This report is intended for the internal use of the City of Stockton , and may not be provided to, used, or relied upon by any third parties.
Proprietary & Confidential
FINAL REPORT
City of Stockton
GRANTS MANAGEMENT EFFICIENCY STUDY
February 2023
Moss Adams LLP
999 Third Avenue, Suite 2800
Seattle, WA 98104
(206) 302-6500
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2022 Grants Management Efficiency Study
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Table of Contents
Executive Summary 1
A. Background, Scope, and Methodology 1
B. Summary of Observations and Recommendations 1
Introduction 4
A. Background 4
B. Scope and Methodology 4
C. Commendations 5
Observations and Recommendations 6
A. People Solutions 6
B. Process Solutions 11
C. System Solutions 20
Appendix: Sample Resources 24
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EXECUTIVE SUMMARY
The City of Stockton (the City) engaged its internal auditor, Moss Adams LLP, to conduct an independent assessment to determine the efficiency of the City’s grant management processes. The assessment provides an objective perspective into the opportunities for improvement that exist across the City and serves as a tool for management to prioritize initiatives. These observations and recommendations were developed based on interviews with City leadership and staff, as well as a review of data and documents provided by the City.
This assessment was conducted between September 2022 and January 2023. For most of the duration of this project, the City’s Grants Manager was an active participant in this process and provided feedback to these findings before that individual left the City in November 2022.
Observations and recommendations are grouped into three areas as defined below: 1) People Solutions, 2) Process Solutions, and 3) System Solutions.
People, process, and system solutions observations and recommendations are summarized below and detailed discussion is provided in Section III of this report.
OBSERVATIONS AND RECOMMENDATIONS
PEOPLE SOLUTIONS
1. Observation
T
he City is shifting its grant management approach from primarily decentralized to a hybrid model. This transition will require strong leadership support to be successful.
Recommendation
A. Ensure that the Grants Manager position has strong and active support from the CMO and other senior leadership within the City to make necessary changes and ensure staff accountability.
B. Develop a plan to proactively manage the shift from COVID funding to a more sustainable funding model.
C. Explore options to develop an internal method or approach to evaluate grant opportunities, including appropriate estimation of required staff capacity to support each grant. The CMO should be actively involved in this process, as it is frequently the nexus for incoming opportunities and/or requests from City Council.
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OBSERVATIONS AND RECOMMENDATIONS
2. Observation
T
he City has taken the positive step of hiring Grants Manager and Grants Analyst positions to provide centralized support for grant-related activities.
However, staffing limitations remain, and there is confusion around the intended responsibilities of the new positions.
Recommendation
A. Consider reviewing staffing levels within departments or divisions that are heavily involved in the grant management process (including Public Works, Economic Development, and Procurement) to ensure sufficient capacity to effectively accomplish related work.
B. Clearly document and communicate the roles of the Grants Manager and Grants Analyst to all departments.
PROCESS SOLUTIONS
3. Observation T he City is making progress in developing comprehensive grant policies and procedures, but some gaps remain.
Recommendation
A. Continue efforts to update, adopt, and roll-out grant-related policies and procedures.
B. Develop more informal reference guides or other resources to explain grant-related processes, roles, and responsibilities to City staff in a user- friendly format.
4. Observation H istorically, grant processes have varied widely by department, which has created inefficiencies and increased the City’s risk.
Recommendation
Continue current efforts to improve the consistency and efficiency of grant- related processes. Taken as a whole, these efforts should help to expand staff knowledge, increase process consistency, and reduce risks.
5. Observation O ver the past decade, the City has struggled to provide adequate grant management training to staff.
Recommendation Develop a standardized grant management training for all staff who are involved with grants management.
6. Observation
W
hile the City is in the process of implementing more robust centralized oversight of grant compliance, there are ongoing challenges related to data accuracy and consistent system use.
Recommendation
Continue efforts to:
A. Develop and implement clear guidelines about which elements of compliance and reporting will be performed by the centralized Grants team and which will be the responsibility of department personnel.
B. Establish centralized grant oversight reporting tools.
C. F ully implement and utilize Tyler Munis as the grant system of record.
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OBSERVATIONS AND RECOMMENDATIONS
7. Observation
I
nstitutional knowledge of interdepartmental collaboration has been eroded by staff turnover and procedural confusion. As the City shifts its grants management approach to a hybrid model, the Grants Manager can play an important role in rebuilding City-wide confidence in this area.
Recommendation Document roles and responsibilities, including clarification on the role of the Grants Manager.
SYSTEM SOLUTIONS
8. Observation
T
he City is actively implementing Tyler Munis to serve as its ERP and system of record for grant management. Currently, each department is using slightly different approaches toward grant data, largely due to the difficulty of the transition to Tyler Munis. As a result, Tyler Munis is not yet generating accurate and reliable information.
Recommendation
Continue efforts to fully transition into the Tyler Munis system for all grant- related data and actively work with departments to ensure the system is serving its intended purpose.
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INTRODUCTION
The City of Stockton engaged its internal auditor, Moss Adams LLP, to conduct an independent assessment to determine the efficiency of the City’s grant management processes and to identify opportunities for improvement that exist across the City.
As part of an ongoing process improvement effort, this study is intended to provide an objective perspective into the opportunities for improvement that exist across the City and serve as a tool for management to prioritize initiatives. This assessment was conducted between September 2022 and January 2023. Analysis was informed based on interviews with City leadership and staff, a review of data and documents provided by the City, and comparison to industry best practices. The project consisted of four major phases:
• Project Initiation and Management: This phase concentrated on comprehensive planning and project management. It included selecting employees to interview, identifying documents to review, communicating results, and establishing regular reports on project status. • Fieldwork: This phase included interviews, document review, and best practice research. We worked with City leadership to obtain the most up-to-date information and insight available. ○ Interviews: This phase included interviews and focus groups with over 20 employees—including the Deputy City Manager, the Chief Financial Officer, and the Grants Manager, as well as Directors, Program Managers, Budget Analysts, Accountants, Finance Officers, and Administrative Analysts from departments that manage grants. ○ Document review: We reviewed documents including City-wide grant administration policies and procedures, job descriptions for City employees involved in grants management and/or compliance, reports tracking grants compliance, documentation of the current technology systems used by the City for tracking grants management and/or asset management, and others. ○ Best practice research: Based on identified opportunities for improvement, we conducted research on best practices for grants management.
