Don's Experience with USG Compliance Issues

You might also be interested in my thinking on grant administration.

From November 1994 through October 2011, I worked for Internews in a range of capacities, all focused on USG compliance. Since then, I've been an independent consultant.

I signed on with Internews as an administrative assistant for one of the company's first large-ish ($10 million) cooperative agreements from USAID. That first assignment was my introduction to USAID rules and regulations, and particularly issues to do with subawards. As no one at Internews then had any expertise in this area, I did a lot of scrambling to learn as much as possible as quickly as possible. I was tasked with writing and negotiating significant subgrants (and a couple of contracts), as well as serving as primary stateside "fixer" for the project.

Within a year, I was recognized as a valuable asset to the growing organization. My role was expanded to include general grants/contracts functions, in addition to the single project for which I was hired. I began to participate on the organization's management team, advising on compliance issues. Over time, as the company grew from under $10 million to over $30 million in annual revenue, I was given a series of job titles, from Administrative Analyst to Director of Grants and Contracts. For a few years, they called me Vice President for Administration. Over the course of this evolution, I sometimes had responsibility for IT, HR and Facilities. I wrote Internews' policies on procurement, assistance, travel, etc. I developed and implemented a relational database (using QuickBase) to help track awards, projects, proposals, subgrants, and procurements.

Never quite satisfied with the explanations I received from the finance department, I made myself an authority on indirect cost allocation under the rules of OMB Circular A-122 (2 CFR 230, now replaced by 2 CFR 200 Subpart E and the applicable appendices). And I developed some skill in explaining indirect allocation to staff and funders alike. (It still feels a bit hopeless with non-USG funders, but I'm happy to report that staff really did seem to catch a deeper understanding of the organization's NICRA.)

But the real "meat" of my work with Internews was always in interfacing with the organization's implementers in the field. I developed and honed a sensitivity to the compliance issues most often faced by program implementors. I'm proud to say that I built significant bridges across the gap between HQ (grants/contracts/finance) and program managers in the field. But don't rely solely on my own report; please read some selected testimonials from colleagues.

In 1996, I took my first rules and regs course from Bob Lloyd, put on by then APVOFM (now InsideNGO). Over time, I began to recognize myself as a "seasoned practitioner" in the area of grants/contracts administration, and eventually became a regular respondent on InsideNGO's community listserve as well as a member of that organization's team of trainers, presenting on both indirect costs and rules and regs (22 CFR 226 - now replaced by 2 CFR 200/2 CFR 700; 2 CFR 230 - now replaced by 2 CFR 200; 22 CFR 228; and the USAID Standard Provisions).

In recent years I've served on InsideNGO's Government Relations Committee and Grants & Contracts Advisory Board. I've presented at InsideNGO annual meetings on USAID Branding/Marking, indirect costs, and FFATA compliance. And I've contributed significantly to InsideNGO comments to USAID, OMB and DOS in response to the rulemaking process.

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