
Effectively navigating compliance requirements helps avoid adverse consequences and improves your organization's readiness for future funding.
There are three final compliance requirements that we need to cover in our federal grant compliance series. Eligibility (E); matching, level of effort, and earmarking (G); and program income (J) are all nuanced compliance requirements that can vary significantly from program to program.
As always, you should review your grant agreements and the compliance supplement to gain a better understanding of how you should be managing these requirements.
Eligibility
Sometimes awards limit which individuals, groups, or subrecipients can participate or receive services under a program. The restrictions will vary across programs, but often require an assessment of income, location, or class of characteristics. Embedded within this requirement is the need to assess the eligible party and to confirm they are receiving the correct benefits based on their eligibility status.
More from this blog series
Have a series of reviews to verify initial eligibility determination is accurate and properly documented, that eligibility is re-reviewed and renewed, benefits are accurately calculated, and benefits are discontinued once participants leave the program or are no longer eligible.
Matching, level of effort, earmarking
This area covers a series of requirements that all relate to constraints and limitations on money management. Matching requires contributing additional amounts to a program’s cause beyond the federally awarded amount. Level of effort includes requirements for:
- A specified level of service to be provided from period to period,
- A specified level of expenditures from particular sources to be maintained from period to period, and
- Federal funds used to supplement and not supplant non-federal funding of services.
Earmarking requirements specify a minimum and/or maximum dollar amount or percentage of specific activities or specific types of participants that the program provides/serves.
These requirements are often monitored as part of the budgeting and reporting processes, so it is important the person reviewing those documents is aware of all “G” requirements.
Program income
When gross income is generated by a program-related activity, it must be used to either:
- Reduce the federal funds committed towards allowable costs,
- Meet cost sharing or matching requirements, or
- Be added to the federal award (however, this option requires federal approval).
Program income can be any number of things, including fees for services performed, rental income, and sale of commodities.
Keep documentation supporting the program income collected and used, and implement reviews over those processes.
How CLA can help with compliance requirements
We offer a wide variety of grants management guidance and services. Review our grant compliance services page or contact us to discuss the specific needs of your organization. We are happy to help with questions, big or small!
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