• Analysis: In the assessment phase, we evaluated the importance, impact, and scope of our observations within the context of the information we gathered to develop actionable recommendations.
• Reporting: We concluded the project by reviewing draft observations and recommendations with City leadership to validate facts and confirm the practicality of our recommendations.
For most of the duration of this project, the City’s Grants Manager was an active participant in this process and provided feedback to these findings before that individual left the City in November 2022.
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Based on the insights gathered through interviews and document review, it is evident that the City’s grants management process has many commendable organizational attributes. Some examples are provided below:
• Positive Progress: The City has been making active progress to improve the grant management process. This is demonstrated in the investment in new grant-related positions, development of digital workflows within the Tyler Munis system, and efforts to update relevant policies and procedures. • Support for Grants Manager Position: Most interviewed staff reported highly positive feelings about the new Grants Manager position and hope for both a strong working relationship with their department and more clarity and efficiency within the grant management process. • City Engagement: City leadership and staff are passionate about their work, dedicated to serving the public, and excited about the services that grants can help them offer.
We would like to thank City leadership and staff for their willingness to assist in this assessment.
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OBSERVATIONS AND RECOMMENDATIONS
Based on the input gathered from interviews, document review, focus groups, and surveys as well as comparisons to best practices, we prepared a comprehensive set of findings and recommendations, which are presented in the three areas previously described.
1. Observation The City is shifting its grant management approach from primarily d
ecentralized to a hybrid model. This transition will require strong leadership support to be successful.
Recommendation A. E nsure that the Grants Manager position has strong and active support from the CMO and other senior leadership within the City to make necessary changes and ensure staff accountability.
B. Develop a plan to proactively manage the shift from COVID funding to a more sustainable funding model.
C. Explore options to develop an internal method or approach to evaluate grant opportunities, including appropriate estimation of required staff capacity to support each grant. The CMO should be actively involved in this process, as it is frequently the nexus for incoming opportunities and/or requests from City Council.
Historically, the City has functioned with a largely decentralized and siloed grant management process.
Each department has been responsible for developing their own internal processes and systems to support their grants. However, the City has received increased levels of grant funding in the last few years, particularly COVID-19 relief funds. Due to the increase in grant activities, the City is making concerted efforts to create more centralized resources to support consistent grant management and grant making across the City.
Interviewed staff reported both optimism and concerns around this effort. Notably, employees appeared to be very interested in additional tools, resources, and documented processes and procedures.
However, there were significant concerns that additional coordination would increase workloads for staff who are already at capacity.
The recently established Grants Manager position is housed within the Administrative Services Department, rather than the City Manager’s Office (CMO). This structure makes sense from a functional perspective but some staff raised concerns that the Grants Manager would be severely hindered without active support from the CMO.
In addition, the City has not yet created an overarching strategy related to two important areas of grant management:
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• Transitioning off of COVID Funding: The City has received a significant increase in grant funding due to COVID-related impacts within the past two years, but has not yet developed a plan for how to transition away from this funding.
• Grant Opportunity Selection: The City has not yet developed a standardized approach or criteria for when and when not to pursue grant opportunities. Instead, each department director makes that decision. While it is best practice to ensure a certain degree of autonomy, as individual department directors know their subject matter most closely, interviewed staff noted that there is sometimes confusion about when it is a good use of staff resources to pursue or implement a grant opportunity.
Some staff reported that City leaders sometimes appear to lack a full understanding of the level of staff support implementing a given grant will require, which can lead to situations where grant funding is secured but there is limited or no staff capacity to appropriately focus on implementation. This is particularly true within departments like Public Works, where there are many possible grant opportunities, and the process to vet each opportunity requires significant investment of staff time.
Recommendations
A. Ensure that the Grants Manager position has strong and active support from the CMO and other senior leadership within the City to make necessary changes and ensure staff accountability.
While we do not see the need to shift the location of the Grants Manager to the CMO, the Grants Manager will need strong and active support from the CMO and other senior leadership within the City in order to make changes to established processes and ensure that staff are held accountable to adopting new policies and procedures. Employees will need to be held accountable to adopt new change.
B. Develop a plan to proactively manage the shift from COVID funding to a more sustainable funding model.
As the City’s COVID-related funding decreases, the City should develop a plan to proactively manage the shift to a more sustainable grant portfolio that will allow the City to retain its current levels of community service. The plan may need to address both potential future funding sources and changes to current services if funding is reduced.
C. Explore options to develop an internal method or approach to evaluate grant opportunities, including appropriate estimation of required staff capacity to support each grant. The CMO should be actively involved in this process, as it is frequently the nexus for incoming opportunities and/or requests from City Council.
Standardizing the internal method to evaluating grant opportunities (even through a simple tool like a basic checklist) will help ensure that the CMO and City staff are operating under the same assumptions when discussing staff capacity and the feasibility of both pursuing and managing grant opportunities.
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2. Observation The City has taken the positive step of hiring Grants Manager and Grants Analyst positions to provide centralized support for grant-related activities. However, staffing limitations remain and there is confusion around the intended responsibilities of the new positions.
Recommendation A. Consider reviewing staffing levels within departments or divisions that are heavily involved in the grant management process (including Public Works, Economic Development, and Procurement) to ensure sufficient capacity to effectively accomplish related work.
