BOB LLOYD is a respected authority on policies and practices affecting the award, administration and oversight of federal grants, contracts and subawards. Mr. Lloyd has nearly 40 years of experience in federal award implementation. Prior to starting his management consulting practice in Washington, D.C., in 1982, he served as the executive director of the Grants Management Advisory Service and held staff positions in two large federally funded organizations. Since then, he has been a consultant, trainer or advisor to award and audit units in sixteen federal award-making departments and agencies, and to recipient and subrecipient organizations and their professional advisors located in all 50 states, the District of Columbia, several U.S. territories and 18 foreign countries. He is the principal author of several reference works on federal grants management and audits, and currently serves as contributing editor to Federal Grants News and Federal Auditing News, published jointly by Atlantic Information Services and NACUBO. He also is a Charter Life Member of the National Grants Management Association and served on its Board of Directors for five years.
Contact Bob Lloyd at firstname.lastname@example.org.
On Site Grant and Subgrant Management Training
Built on more than three decades of training federal grantor agencies and grant recipients, subrecipients and their advisors, a variety of well-conceived and “road tested” grant and subgrant management courses is available. These courses cover standard topics such as the details of governmentwide grant administration and cost accounting requirements contained in Office of Management and Budget (OMB) Circulars A-102, A-110, A-21, A-87, and A-122 and the grant oversight and audit requirements arising out of OMB Circular A-133. They also cut across the entire life cycle of a federal grant and subgrant award, dealing with topics like preparation of project narratives and grant budgets, pre-award due diligence, management system development, subaward management and oversight, creation and retention of grant expenditure documentation, timely accurate reporting, and effective close-out. Offerings can be tailored to the desired topical coverage and course duration as well as to audience type and level of experience.
Grants Policy and Procedure “Audits”
The policy and procedure manuals of organizations that receive federal grant and subgrants are too often the repository of requirements that someone put in there years ago because they believed that the federal government required them. The problem is that those requirements may have taken on a long life of their own and current policymakers and staff fear that, if the requirements are pruned down or removed completely, many bad things might happen. Meanwhile, the cost grows of continuing to inform everyone affected about the requirements, to monitor to find out whether they are being followed, and to enforce them when they are not. A grants policy and procedure “audit” is a professional and knowledgeable review of an organization’s policies on such matters as financial management, procurement, property management, subgranting, and records development, access and retention. The “audit” objective is to clarify what features are truly required, which ones make sense administratively, which ones are “nice to have,” and which ones have outlived any of those purposes. The intended result is long-term administrative cost savings.
Compliance Program Development and Enhancement
There is little question that the establishment and use of a multi-faceted compliance program is a tool that some of the most effective recipients of federal grants and subgrants have employed. They’ve recognized the willingness of the federal government to impose specific requirements for compliance programs in other sectors, such as health care, as reason to develop their own. They’ve concluded that a proper combination of competent staffing, clear policies and procedures, training, monitoring, and enforcement, tailored to the particular environment, holds the best chance of helping a federal assistance recipient stay out of trouble. And, if trouble arrives, they know that the presence of an organized compliance program has often been viewed by federal officials as a mitigating factor that can help show that procedural missteps were isolated incidents rather than systemic failures … and that Draconian corrective measures are not warranted. Professional assistance that relies on long experience about which compliance program features actually work and which are simply “window dressing” can help assure that the accountability and transparency atmosphere in your organization is top notch.
Audit Resolution Services
There are few things associated with the administration of federal grants and subgrants that are causing more angst than audit findings. Whether they arise from audits conducted in accordance with Office of Management and Budget Circular A-133 or those performed by federal inspectors general or any of their “duly authorized representative,” assertions that noncompliance with laws, regulations or agreement terms has occurred or that significant deficiencies or material weaknesses exist in an organization’s internal controls are generating lots of headaches. Effectively responding to audit findings early and at each stage of their development and issuance is critical. That means accurately assessing whether the conditions identified are accurate, the criteria used for making judgments are appropriate, the effects are consequential, the causes are accurate and the recommendations will correct the problems. That sometimes involves the uncomfortable step of challenging the quality of the auditor’s work. To take on those tasks, it’s often advisable to have some experienced help with detailed knowledge about applicable auditing standards for field work and reporting and about federal grant compliance criteria. With a record of having helped overturn more than $15 million in questioned federal grant costs and numerous procedural findings, Bob Lloyd may be someone you want at your side during an exit conference, or when a draft audit report hits your desktop.
Indirect Cost Rate Development
There are few concepts in federal grants management that are more widely misunderstood than indirect costs. The misunderstanding cuts across the entire spectrum of those involved with these awards, from Congress all the way down to the lowliest subgrantee, and from the media to the average taxpaying citizen. And because there is a lot of misinformation floating around, staff members of grantee and subgrantee organizations might be intimidated into thinking that the development, presentation, submission and negotiation of indirect (facility and administrative) cost rates with the federal government is something that needs to be fully delegated to someone else. Not so! Federal Fund Management Advisor offers a different approach which builds on the knowledge of an organization’s own staff members about existing internal organizational relationships, policies and procedures, and charging practices to help guide the indirect cost recovery process in an effective cost-sensitive manner.
On-Call Compliance Assistance
Even experienced federal fund managers run up against confounding questions that they may have trouble answering. Or they encounter an issue where possible interpretations fall across a range from “very risky” to “safe but sorry.” The confusion or doubt can generate both delay and internal organizational conflict that undercuts effective performance and administration of federal grant awards. And, in the current highly charged federal fund accountability atmosphere, missteps can be dangerous. That’s why, when those situations arise, it can be comforting to have another experienced administrative professional to call on—to respond to questions, document the answers, and explain requirements and best practices to policymakers and colleagues. Bob Lloyd, Principal of Federal Fund Management Advisor, provides that kind of “back stop” assistance to clients.
Government Relations and Advocacy
While there are a few restrictions on the use of federal grant funds for lobbying, organizations that seek and obtain these federal awards are nonetheless able to conduct some government relations activities, particularly when federal legislative or executive branch officials issue invitations to participate in the policymaking process. These can come in the form of opportunities to present testimony or ideas to legislative hearings or to comment on proposed regulations or other executive branch policies. When those opportunities arise, it is sometimes advisable to seek the assistance of a seasoned government relations professional with deep knowledge of existing federal government policies and the ability to assess the impact that new or changed requirements would have.