Transcript for audio podcast: Rules for HHS Grant Officers
From the Office of Inspector General of Department of Health and Human Services
I'm Laura Canfield and I'm an attorney in the HHS Office of Inspector General.
You as HHS grant officers can do a lot to help minimize the risk of fraud, waste, and abuse in HHS grants, and ensure that the people who need help get it.
As you know, HHS is the largest grant-making organization in the Federal government, awarding about 60 percent of the Federal government's grant dollars.
HHS administers more than 300 different grant programs providing benefits and services to the neediest and most vulnerable segments of our society. Fraud, waste and abuse undermine these programs. Awarding agencies' weak internal controls over grants management is often part of the cause.
As HHS grant officers you can do something about it. In the pre-award phase, you need to make sure that the grant applicant knows what to do and will be held accountable. In the grant announcement you should use certifications relating to specified activities or requirements.
The grant applicant should confirm in writing that it is aware of these requirements and intends to comply with them. Certifications are especially useful for newer grantees with limited or no experience with grants.
For example, Superstorm Sandy grantees could be required to certify that funds provided by HHS will not be used for costs reimbursed by other sources such as FEMA or private insurance.
Once grantees know about specific requirements, they should put policies and procedures in place. These will reduce the risk of fraud, waste and abuse.
Another thing you should do is issue grant application guidance, preferably in tandem with the grant announcement. The guidance should be user-friendly and include detailed instructions.
For instance, guidance might show applicants how they will need to use outcome-based information by providing examples of completed work plans. This kind of clarification in the pre-award process will help grant recipients provide you with essential information, so you can more effectively monitor their grants.
You should also thoroughly and critically review grant applications. Grant applications should contain full explanations of how the grantee intends to meet all requirements. You should pay particular attention to the prospective grantee's performance capabilities and its financial system.
In the past, OIG reviews have shown that some HHS grantees have not had, or have not operated, their financial systems properly. These reviews often result in costly audit disallowances. So you should make sure that the design of a prospective grantee's financial management system will ensure that money is spent in accordance with applicable grant requirements.
After HHS funds are awarded it is your job to see that program funds are spent appropriately. Your primary oversight tools are progress reports, site visits, and frequent communications with grant recipients.
Review progress reports periodically. They contain valuable insights into how well the grant project is operating and whether the grantee is meeting interim goals and objectives. If progress reports are reviewed early in the grant period, some problems like charging unallowable costs can be identified and prevented from happening again.
Site visits let grant officers see for themselves what grant recipients are doing and engage in conversation. As a result of your observations you may require grantees to prepare an action plan to correct problems.
Site visits can be particularly helpful for new grantees. For example, a site visit might be the only way to identify and fix unsafe conditions that exist at a child care facility funded by Head Start.
An open line of communication with a grantee is essential. This is how you share information, provide technical guidance, identify and resolve emerging issues involving potential budget adjustments or program changes, and answer grantee questions.
How do you open this line of communication? You may want to develop frequently asked questions for grantees about program requirements. You could conduct training relating to applicable Federal laws, regulations and policy.
And you can disseminate guidance through webinars, podcasts, or slide shows.
As HHS grant officers you have a vital role to play. Your work helps preserve the public's trust by ensuring that grant awards are used properly and provide help to the people who most need it. Thank you for listening and for doing your part to help prevent grant fraud, waste and abuse.
If you suspect fraud involving an HHS grant, we want to know. Contact us at 1-800-HHS-TIPS or on the web at oig.hhs.gov.
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