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Key takeaways from the BFS team’s presentation at the NGMA Compliance Conversations webinar “Grants in Transition: Practical Steps on Navigating the Now & Preparing for What’s Next.” In this webinar, the BFS team provided practical steps to navigate the shifting federal funding landscape. To read a summary of the presentation on preparing for what’s next, click here.
Missed the live presentation? Access the recording here.
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We are grateful to the grants professionals who joined us for an important compliance conversation on grants in transition. These conversations are more than just training—they’re a space to tackle real-world pressure points and share strategies that help agencies stay one step ahead of compliance risks.
In this session, we focused on what’s keeping folks up at night: policy gaps, spending stress, desk reviews, and documentation pressure. And we didn’t just talk about the problems—we shared practical tools to help solve them.
Here are a few highlights and takeaways from the session.
Review, Track, and Update Your Policies - Starting Now
With changes to 2 CFR 200 coming in FY26 and a steady stream of impactful Executive Orders (EOs), now is the time to review and align your internal policies and procedures to keep pace with the evolving federal landscape. We recommend:
- Reviewing policies now to see where alignment is possible
- Tracking EO-related changes that may affect policies and compliance
- Updating policies and procedures regularly as part of internal controls best practice
- Flagging policies that may need revision later, once 2 CFR 200 has been updated
Don’t wait for formal implementation dates to begin your internal work. Proactive alignment not only supports compliance, it strengthens your operational integrity.
Audit & Desk Review Focus Has Shifted - Are You Ready?
Traditionally, audits focused on familiar territory: HR, procurement, and other program-facing policies. But today, the lens is wider—and sharper. Auditors are no longer just checking boxes; they’re evaluating how your policies, practices, and spending align with program intent, performance outcomes, and federal priorities.
Even policies that once went unnoticed may now raise red flags if they’re outdated, misaligned, or undocumented. In this new environment, internal policy reviews, clear justification, and organized documentation aren’t just best practices—they’re essential tools for audit readiness and risk mitigation.
Are you a Red Flag?
- Do you have high unobligated balances?
- Do you have a spend-down strategy that aligns with program goals?
- Do your programs and policies align with the intent of your programs and the current EOs?
Budget Modifications Require Strategy - and Transparency
Budget realignments don’t have to be reactive. We talked about how to navigate spending down and budget shifts with confidence by:
- Staying within the lines - understand pre-approval thresholds
- Aligning spending with program goals - don’t just “use it or lose it”
- Talking to program leads early - don’t wait for a crisis
- Documenting every step - because if it’s not documented, it didn’t happen
- Drawing down regularly - don’t let claimed-but-unreimbursed funds pile up
Too many agencies fall into the "use it or lose it" trap without a strategic plan. We emphasized that spending should be intentional, documented, and defensible. With today’s unpredictable funding environment, sitting on reimbursements is a risk. Claim within 30 days of expenditure whenever possible.
If It’s Not Documented…It Didn’t Happen
We can’t say this enough: Good documentation is your first line (and often strongest) defense. Make sure your grant documentation is:
- Centralized, organized and accessible
- Clear, legible, and tied to the decision being made
- Contextual - not just what happened, but why it happened
Action Items You Can Tackle Today
- Review and revise your policies, especially procurement, cost allowability, and disclosures.
- Centralize your grant documentation, so it's ready when you need it.
- Start the budget reallocation conversations now, before deadlines close in.
- Prep for monitoring and desk reviews - they’re coming, even if you haven’t been flagged yet.
As the grants landscape continues to shift, stay focused on what you can control. Create a list of action items, tackle every item on the list and keep reviewing, documenting and making changes as needed to ensure compliance. Stay up-to-date by remaining engaged and continuing to seek and use information, resources and tools.
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Mara Ash, CIA, CGFM, CMRA, CICA is the CEO and Cindy Watson, CICA is the managing director of BFS Strategic Partners. For additional support and tools, visit decoded.expert.
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