Adapting to Shifting Federal Policies: Strategies for Achieving Community Service Goals in Changing Times

The last few weeks have seen major shifts in federal policies which affect a wide swath of federal grants and grantees. The policy changes have primarily been effectuated through presidential Executive Orders released by the White House. Receiving much attention are the Executive Orders around the topics of diversity, equity, and inclusion (DEI). Notable examples include Ending Radical and Wasteful Government DEI Programs and Preferencing and Ending Illegal Discrimination and Restoring Merit-Based Opportunity.

While there are likely to be complex legal challenges ahead which may affect how the Orders are implemented, they still represent a significant shift in the federal administration’s priorities. Despite the lack of details as to how the shift in priorities will be implemented by various funding agencies, current and future federal grantees will want to heed this shift as it is likely to alter many aspects of grant-seeking and grant management.

The most recent policy changes around federal grants are not entirely unexpected. Each incoming administration has their own priorities, and grants are a primary mechanism for realizing policy priorities through tangible projects across the U.S. Change is the constant in federal grants management.

Communities that received Coronavirus State and Local Fiscal Recovery Funds (SLFRF) monies will remember the experience of keeping up with rapidly changing eligibility, compliance, and reporting guidance. The ability to successfully maintain compliance while also adapting to dozens of guidance changes across several years was determined largely by the robustness of recipients’ pre-existing grants infrastructure (or their ability to rapidly stand up a grants infrastructure).

The changes affect grant-seeking organizations and current grant recipients in different ways (acknowledging that many organizations are both). Strategies for organizations seeking to maintain current grant funding or win grant funding in the future center on balancing structured grants management practices with the ability to adapt to change along the way—the same fundamental strategies needed to manage SLFRF.

By taking measured steps now, grantees can be more competitive in their grant-seeking and more compliant in their grant management.

Strategies for Grant-Seeking, Research, and Pursuance:

1. Adjust Your Mindset: Adopt a growth mindset. This concept, championed by psychologist Carol Dweck, is characterized by the notion that people are able to learn and adapt—sometimes more than they realize—with the right mindset. Organizations can, too. Remember that development is rarely linear, especially in organizations juggling multiple, complex operations and services. The realities of development are often characterized as disjointed incrementalism. Changes in federal priorities can usher in exciting new areas of development previously overlooked, while other areas may slow down for the time being.
   
   
2. Organizational Priorities: Do a deep dive into the federal administration’s priorities, as well as the priorities of funding agencies. Priorities are revealed in strategic plans, Learning Agendas, Notices of Funding Opportunities (NOFOs), etc. Crosswalk those priorities with the priorities of your organization. You will likely find an overlap, perhaps in places you did not expect.
   
   
3. Project Fit: Consider different types of projects for existing and new grant opportunities. Perhaps your entity delivers projects and services which have not previously been a good fit for federal grants. Now is the time to revisit those projects and get them ready for federal grant applications.
   
   
4. Decision-Making Frameworks: Now is also the time to look at your decision-making framework for grants pursuance decisions, sometimes known as the go/no-go process. Consider priority overlap, matching requirements, staff capacity, ongoing maintenance requirements, project size, and compliance and reporting requirements when deciding to go after grants.
   
   
5. Evidence and Evaluation: Implement strong data, evidence, and evaluation policies and processes aligned with the priorities outlined in the Foundations for Evidence-Based Policymaking Act of 2018. Evidence-based policymaking is the process of using the best available research; data; and evidence to design, implement, and evaluate policies, programs, and projects. The goal is to ensure that decisions made by policymakers are informed by reliable, objective information—thereby creating policies that are likely to be more successful in achieving measurable outcomes which address important community issues. Align with federal data priorities, use technology to capture data, and use proven methods to analyze the data you collect.

Community Partnerships: If your organization does not already have strong relationships with other community organizations (governmental, non-profit, quasi-governmental, foundations, corporations, etc.), now is the time to start building relationships based on shared priorities. As funding priorities at the federal level shift, community partners will be called upon to fill those gaps.  

Follow Grants Best Practices: Keep an eye out for changes to federal policies and regulations. Establish strong, thorough compliance practices aligned with the most recent changes to the Uniform Guidance which took effect in October 2024. Work on project design early: beginning to outline information for a grant application a year in advance is not too early. Finally, manage the expectations of all involved and remain flexible.

Strategies For Current Grantees: 

1. Evaluate Your Grant’s Scope of Work (SOW): Take time to thoroughly review the SOW outlined in your grant agreement. Search for any keywords and concepts which will need to be removed or amended (diversity, equity, inclusion, climate change, etc.). Look at how a project’s design can be reworked to include more evidence-based policymaking concepts and practices. It’s important to differentiate between outputs targeted at specific groups versus outcomes and impacts measured through evaluation. (Evaluation results can be disaggregated by groups to get a sense of program delivery methods which may need to be altered.)
   
   
2. Quantify SOW: If your SOW includes aspects which will need to be removed, take time to quantify various aspects of your project. For any aspect which may need to be removed, quantify the percentage of the budget, the total time and effort, and the timeline for completion/period of performance. All of these will need to be addressed in your request to change the SOW.
   
   
3. Request a Revision: After determining what needs to be removed and the impact on quantifiable parts of the project, you will need to determine how you will move forward. You may choose to simply scale down the overall scope of your project or may want to amend the project. 2 CFR 200.308 lays out the requirements for revising your budget and/or program plans. And 2 CFR 200.329 (e) lays out the requirements around reporting significant developments in between performance reporting due dates. Your grant agreement may contain additional requirements. In every case, follow the requirements without deviation, document all changes and the reasoning for those changes, and work closely with your federal program officer or pass-through entity. Ultimately, SOW amendments must be approved by the federal agency or the pass-through entity.
   
   
4. Determinants and Data: If you decide to amend your SOW and need to redesign programmatic components of your project, look at how social determinants of health can be incorporated into your program design, particularly poverty. Concepts and frameworks such as Areas of Persistent Poverty and Historically Disadvantaged Communities should be consulted. Educational attainment, work skills and access to jobs, English proficiency and literacy, social capital, and self-efficacy are among the factors most strongly associated with positive life outcomes.

The U.S. Census and the American Community Survey are highly reliable sources of data on which you may safely rely. In fact, many commonly used indices rely heavily, or entirely, on datasets from the U.S. Census. If use of a particular index is a concern, take the time to research its methodology and find the source data. If the source data comes from a reliable and neutral source, feel free to use that data in its original form to support your project.

While the recent changes in federal grant policies were significant, they present new opportunities: to look at projects which may now be eligible and competitive for federal funding, to consider entirely new funding opportunities, to build new community relationships, to strengthen compliance practices, and to improve data literacy

To learn more about the dedicated resources we have and gain valuable insights on grants management, please visit our Center for Grant Excellence page.

If you need further assistance, please reach out to see how we can help.

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