B. Clearly document and communicate the roles of the Grants Manager and Grants Analyst to all departments.
As noted in the Leadership Support and Strategy se ction , the City has historically operated with a largely decentralized staffing model for grant management where each department has been responsible for hiring staff to support all phases of the grant management lifecycle. These activities have been supported by the Administrative Services Department (ASD) Procurement, Accounting, and Budget teams, who assist with processing purchasing and financial transactions.
Most departments have divided responsibilities between positions that support the fiscal management of t
he grants and positions that support the programmatic implementation of the grants. However, this structure varies from department to department, depending on specific needs. For example, given the nature of their grant funding, the Fire Department does not need to utilize any dedicated position for programmatic implementation.
The following is a list of the positions within the City that have been tagged as supporting the fiscal and programmatic management of grants. Each row in this table represents one FTE. In addition to these roles, there are other staff who support various elements of programmatic implementation.
DEPARTMENT/DIVISION POSITION TITLE
Administrative Services Department – Administration Chief Financial Officer Administrative Services Department – Budget Senior Budget Analyst Administrative Services Department – Accounting Accountant II Administrative Services Department – Accounting Supervising Accountant Administrative Services Department – Grants Program Manager III (Grants Manager) Administrative Services Department – Grants Grants Analyst City Manager’s Office Program Manager III
Community Development Department Program Manager II
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DEPARTMENT/DIVISION POSITION TITLE
Community Services Department Program Manager III
Community Services Department – Library Senior Administrative Analyst Community Services Department – Recreation Senior Administrative Analyst Economic Development Department Program Manager III
Economic Development Department Senior Administrative Analyst Fire Department Program Manager II
Fire Department Program Manager II
Municipal Utilities Department Finance Officer
Police Department Administrative Analyst II
Police Department Program Manager II
Police Department Director of Fiscal Affairs and Planning Public Works Department Program Manager III
Public Works Department Senior Administrative Analyst
The City has experienced a high level of employee turnover within the past several years, which has resulted in a loss of institutional knowledge around grant management activities in many departments. In addition, as noted within the 2022 Enterprise Risk Assessment, the City’s lean staffing model, combined with increased turnover and difficulty with recruiting, has resulted in capacity challenges across the organization. In tandem, the City has also experienced a significant increase in grant funding, largely due to the impacts of COVID-19. For example, the Economic Development Department (EDD) has seen an increase in grant funding from around $20 million in 2020 to over $150 million in 2022. However, they have not commensurately increased staffing support. Taken as a whole, this has resulted in:
• Inconsistent levels of staff knowledge and experience related to managing or implementing grants, which increases the City’s risks of inefficiency and non-compliance • Insufficient staff capacity to efficiently secure, manage, and spend grant funding, which increases the risks that the City may have to return funding
To mitigate some of the issues mentioned above, the City hired both a Grants Manager and Grants Analyst position in 2022. The EDD is partially funding both roles—in total, the two positions are 53.5% funded by EDD. As part of this set-up, the Grants Manager position is meant to dedicate around 50% of their time to directly support EDD and the Grants Analyst position is meant to dedicate 65%. While this is a practical solution given the City’s desire to keep staffing costs low, this did raise concerns for some Attachment A
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interviewed staff regarding whether these roles would have sufficient capacity to appropriately support City-wide efforts and whether they might be discontinued in one or two years when funding from EDD is lowered.
Some interviewed staff reported confusion or a lack of knowledge about the intended roles and responsibilities of the Grants Manager and Grants Analyst roles. For example, some interviewees noted that they had been told that these positions were solely designed to support EDD rather than serve the City as a whole. In other instances, interviewees reported concerns that the Grants Manager position was only in place to provide compliance activities, rather than provide meaningful support or aid to departments.
Recommendations
A. Consider reviewing staffing levels within departments or divisions that are heavily involved in the grant management process (including Public Works, Economic Development, and Procurement) to ensure sufficient capacity to effectively accomplish related work.
To maximize current staff resources and plan for future staffing needs, the City should consider creating an informal workforce plan that identifies competency and staffing level gaps in its current and future operations as it pertains to City-wide grants management. Successful workforce planning consists of the following elements:
• Identifying key functions: Consider the key functions of grants management in each department. • Workforce analysis: Determine what competencies and staffing levels are required in each department to support goal achievement and organizational performance. As part of this phase, consider how job descriptions may change as the Grants Manager position develops. • Gap analysis: Compare the City’s projected future grants workload to the current workforce to identify competency and resource gaps and surpluses. This analysis will help inform where future candidates are most needed and reveal opportunities for existing staff development. • Strategies to fill gaps in alignment with anticipated growth: Consider whether the gaps are best filled by a process managed by the Grants Manager, temporary use of a consultant or contract staff, or hiring additional staff.
• Regular evaluation and revision of the plan: The resources to fulfill the City’s grants management needs will continue to change as the type and scale of grants that the City is applying for and receiving evolves. The workforce plan should be revisited biannually and adjusted based on changes to the City’s grant portfolio.
B. Clearly document and communicate the roles of the Grants Manager and Grants Analyst to all departments. As part of this work, it will be important to acknowledge the role of EDD and, if possible, provide a long-term plan for how these positions may be funded moving forward to help alleviate concerns that these roles will be eliminated within 1 to 2 years.
Ideally, the Grants Manager and Grants Analyst roles would be able to support the following centralized, City-wide functions:
• Coordination: Coordinating grant management activities for cross-department or City-wide grant efforts (for example, ARPA funding).
• Oversight: Providing centralized monitoring and oversight of grants to ensure compliance with grant agreements, deadlines, and reporting requirements, including developing standardized reports to be shared with staff and leadership.
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• Training and Support: Providing training, building capacity within departments, and acting as a consultant to offer expertise to other departments. Consider continuing standing meetings held by the Grants Manager, including periodic meetings with key grant departmental grant administrators and budget analysts.
