Checks with Balances: Ensuring Appropriate Use of Grant Funds

Editor’s note: This article is part of a series. Click here for the previous article.

Gordon Graham here, continuing with my thoughts on Family Nine of the 10 Families of Risk. In our last visit together, I covered some of the tragedies caused by misuse and abuse of grant money and I promised you I would provide some control measures to prevent these tragedies from occurring.

For those of you who have not been following these writings since my first piece almost six years ago, here is my entire life in one sentence.

Risk management is any activity involving the evaluation and comparison of risks and the development, selection and implementation of control measures to address these risks.

By control measures I mean policies, procedures, rules, directives, standard orders, general orders, and initiatives. If these measures are properly designed, up to date and being taken seriously, you can prevent tragedies from occurring.

With respect to the risks involved in grant money, here are some control measures for your consideration, courtesy of the good people in Lexipol’s Grant Services division:

  1. Ensure needs and basic project details are identified as required by the grant.
  2. Establish and maintain all grant pre-registration requirements.
  3. Keep all applicable registrations active to eliminate the chance of missed deadlines.
  4. Pay attention to deadlines for required grant progress reports and closeout reports and ensure these reports are submitted on time.
  5. Put appropriate financial controls in place so you know how grant money is being used—and can identify misuse early.
  6. Don’t think, “We are out here in the ‘middle of nowhere’ and no one is ever going to come check on us.” FEMA gets most of its fraud and abuse tips from neighboring departments angry because Department A has received grant money and they “didn’t deserve it” or they simply misspent it. The second source for reports is vendors who don’t get the bid award.
  7. Understand the grant stipulations. If you don’t thoroughly understand them, talk to the grant manager to get clarification. Don’t take the advice of someone else in your department, the chief next door or some salesperson. If you do, you may wind up having to pay money back to the federal government.
  8. It shouldn’t need to be said, but don’t get greedy and don’t be dishonest! Some people see a pile of money and think they can get away with misappropriating it. Not that long ago reports surfaced about a deputy chief who will likely serve time in federal prison because he stole $1.5 million from a regional SAFER grant by creating fake companies and writing checks to them for work that was never done. The bank he dealt with got suspicious and called the FBI.
  9. Operate as though the government agency providing the grant knows how you’re spending every penny. Assuming the grantor “won’t find out” is a big mistake. There is always a trace on funds, how they are spent, when they are spent and if they were spent in the manner intended in the grant.

In addition to the above control measures, consider the impact misuse or fraudulent use of grant money can have. It’s not only a nightmare for the agency when they’re caught doing so (and they will be caught), but it can also reflect poorly on the state or federal agency issuing the grant money. They will not want to fund an offending applicant in the future—which means even a minor mistake can affect your agency’s ability to get grants far into the future.

We must remember that “government” does not have any money. Government transfers tax dollars into grant dollars—and hard-working taxpayers have every right to expect that grant dollars are used appropriately.

In addition, if public and lawmaker confidence in the grant program is low, then the funding stream is at risk of not being renewed or the budget is cut in future appropriations. So not only can misuse directly impact an agency, it can have the much larger consequence of affecting funding for all public safety agencies.

To wrap up this writing, here are two thoughts for your consideration and some closing comments. First, there are only so many grant dollars available; to waste or misuse (intentionally or negligently) these dollars is just plain wrong. Second, we must remember that “government” does not have any money. Government transfers tax dollars into grant dollars—and hard-working taxpayers have every right to expect that grant dollars are used appropriately.

As a sergeant in the 1980s, I was the beneficiary of grant dollars under various National Highway Traffic Safety Administration (NHTSA) programs. Here is a listing of some of the areas of focus. Please note all of them relate to the primary mission of everyone in public safety—preservation of life!

  • Section 402-State and Community Highway Safety Programs
  • Section 153-Use of Safety Belts and Motorcycle HelmetsSection 157-Safety Incentive Grants for Use of Seatbelt
  • Section 157-Safety Innovative Grants for Increasing Seatbelt Use Rate
  • Section 405-Occupant Protection Incentive Grants
  • Section 2003b-Child Passenger Protection Education Grants
  • Section 410-Alcohol-Impaired Driving Countermeasures
  • Section 163-Safety Incentives to Prevent the Operation of Motor Vehicle by Intoxicated Persons
  • Section 154-Open Container Requirements
  • Section 164-Minimum Penalties for Repeat Offenders for Driving While Intoxicated or Driving Under the Influence
    • Section 411-State Highway Safety Data Improvements

Mind you, I did not have an active role in obtaining the grant dollars—that was done at headquarters and the grant money filtered down to the various area offices for their use. On a very, very selfish note, this was a big deal. Our basic pay rate back then was not a lot and the overtime money cops could realize by working these details was substantial. As the sergeant supervising a squad of cops on one of these overtime grant details, I wanted to make sure our public got fair value for their tax dollars that were filtered through NHTSA.

For that reason, I and the other sergeants in the office I was assigned to who took these details tried to get hard-working cops who appreciated the opportunity to work these special details and maximize the effectiveness of the grant money.

As I moved up in my department while simultaneously lecturing nationally about various issues in law enforcement operations, I started to meet people from the state Office of Traffic Safety (OTS) and some people from NHTSA. Over the years I regularly heard comments regarding how pleased they were with the proper usage of the grant money and how the grant requests from my agency were viewed favorably by both OTS and NHTSA because of our past performance in using these grant dollars.

That is a good thing. Every public safety leader in America is concerned about finding extra funds to better protect their community. Having a good reputation with the organizations providing these grants will help in your future efforts to obtain these funds.

That wraps it up for my thoughts on grant money. In our next visit together, I will address department credit cards and the risks associated with them. Until then, please continue to do great work.

Timely TakeawayTimely Takeaway—At what level in your department is credit card usage reviewed—and do you have an audit process in place to ensure the reviews are taken seriously?

Gordon Graham

GORDON GRAHAM is a 33-year veteran of law enforcement and the co-founder of Lexipol, where he serves on the current board of directors. Graham is a risk management expert and a practicing attorney who has presented a commonsense risk management approach to hundreds of thousands of public safety professionals around the world. Graham holds a master’s degree in Safety and Systems Management from University of Southern California and a Juris Doctorate from Western State University.

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