A new FAQ is out for the overall regulations for spending of federal grant funds — Uniform Guidance found in 2 CFR 200 (and mirrors the regs from our HHS funder at 45 CFR 75). You can find the full text here, where over 140 questions are addressed, but let’s look at a few key ones over the next few posts.
Q-8. What is a risk-based framework that is used to alleviate compliance requirements? A risk-based framework is a critical component of a Federal awarding agency’s performance management framework, particularly as it relates to a Federal program. It helps identify risks that may affect advancement toward or the achievement of a project or sub-project’s goals and objectives. In addition, integrating risk management practices can assist Federal managers to determine an appropriate level of resources and time to devote to project oversight to monitor recipient progress and hold them accountable for good performance. A risk-based framework could also help Federal awarding agencies develop risk mitigation strategies emphasizing strong performance, and reprioritizing routine post award monitoring and oversight strategies. (See§200.102(d).)
If you haven’t looked at a process for identifying and responding to risks, you need to. When you identify risk you can monitor and mitigate those risks more easily. I suggest a risk management plan that includes compliance, safety and service provision risks, and may look a little like this.
Risk Management Plan worksheet:
| Identified Risk | Current mitigating measures | What needs to be done | How to monitor long term |
| Someone is injured on the property | Liability insurance Safety postings around any work/wet surface | Uneven surfaces repaired. | A regular slip/fall inspection. |
| Staff member sues for unfair bias. | Staff training for all managers addressing bias, rights, justice. | Require annual retraining. | Designate a point person to discuss issues as they arise |
While we usually suggest you “think positive”, for this process you and your leadership need to bring your disaster fantasies to the table. What are all the things that might go wrong and how can you reduce or remove the risk?