• Process Improvement: Creating streamlined internal processes, systems, policies, and procedures to increase efficiency; identifying bottlenecks.
• Reporting: Assisting in the proper configuration of Tyler Munis data and helping departments set up reliable and useful reports.
3. Observation The City is making progress in developing comprehensive grant policies a
nd procedures, but some gaps remain.
Recommendation A. C ontinue efforts to update , adopt, and roll-out grant-related policies and procedures.
B. Develop more informal reference guides or other resources to explain grant-related processes, roles, and responsibilities to City staff in a user-friendly format.
The City has a Grant Administration Policy in place to guide grant activities across the organization. The City is also actively working to update the Grant Submission and Grant Administration Procedure documents, and a Grants Administration Guidebook is also currently in draft stage. This work will enable the City to close out many previous audit findings related to grant policies and procedures. We have provided recommended edits to the draft policies separately.
Based on staff interviews, most departments have not developed department-specific procedures.
Personnel in these departments rely solely on the guidance documents from the granting agencies and the City. While additional policies and procedures are not necessary when adequate guidance is provided by granting agencies, some agencies do not provide sufficient direction to fully meet staff need for guidance.
In addition to the formal policies and procedures that the City has developed, staff report that it would be highly beneficial to have a more informal reference guide and/or job aides that can present the various processes in a more user-friendly format.
Recommendations
A. Continue efforts to update, adopt, and roll-out grant-related policies and procedures.
B. Develop more informal reference guides or other resources to explain grant-related processes, roles, and responsibilities to City staff in a user-friendly format.
While it is likely that the updated Grant Administration Procedure document will fill many of the current gaps, a reference guide that clearly explains grant-related processes, roles, and responsibilities to City staff in a user-friendly format would assist with both employee training and enforcing consistent processes.
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In addition, for departments that process significant grant funding, it may be useful to develop additional internal grant-specific or department-specific procedure documentation to increase consistency and aid in onboarding/training new team members within that department. If needed, grant-specific or department- specific procedures should provide additional guidance to employees and reduce risk of non-compliance, particularly for grants where agency direction is sparse. It will be important that these internal documents are kept in alignment with the City’s enterprise policies and procedures.
4. Observation Historically, grant processes have varied widely by department, which has created inefficiencies and increased the City’s risk.
Recommendation Continue current efforts to improve the consistency and efficiency of grant-related processes. Taken as a whole, these efforts should help to expand staff knowledge, increase process consistency, and reduce risks.
Grant administration processes have been historically challenging for departments to understand or follow. For departments that process significant grant funding on a regular basis, individual staff members have developed knowledge and processes to complete grant-related activities. However, for departments that rarely or irregularly process grants, the lack of well-defined City-wide grant processes (see Policies and Procedures section) has been particularly challe nging—especially in relation to the post-award activities. City-wide processes are described below and are broken into the following steps:
• G rant Identification
• Grant Application
• Post-Award
• Working with Subrecipients
• Grant Implementation and Monitoring
• Grant Close-Out
Grant Identification
As noted within the Leadership Support and Strategy s ection, the City has not yet developed a standardized approach or criteria for when and when not to pursue grant opportunities. Some staff reported that leadership does not always have a good sense of the level of staff support implementing a given grant will require, which can lead to situations where grant funding is secured but there is limited or no staff capacity to appropriately focus on implementation. This is particularly true within departments like Public Works, where there are many possible grant opportunities, and the process to vet each opportunity requires significant investment of staff time.
City policy requires that all grant applications ar
e consistent with City priorities as reflected in City Council policies, goals, and the annual budget and capital improvement plan. In interviews, this requirement emerged as an area where the Grants Manager could help bridge departments’ knowledge gap between their individual departmental goals and the overarching goals of the City. In practice, grant identification varies by department. For example, the Police and Fire departments apply exclusively for standard, Attachment A
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annual, and rotating grants, while Public Works staff are continuously identifying and pursuing new grants.
Grant Application
Prior to submitting a grant application, all departments are required to obtain approval from ASD’s Budget Division. ASD evaluates the financial impact of the grant commitment (matching funds, new staff positions, maintenance of effort, etc.) and whether the department has identified a reasonable plan to meet that financial need. Once ASD has approved the plan, departments are required to request approval from CMO to ensure appropriate coordination and consistency with City-wide goals and priorities.
Approval from ASD and CMO can follow two methods: the submission of an agenda item and resolution or motion for City Council approval, or the submission of a Notice of Intent (NOI) to the Deputy City Manager that has oversight for the department and/or City Manager for approval. The workflow describing requirements for submitting a NOI or a resolution or motion to City Council is included in Chart A and B of the City’s draft Grant Administration Procedure. The updated approval process currently in development by the Grants Manager stipulates that the CMO approval process should occur in Tyler Munis, which requires departments to upload all grants that they intend to apply for into the Tyler Munis Grant Master module. That process will allow the Grants Manager to easily find out at any time how many grant applications are pending across the City.
Interviewed departmental staff noted that the requirement to obtain approval from ASD and CMO prior to submitting a grant application significantly lengthens the overall time required to apply for a grant. In addition, staff noted that it can take eight weeks to get a resolution or motion before City Council, pushing the overall timeline to around three months. This timeline can limit the City’s ability to apply for grants that require faster turnaround times. The option to submit an NOI instead of a motion to the City Council is in place to provide a quicker process when necessary.
Some interviewed departmental staff also noted that the new process of uploading all grants under consideration for application into Tyler Munis adds additional workload and reported a lack of clarity around the necessity of this step. As a result, some departments are not uploading their proposed grants into the Tyler Munis system until after they are awarded.
Once the required approvals are obtained, methods of compiling grant applications vary by department.
For example, Public Works uses consultants to help package the necessary data and project cost estimates, relying on its fiscal staff to respond to information requests. The Library brings in outside consultants where technical assistance is necessary—for example, the use of an architect helped secure a $12 million grant. In other departments, the program managers who will oversee executing the grants are tasked with the entirety of the grant application.
