The HHS Grant Management Process reflects established policies and regulations and is designed to ensure that grants serve the American public's interest in well-managed grant programs. Specifically, the process ensures that:
- grants are properly planned;
- competition is open and fair;
- proposed budgets are carefully scrutinized;
- grant awards are negotiated and structured to protect the interests of the government;
- recipients are given the assistance and support they need to succeed;
- awarded grants are carefully monitored and adjustments made, as necessary, to solve problems that arise;
- and conflicts with recipients are constructively resolved
The Grant Management Process describes the steps related to the management of competitive grant awards. Many grant awards, however, are noncompetitive. (Noncompetitive awards include new awards, extensions, continuations, and supplements.) The process for managing noncompetitive grant awards differs in that there is no requirement for an announcement, and the technical evaluation process is either unnecessary or is significantly abbreviated. The other steps in the Grant Management Process, however, are still required for noncompetitive grant awards. Here are the basic steps:
In preparation for a Funding Opportunity Announcement (FOA), an HHS Grants Management Office performs various activities required for implementation of an HHS grant program. An HHS Program Management Office will identify program priorities and timelines in coordination with their respective grants management office. The planning activities include:
- Identifying the program goals, objectives, and available resources.
- Determining the grant mechanism best management office, suited to meet program goals (e. g, discretionary grants, cooperative agreements, mandatory grants).
- Identifying and planning for special grants management requirements (e.g., developing a new application kit, planning for pre-award site visits, organizing an orientation session for potential recipients),
- Developing long-term plans and schedules for announcing and awarding grants (A key objective of the planning process is to ensure awards are phased over the fiscal year, avoiding an unmanageable workload surge in the fourth quarter.)
The Program Management Office develops the Funding Opportunity Announcement (FOA) and/or Requests for Assistance (RFAs) that accurately reflect program goals, requirements, and timetables. The Grants Management Office reviews and approves the FOAs and/or RFAs to ensure compliance with laws and regulations, as well as with sound business management practices.
Grant proposals are solicited from the public through FOAs or RFAs. Announcements describe the programmatic and business management requirements of the grant program. Announcements typically are published in the Federal Register, except announcements for many of the Department's research and research training programs, which are published in the NIH Guide for Grants and Contracts. HHS also publishes every FOA and/or RFA on Grants.gov along with 25 other Federal grant-making agencies.
The application evaluation activities include the receipt and review of grant applications submitted by potential recipients. The Grants Management Office oversees the review and evaluation of grant applications to ensure outside reviewers and agency personnel comply with management policies and regulations, and with sound business management practices.
The Program Management Office evaluates grant applications for their programmatic value and determines which applications best meet program goals and offer maximum potential for success.
This involves receiving and officially logging incoming grant applications. Applications are screened (usually against a checklist) to ensure they are properly completed. The Grants Management Office receives and screens the grant applications for completeness and eligibility of the applicant. This function may be centralized and/or supported by contractor effort.
This involves evaluation of the technical aspects of grant applications through the objective review process. After the technical evaluation is completed, a preliminary decision is usually made and documented on a technical merit rankings list. The Grants Management Office advises objective review groups and individuals in the proper procedures to follow in conducting the independent/objective review and/or checks for violations of procedures. The Program Management Office provides technical experts who participate in the independent/objective review and develop the technical or merit rankings list, unless the evaluation is performed by an individual office (e.g. NIH Center for Scientific Review).
This involves evaluation of the business management capability of applicants based on information contained in the application, additional information as requested, and a review of prior performance as a recipient. If necessary, a pre-award business management review is conducted (usually on-site). This step also involves reviewing the application to ensure it complies with the applicable regulatory or statutory requirements (e.g., to ensure all required assurances have been provided). The Grants Management Office performs business management evaluation activities. The Program Management Office assists the Grants Management Office as requested.
This involves conducting a detailed cost analysis of the proposed budget submitted by the grant applicant to determine if costs are allowable, allocable, and reasonable. The Grants Management Office performs cost analysis activities. The Program Management Office assists the Grants Management Office as requested, particularly by assessing the impact of cost issues on technical aspects of the grant.
