Insights

Under the Uniform Guidance, the moment a federal award is made, the process by which your organization selects and pays any contractor, consultant, or vendor becomes a regulated activity. [...] And if that process was not followed, the costs associated with those contractors can be disallowed, meaning your organization may be required to repay them from non-federal funds.

Organizations are still referencing compliance policies built around a regulatory framework that no longer exists. Staff are being trained on citations that have been rescinded. And when monitoring visits and audits arrive, the gap between what an organization's written policies say and what the current governing regulation requires is itself a compliance finding.

Federal compliance findings are rarely about talent. They are about structure: who owns what, what systems are in place, and whether the people responsible for compliance have the bandwidth and authority to actually do it.

Federal grant management is a separate discipline, governed by the Uniform Guidance at 2 CFR Part 200, enforced through audits and monitoring visits, and capable of producing repayment demands, award terminations, and lasting reputational damage with federal agencies when organizations are not prepared.