Post-Award
Upon notification of award, departments are required to provide ASD with all relevant information related to the grant, including a breakdown of the budget. Departments are also required to update the designated Tyler Munis Grant Master record with supporting documentation and all pertinent information.
Under the new City-wide Grant Administration Procedures that are in development, all departments will be required to schedule a grant award kick-off meeting within two weeks after the contract has been executed. The kick-off meeting will bring together all administrative, fiscal, and program staff who will be involved in the grant and provide a platform to gain clarification on all aspects of the project implementation. This is aligned with best practice.
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All departments are responsible for compliance with all federal, state, or local grant requirements, including implementation, monitoring, subrecipient monitoring, audit visits, audit responses, and grant reporting submissions. Some departments have their own process documentation for these steps, but policies and procedures relating to implementation, monitoring, and other post-award processes have not been adequate in the past. The new City-wide Grant Administration Procedures will include some guidance for these processes. The new procedure should also include clear documentation regarding the post-award instances where additional approval is required from the CMO. Interviewed departmental staff noted that there can be confusion around invoicing, authorization for public communication, and signature approvals.
Although departments have been mostly able to maintain their own post-award processes, staff report that the repercussions of not having standardized City procedures are most apparent when grants do not have a clear owner. For example, when a grant is awarded to multiple departments, the roles and responsibilities are unclear. As a result, the required procedures may not be followed.
Working with Subrecipients
While much of the City’s grant funding is intended to directly support City projects and services, the City also acts as a pass-through entity to award grant funding out to community partners. Staff report that there have been significant challenges related to subrecipient coordination and monitoring. In particular, subrecipient pre-award risk assessments and monitoring requirements were areas of interest and concern.
Grant Implementation and Monitoring
Grant execution and monitoring expectations and procedures were previously not documented, resulting in a lack of consistent processes and increasing the City’s risk. While each grant comes with its own set of implementation and monitoring requirements, there are opportunities to establish base-line practices that can be applied across all or most grants within the Grant Administration Procedure draft.
Please see the Compliance and Reporting s
ection for more related obs ervations.
Grant Close-out
Grant close-out procedures have not previously been standardized, but the new City-wide Grant Administration Procedures will include documentation for this step.
Recommendation: Continue current efforts to improve the consistency and efficiency of grant- related processes.
The City is activity working to close many of the gaps noted above. We recommend continuing current efforts to:
• Finalize and implement comprehensive grant policies and procedures • Provide relevant training
• Offer an informal reference guide or other resource
• Implement standard internal reports for tracking and accountability Taken as a whole, these efforts should help to expand staff knowledge, increase process consistency, and reduce risks.
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5. Observation Over the past decade, the City has struggled to provide adequate grant m
anagement training to staff.
Recommendation Develop a standardized grant management training for all staff who are i
nvolved with grants management.
The City has not yet developed any internal trainings related to grant management (apart from some technical trainings on the Tyler Munis grants module), and new employees working on grants currently learn grants-related procedures organically from their peers or manager via on-the-job training. Due to high levels of staff turnover within the past several years, interviewed staff reported that there are significant gaps in knowledge around roles, responsibilities, and processes. Staff in most departments reported that grant-related work varies significantly across the City, making it difficult to cater trainings to wider audiences. Nonetheless, there is a widespread appetite for more grants-related training of any kind.
Some departments have had staff attend external trainings provided by specific granting agencies—which is aligned with best practice. But there are still many employees who are new to the City and/or new to working with grants who would benefit from training, particularly employees in program manager roles, who may have limited knowledge of the financial and compliance aspects of grant management.
Providing grants management training has been an enduring challenge for the City. Three past Moss Adams reports (2013, 2015, and 2017) all found that a lack of training specifically pertaining to grants management was contributing to risk related to grants management. 2013 Internal Controls Report
The Moss Adams 2013 Internal Controls Report found that the City employees responsible for monitoring grant compliance were not receiving adequate information about the complex and continuously changing compliance requirements imposed by federal, state, and pass-through agencies to accurately manage and track compliance with grant requirements. Ideally, training programs, both formal and informal, should provide the necessary knowledge and skills to manage and administer grants compliance. The report recommended that the City provide specific internal and/or external training to employees in departments responsible for monitoring grants. It specified that the training should be relevant to the type of grants being managed, including documented requirements, and that the City should maintain a training budget that is adequate to cover such costs.
2015 Internal Grants Management Audit
The Moss Adams 2015 Internal Grants Management Audit found that staff were not always fully aware of what changes needed to be implemented to comply with updated federal requirements for grants management, and that most grants management staff members within the Police Department and EDD had not attended any grants-related training in the past year. The audit recommended that departmental grants management staff should attend grants-related training regularly to ensure that they were aware of new requirements and best practices.
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2017 Grants Management and Administration Internal Controls Testing The Moss Adams 2017 Grants Management and Administration Internal Controls Testing found that formal grants administration training was not provided to all personnel involved with grants. The report noted that without adequate training about grants requirements, the City faced an increased risk of non- compliance that could jeopardize grant funding. The report recommended that formal training should be provided to all personnel involved with grants, including overall grants management administration and compliance requirements. In addition, it noted that:
• The training records for personnel should be maintained and tracked centrally to ensure appropriate training is provided.
• The CMO should consider amending the Grants Administration Policy to include a training requirement.
• The successful completion of grants training should be reporting and tracked centrally. • In addition to the specialized trainings provided by the granting agencies, the City should consider developing or finding a cost-effective formal training that provides an overview of the organization’s grant processes for all grants administration and management personnel to ensure consistent and standardized guidance is provided to all grant-related personnel in the City.
Recommendation: Develop a standardized grant management training for all staff who are involved with grants management.