The negotiation process may be minimal or may involve negotiating all aspects of the grant award with the applicant It may involve explaining to the recipient that the budget must be changed to comply with regulations. Or it may involve a comprehensive give-and-take negotiation of all aspects of the award, including the scope of work, the budget and the terms and conditions. The Grants Management Office represents the government in all negotiations with recipients. The Program Management Office will provide information and/or participate in negotiations, in coordination with the Grants Management Office.
The award process involves the preparation of the Notice of Award (NoA) and officially obligates funds for the grant. The NoA describes all terms and conditions of the award, including reporting requirements. NoAs are usually generated through an automated system and electronically transmitted to the budget office to obligate funds for the grant. A printed copy of the NoA is distributed to the recipient. As part of this step, required files (usually an official grant file and an institutional file) are created and/or updated for each grant/recipient.
The Grants Management Office prepares and signs the grant award, certifying that the award complies with all legal, regulatory, and internal policy requirements and that it is a sound business agreement into which the Department should enter. The NoA is then distributed to the appropriate key offices. The Program Management Office, although not required by Departmental policy, usually signs the grant award, certifying that the award will contribute to the programmatic goals and that the activities funded under the award are technically and programmatic sound.
Post-award monitoring of recipient performance includes:
- Tracking receipt of required financial and progress reports.
- Reviewing these reports to identify performance or financial deficiencies.
- Maintaining records of all communications with the recipient, including correspondence and telephone or on-site contact.
- Conducting site visits when necessary to closely investigate problems or deficiencies identified through analysis of reports.
- Responding to requests for amendments to the grant.
The Grants Management Office performs post-award monitoring activities including site-visits, reviewing reports, etc. The Program Management Office monitors the technical progress and performance of the recipient through review and analysis of project reports and through on-site reviews.
Formal actions involve signing and issuing official documents (time period, funds, scope), modifying grants, or taking other corrective actions (e.g., suspensions, disallowances).
The Grants Management Office evaluates circumstances necessitating post-award action and advises the Program Management Office on options. The Grants Management Office also issues appropriate documents, including notices of suspending and/or terminating grants, certifies that such actions are in compliance with legal, regulatory, and policy requirements and are consistent with sound business practices. The Program Management Office evaluates circumstances necessitating post-award action and recommends or jointly approves specific action in consultation with the Grants Management Office and based on an assessment of the impact of the action on programmatic goals.
Audit resolution involves reviewing required periodic audits of recipients and determining how to respond to audit findings. It also includes explaining to recipients actions they must take in response to audit findings and following up to ensure the actions are implemented.
The Grants Management Office ensures that recipients comply with audit requirements and document actions needed to resolve audit findings. It ensures that recipients complete followup actions. The Program Management Office provides information and consultation to the Grants Management Office as required and takes necessary follow-up action as requested.
Conflict resolution involves settling disagreements that may occur with recipients, including formal appeals. The Grants Management Office works with recipients to achieve informal resolution of disputes (alternative dispute resolution). For formal disputes, the Grants Management Office takes the lead in researching case history; conducting background analyses; and providing expert advice and testimony. It also ensures the availability of a complete and accurate official grant file. The Program Management Office works with recipients to achieve informal resolution of disputes. For formal disputes, the Program Management Office provides information and consultation to the Grants Management Office.
Closeout involves reviewing expiring grants to ensure all requirements are met, obtaining certification from the Program Management Office that programmatic objectives have been met, resolving any known business management issues (e.g., ensuring costs are allowable, ensuring proper disposition of property purchased with grant funds), and ensuring that the grant file is complete.
The Grants Management Office takes the lead in conducting final business review of completed grants; ensures final reports are submitted and approved; makes adjustments disallowances or other action as appropriate; and officially closes the grant. The Program Management Office ensures and documents that programmatic objectives are met, provides additional information and consultation to the Grants Management Office as required, and takes necessary follow-up action as requested.