control analysis, you can consider working with external consultants or with your peer organizations strategy and strength in all organizations. It's not just about following rules and being compliant, it's really about building resiliency for or what's next. So with that, we are at the hour, but we really appreciate everyone's time today. We hope you enjoyed the webinar and got some key takeaways for you. And thank you so much for attending.

Transcribed by Rev.com AI

 

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