The training should be provided on an annual basis and integrated into the onboarding process for new staff who will be involved in grants management. The training should include, but not be limited to, overviews of:
• Grant management and grant making lifecycles
• Roles and responsibilities within departments and across the City • Relevant policies, procedures, and processes
• How to use the Tyler Munis system to support grant activities • How grant compliance and oversight reports are generated and used The City should also consider providing a specific training related to subrecipient monitoring and management to employees in departments that deal with pass-through funding. The training should be relevant to the type of grants being managed and the City should maintain a training budget that is adequate to cover these training costs.
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6. Observation While the City is in the process of implementing more robust centralized ov
ersight of grant compliance, there are ongoing challenges related to data accuracy and consistent system use.
Recommendation Continue efforts to:
A. Develop and implement clear guidelines about which elements of compliance and reporting will be performed by the centralized Grants team and which will be the responsibility of department personnel.
B. Establish centralized grant oversight reporting tools.
C. F ully implement and utilize Tyler Munis as the grant system of record.
Compliance Oversight
Historically, the City has not maintained centralized oversight of grants. The City has relied primarily on reactive evaluations of its compliance with regulatory requirements and City policies, which involved ongoing monitoring, testing, and reporting completed by its internal and external auditors. While individual departments performed monitoring and grant compliance work in accordance with granting agency requirements, the City had not established personnel with oversight responsibilities for all awarded grants. Without centralized monitoring and oversight of grants management, the City has been out of compliance on some occasions related to reporting and timeliness of grant expenditures.
Within this environment, the City has been required to return grant funding if it has been out of compliance with grant requirements or has failed to spend down the funding (which is often related to insufficient staff capacity—see more details in the Staffing Structure s ection). Most recently, the City
received several minor findings from the US Department of Housing and Urban Development (HUD), some of which were related to reporting and the timeliness of grant expenditures. Given the City’s high reliance on grant funding to support critical projects and services, it is imperative that the City have systems and processes in place to accurately and efficiently monitor grants to ensure all funds are spent down and used in accordance with the contract and other relevant guidance.
Grant Reporting
Accurate grant reporting has been and continues to be a challenge within the City. This is partially due to the previous lack of a comprehensive grant management system and the current transition into the Tyler Munis system (see Systems and Data Integrity s
ection for more details). As a result, multiple interviewed staff reported that they do not yet fully trust the data in Tyler Munis and are unable to use that system to pull adequate reports. Within this context, staff are using shadow systems and spreadsheets to manually track data, which is both inefficient and prone to human error.
Comprehensive tracking of grant deadlines has also been a challenge f or the City. While the
implementation of Tyler Munis for grant management should assist with this issue, staff are still primarily relying on calendars or spreadsheets to track external reporting deadlines. In the past, the City has struggled to establish and implement standardized procedures for completion and review of financial and performance reports for grants. However, there is hope that the updated Grant Administration Procedure will bridge these gaps and help increase consistency.
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Recommendations:
A. Continue efforts to develop and implement clear guidelines about which elements of compliance and reporting will be performed by the centralized Grants team and which will be the responsibility of department personnel.
While the Grants Manager and Grants Analyst roles can support centralized tracking of items like grant deadlines, each individual grant has its own specific requirements. Given the large range of grants that the City is awarded, program managers within individual departments will still need to be responsible for understanding, tracking, and complying with grant-specific requirements.
B. Continue efforts to establish centralized grant oversight tools.
These tools should include, but not be limited to, regular reporting on:
• Upcoming grant reporting deadlines
• Spend down in comparison to grant timeline
• Time elapsed between cash draw or reimbursements and spending • Grant matching requirements and contributions
• Grant closeout
C. Continue efforts to fully implement and utilize Tyler Munis as the grant system of record.
See the Systems and Data Integrity se cti on for more details.
7. Observation Institutional knowledge of interdepartmental collaboration has been eroded by staff turnover and procedural confusion. As the City shifts its grants management approach to a hybrid model, the Grants Manager can play an important role in rebuilding City-wide confidence in this area.
Recommendation Document roles and responsibilities, including clarification on the role of the Grants Manager.
Challenges in interdepartmental collaboration were a common theme in staff interviews—particularly in regards to the relationship between departmental grants staff and the Accounting and Budget staff.
Budget staff are a key part of the grant approval process at the City, but many interviewed staff throughout the City expressed confusion about the best way to interact with the Accounting and Budget Divisions of ASD. Typically, Accounting and Budget staff assignments are made by fund and department.
Contact information for assigned staff is provided to departmental fiscal staff as assignments change but staffing levels and turnover have made this assignment structure temporarily unattainable. Except for the Municipal Utility Department (MUD), most departments do not currently maintain standing check-ins with ASD. Interviewed staff suggested that it would be helpful for the grant administration process to include a check-in with ASD that would guide Grants Managers through the most important aspects of grant accounting.
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Some interviewed staff also reported that ASD’s high workload made them hesitate to ask for anything from this team, which caused them to deviate from standard processes. For example, a staff member reported that due to their impression that ASD has trouble finding the time to upload project budgets into Tyler Munis, they preferred to handle as much as possible alone and rely on ASD only for the necessary checks and balances built into the system.
Interdepartmental challenges also occur with grants like ARPA and CARES, which require collaboration between several departments. This has been a challenge for the City without a designated person or department in charge of coordinating large grants like this. For example:
• ARPA is a City-wide grant led by the CMO. Since joining the City, the Grants Manager has taken on some ARPA-related task coordination including quarterly reporting. The Grants Manager will need to continue to work closely with CMO to ensure success, but the specific roles of the CMO, the Grants Manager, and department staff have not yet been clearly defined for City-wide grant management. • During the implementation of CARES, there was no designated department or personnel tasked with compiling compliance and monitoring information. When close-out began, the necessary information was spread throughout the City.
