March 26, 2026

Avoiding Costly Mistakes in Post-Award Grant Management

About seven years ago, I walked into a session at the National Grant Management Association (NGMA) Conference with a title I haven’t forgotten since: My Boss is Going to Hell or Jail.

It got my attention, as it should have. At the time, I had already spent nearly a decade writing federal grant proposals. But sitting in the NGMA sessions, what became very clear was that writing the grant is only half the battle. Managing it correctly (and understanding the rules so that the organization can do that) was of the same importance.

Here are just a handful of the sessions I attended:

  • True Cost for Sustainability and Impact – Understanding the full cost of delivering programs and how underbudgeting can undermine outcomes
  • Procurement Standards – How to follow federal rules for purchasing goods and services, including competition requirements and documentation
  • Understanding the Uniform Guidance – A breakdown of federal regulations and where to find them that govern how federal funding must be spent, tracked, and reported
  • And, maybe most importantly, the aforementioned My Boss is Going to Hell or Jail

This conference was a true eye opener for me, even though I’d been writing federal grant proposals for about 10 years at that point. Writing and managing are two very different things.

Read on for a special offer on an upcoming training TGP is offering to support those who may be newer to understanding post-award grant management, or who want a refresher on the basics of allowability and cost principles when managing federal grants.

Here are a few of the basics that I learned:

  1. Don’t write in a match if it is not required. Ok, I knew that one before I went, but the conference reinforced it. Early on in our federal grant learning journey, we treated them like foundation awards, where it is generally better to demonstrate that you have additional funding to complement the request. This is not what you need to do with federal grant proposals. Instead, if you name a match, you are making a binding commitment. That match becomes subject to the same strict federal requirements as the awarded funds, including allowability, allocability, documentation, and audit scrutiny. In other words, you’re increasing your compliance burden and risk. If you can’t fully track, document, and justify every dollar of that match, it can be disallowed, potentially putting your organization on the hook. Unless a match is explicitly required, it’s often wiser to avoid creating additional obligations that don’t improve your competitiveness.
  2. Don’t spread staff salaries across multiple people. While it might feel like a way to demonstrate team effort, it creates unnecessary complexity. Federal grants require clear documentation of time and effort, and the more individuals you split a cost across, the harder it becomes to track, justify, and audit. Instead, assign costs to the staff who are truly responsible for delivering the work, and keep your budgeting aligned with how the project will actually be implemented.
  3. If you do not have a federal indirect cost rate (also known as a Negotiated Indirect Cost Rate Agreement, or NICRA), claim the de minimis rate. The de minimis rate was recently raised during the Biden administration from 10% to 15% to better reflect the costs of actually implementing a program. An indirect cost rate covers the essential “behind-the-scenes” expenses that make your program possible, such as administrative staff time, accounting, HR, software, cybersecurity, rent, utilities, and other necessary costs. These are real costs that support every grant and program, even if they aren’t tied to a single line item. Claiming the de minimis rate ensures you are not leaving money on the table and helps your organization more sustainably manage the true cost of delivering federally funded programs. You generally do not receive additional points by only budgeting direct costs, with the exception that now, under the current administration, an August 2025 Executive Order directs agencies to give preference to applicants with lower indirect cost rates. That said, we anticipate that future administrations will likely understand the necessity and nuances of a NICRA or using the de minimis rate to fully fund and better administer the program for which funds are being requested.[1] Either way, knowing the benefits and trade offs will help your organization budget for federal grant management and the true cost of running programs.

And here’s a brief rundown of just a few scenarios that will land your boss in prison or jail (only half-joking, with credit to Johna Rogers, GPC who presented this session):

  • An employee being paid from a grant that he is not working on
  • The organization bypasses the procurement process, claiming “sole source” without documentation
  • The organization charges the same expense to multiple funding sources (double charging) to cover a budget shortfall
  • The organization uses grant funds for costs incurred outside the approved grant period (before the start or after the end date)

Usually, these types of mistakes are due to people not knowing or understanding the guidance – and not knowing what they don’t know. You can change this situation and reduce risk at your organization by studying up on the Uniform Guidance and the federal “Green Book” which details how to implement the guidance (this was another thing I remembered about the conference – that was a big book!), take classes or register for professional development, or talk to/contract with an expert.

The key is to have policies and procedures in place that align with the Uniform Guidance, to ensure all costs are allowable, properly allocated, reasonable, and necessary, and that all costs are consistently applied.

Want to learn more?

Register for our recorded webinar, Allowability & Cost Principles led by expert Tonia Brown-Kinzel on April 8, 2026 from 12:00-2:00 pm MT. If you’ve made it this far, use the code staycompliant for $10 off your registration.

And if you need expert help managing your federal grants, we do that too! Check out our services at our website and contact us if you need support.

It helps to learn at least enough to know what you don’t know so you can look it up. Become informed, and you’ll be a better federal proposal writer – and manager!

[1] When indirect recovery is constrained, organizations must subsidize federal grants with unrestricted dollars, which is not an option for all applicants. If agencies restrict the recovery of indirect costs despite an organization having a federally approved rate based on actual costs (developed through a detailed cost allocation proposal and negotiated with the cognizant federal agency), organizations face a growing mismatch between what federal dollars cover and what federally funded work actually costs.

Contact: Erin Hielkema, Owner

 

 

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