The differences in grant requirements across departments can also present communication challenges when interdepartmental collaboration is required as part of City-wide processes and when flexibility is necessary. For example, several interviewees mentioned instances when funds were administered by a program team in a way that they believed to the compliant with grant guidelines but which ultimately caused accounting challenges for ASD. Other communication-related challenges also came up in staff interviews. Some staff mentioned a disconnect between budget personnel and project management personnel stemming from a lack of accounting knowledge on the project management side. Others noted that many departments could benefit from the grant administration knowledge housed in other departments, but many people no longer know how to informally initiate this exchange—largely because they don’t know who is working on what due to staff turnover.
Recommendation: Update roles and responsibilities, including clarification on the role of the Grants Manager.
Ensuring that all City staff are on the same page about the roles and responsibilities of key personnel is an important first step to ensuring that the grants process at the City is clear. A written copy of roles and responsibilities could also act as an informal guide to grant administration knowledge that might re- engage staff in the informal grants-related information exchange that has been curtailed by staff turnover.
In addition, it may be beneficial to provide all staff with up-to-date information about the best contact points within ASD for common grant-related situations or questions. This type of information can help grants-related staff across the City feel confident about reaching out to the right person at the right time in the grants process and will make it easier for staff who don’t often work on grants to navigate the process.
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8. Observation The City is actively implementing Tyler Munis to serve as its ERP and s
ystem of record for grant management. Currently, each department is using slightly different approaches toward grant data, largely due to the difficulty of the transition to Tyler Munis. As a result, Tyler Munis is not yet generating accurate and reliable information.
Recommendation Continue current efforts to fully transition into the Tyler Munis system for all grant-related data and actively work with departments to ensure the system is serving its intended purpose.
Grant Management System
The City is in the process of transitioning their Enterprise Resource Planning (ERP) system from HTE to Tyler Munis. While the Grants and Project modules of Tyler Munis have been implemented, the City is actively in the middle of implementing the new Payroll module, which will be key to enabling comprehensive grant-related reporting.
Training and New System Rollout
City-wide training regarding the use of the Tyler Munis Grants module has not yet been standardized.
Although some employees did receive an initial training provided by the City, others were trained by another employee in their department. The intended process was for the Subject Matter Experts (SMEs) from the ERP implementation to act as the trainers for the system. Project and Grant SMEs included one Accountant, two Budget Analysts, and seven department representatives. The Grants Manager has been holding regular meetings to support department users as part of the ERP roll-out process and interviewed staff reported positive responses to these meetings and found them to be helpful.
Based on interviews, there appears to be a lack of clarity in some departments related to the use of Tyler Munis for grant management. Interviewees voiced the need for better documentation around their responsibilities for when and how to input data into the system. Staff also report confusion regarding the resources available to them to navigate the new system. Some staff were aware of the SharePoint Site ERP 123 that houses processes, workflows, and end user guides, but some said the site contains broken links and incomplete information.
System Workflows
Staff report that the grant submission approval process and workflow in Tyler Munis is inefficient and is not being fully utilized. For example, although the original intention was to have a fully digital approval process, wet signatures are still frequently being used. This is likely because the grant policy has not yet been changed to reflect the fully digital process, so that process has not been enforced. Some parts of the grant submission process are also handled through Legistar, which is not integrated with the Tyler Munis workflow. In addition, as the Tyler Munis approval process is often very slow, staff note that many approval requests are still being sent entirely through email or approval requests are accompanied by an email nudging the recipient to check their Tyler Munis approval requests. The current approval process is represented by this flowchart:
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Reporting and Data Accuracy
Multiple interviewed staff reported that they do not yet fully trust the data in Tyler Munis and are unable to use that system to pull adequate reports. Contributing factors include:
• The ongoing transition from HTE. There have been significant challenges related to the fact that payroll data is being generated out of HTE, which has created the need for double entry into both HTE and Tyler Munis.
• Inaccurate or out-of-date data being entered into Tyler Munis by department staff. For example, interviewees reported frequent problems with departments not updating the status of their grants, key dates or award amounts changing, and workflow issues.
• Challenges or concerns related to data accuracy. For instance, some staff mentioned a recurring issue where monthly reports do not match year-to-date reports. Another example is the inability to reconcile p-cards against monthly statements, leaving the statement pending until the user attends a drop-in session where manual overrides are administered. • The lack of a coordinated City-wide effort to review and clean-up data as part of the Tyler Munis implementation.
Shadow Systems
The issues surrounding the rollout of the Tyler Munis grants module have resulted in the partial adoption of the system City-wide. Tyler Munis should be able to produce efficient automated reports that make internal reporting simple and straightforward, but almost all interviewed departments reported that they experience so much difficulty with the system that they use Excel or other systems to accurately track elements of their grants. Three departments reported high reliance on external spreadsheets to ensure data accuracy:
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• At the time of our interviews, ASD was maintaining several separate spreadsheets to cross reference data for accuracy (for example, if expenditures in Tyler Munis were posted in the wrong account, ASD staff reported using an external spreadsheet of primary data so that they could identify and correct errors in Tyler). Interviewed staff reported that maintaining data in multiple places is one of their biggest challenge. One of the primary drivers of this issue is the ongoing data cleanup necessitated by the HTE system conversion. As such, ASD anticipates that this issue will be resolved and is actively in the process of reducing or eliminating the need for these types of external spreadsheets. • EDD uses a shadow system because it is more accurate, malleable, and accessible (for example, all team members can clearly track how much money is being spent down). • Public Works staff report that workloads are higher than they were before the transition to Tyler Munis, because they are now doing double data entry and continually referencing between Tyler Munis and the data maintained in their separate spreadsheets.
While using external spreadsheets to view and manipulate data is common, issues arise if the external spreadsheets are used as the system of record (aka, the primary source of accurate data). In those instances, it is an indication that additional work is needed to ensure Tyler Munis can effectively function as the system of record.
Change Management
Based on interviews, there appears to be widespread frustration about the increased workload and learning curve related to transitioning to a new system. Many interviewees reported that Tyler Munis was providing limited value in its current configuration and some departments do not think that Tyler Munis is a good fit for their needs. For example, Public Works reported difficulty with using the reimbursement billing system, as revenue allocation is designed for straightforward billings.
Although the Grants Manager has been working with departments to help them update data and stay in compliance with internal processes, department staff frequently report not having the capacity to honor the request or feeling reluctant to invest the time as they do not see the benefit. To enable a successful and comprehensive transition to the Tyler Munis system, it will be important for City leadership to clearly communicate expectations and engage in change management practices to encourage consistent adoption by staff.
Recommendation: Continue current efforts to fully transition into the Tyler Munis system for all grant-related data and actively work with departments to ensure the system is serving its intended purpose.
This can be accomplished by:
• Developing standardized training on how to use the Tyler Munis system to support grant activities (see Training s ection for more details).
• Reviewing the grant submission approval process workflow to identify opportunities to increase utilization and reduce turnaround time.
• Developing a City-wide approach to review and cleanse data that is critical to support the grant oversight and reporting functions.
• The Grants team actively working with departments (starting with those with the most grant-related activities) to ensure that accurate and accessible reporting can be generated out of Tyler Munis without the need for additional tracking outside of the system.
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• The Grants Manager providing clear guidance to desired improvements in this area that includes information about which fields are required, where to get that data, and what documentation to attach.
The communication around this process improvement should also include justification regarding the necessity of collecting this data, the value that this data will add, and who is mandating the change in process.
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APPENDIX: SAMPLE RESOURCES
Below is a list of checklists, tools, reports, and templates to be employed that will aid in standardizing grant processes throughout the City. Sample resources include:
• Pre-Award Checklist
• Subrecipient Risk Assessment Framework
• Grant Implementation Checklist
• Subrecipient Monitoring Checklist
• Grant Close-Out Checklist
• Grant Lifecycle Summary
Source: Capital Edge Consulting
The pre-award phase represents the beginning of the grant lifecycle, which includes important considerations regarding the pricing of the award and maximizing cost recovery efficiency over the full award term. The pre-award phase is also the organization’s opportunity to ensure that it is capable of complying with the compliance requirements associated with the new award. The following checklist provides pre-award considerations for the Federal Grants Lifecycle:
Organizational Alignment
• The opportunity supports our organization’s Mission Statement and organizational goals. • The opportunity complements or strengthens our organization’s Strategy. • The opportunity benefits our constituents.
• There are no negative political implications that should be considered.
Organization Risk
• Resources within our organization possess the knowledge, skills, and ability required to administer the proposed award in accordance with laws, regulations, and the terms and conditions of the proposed award.
• Our organization has successfully administered an award from the same awarding agency as the proposed award.
• Our organization has successfully administered an award subject to the same regulatory requirements as the proposed award.
• Our organization has not experienced any negative outcomes as a result of audits of previous awards similar to the proposed award.
• Our organization will not need to develop new or additional legal or compliance resources to comply with the law, regulations, and terms and conditions associated with the proposed award. • The planned scope of work is achievable within the requested period of performance. • The scope of work does not present any technical risks that should be considered.
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Financial Risk
• The proposed award budget allows for unrestricted indirect cost recovery. • The proposed award does not include cost share or matching requirements. • The proposed award does not restrict the use of third-party organizations (subrecipients) to meet any applicable cost share or matching requirements.
• Fee or profit will be allowable under the proposed award. • Our organization will not need to develop or hire additional administrative resources to manage the proposed award.
• If the proposed award requires the hiring of new staff, our organization will have additional sponsored projects that the newly hired staff can work on if they are not able to be fully dedicated to the proposed award (less than 1 FTE).
• Our organization will not need to develop or hire additional administrative resources to successfully manage the proposed award.
• If the development of additional administrative resources is required, our organization can capture the full cost of resources across the full award lifecycle. • Our organization will be entitled to potentially valuable intellectual property as a result of the proposed award.
• If the proposed award is expected to run at a deficit (when the fully burdened cost is considered), our organization will have alternative sources of revenue that can offset the proposed deficit. • Equipment purchases or management of government property will not be necessary in support of the proposed award.
• The proposed award will not require the use of existing organization facilities.
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A pre-award risk assessment is a way to evaluate the potential financial and compliance risk of a subrecipient or subaward. Per Uniform Guidance 2 CFR Part 200.331, pass-through entities (the City) are required to conduct a risk assessment on all subawards with federal funding. A risk assessment is not intended to be punitive, but rather is an evaluation tool. The answers provided on the pre-award risk assessment will assist the City in determining the level of support and oversight to provide the subrecipient in order to ensure compliance with the subaward.
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Source: PKS Grant Management & Accounting Solutions, LLC The Grant Implementation Checklist is a best practice which helps to ensure that all requirements and tracking are being setup in a way that allows the City to efficiently and effectively monitoring grant awards received, and any regranting (subawards). While there are software available to support the City’s tracking and monitoring of grant awards, the template below provides a guide to what should be done during the grant implementation and startup phase.
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The specific monitoring requirements for each subaward should include any flow-down requirements from the City’s funding source, as well as any City specific requirements that need to be met by the subrecipient and monitored by the City. The checklist below depicts a comprehensive monitoring program that may be tailored and implemented for City use. The monitoring process is critical to ensuring the City’s stewardship of grant funds in the community, including the verification that subrecipients are accurately tracking and can support all expenditures incurred and programmatic outcomes of the funds received.
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Source: Smith College
The grant close-out process is critical to ensuring that all funds received by the City and regranted (subawards) is accounted for and accurately recorded, properly supported, and all final reporting and close-out documentation can be provided to the City’s funder, as applicable.
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Source: Grants.gov
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