Williams Adley Merges Expertise and Innovation to Support Monitoring and Compliance for Pandemic Relief Grant

Small Business Administration

Challenge

In response to the COVID-19 pandemic, the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act established the Shuttered Venue Operators Grant (SVOG) program to support ongoing operations of shuttered venues. The nature of the pandemic and the statutory guidelines of the SVOG program required the Small Business Association (SBA) to issue $16 billion in grants within weeks of program standup. Furthermore, many of the shuttered venues eligible for SVOG funding were inexperienced grant recipients. The size, implementation timeline, and nature of the intended recipients compounded into a significant challenge for the SBA: balancing the urgency in awarding much-needed relief to 13,000+ recipients while controlling the quality of program execution and ensuring compliance with grant regulations. To design and implement best-in-class solutions, SBA solicited support from Williams Adley. We assisted SBA with its SVOG program oversight and compliance activities in four key post-award areas:

Audit Expertise – The Uniform Guidance (2 CFR 200) does not establish Federal financial assistance audit requirements tailored to for-profit entities.  Because for-profit and nonprofit entities were eligible for the SVOG program, development of audit requirements for its for-profit recipients was required.

Technical Assistance to SVOG Recipients – The SVOG program was designed to expand Federal financial assistance eligibility far beyond traditional nonprofit recipients. Naturally, first-time applicants and awardees are inherently unfamiliar with grant regulations, especially as they related to the audit requirements. Targeted guidance and expert technical assistance were required to ensure recipients utilized SVOG funding for the intended purposes.

Compliance Support – Effective stewardship of Federal funds requires tailored post-award processes. To manage a program of SVOG’s size, scope, and scale, SBA required the creation of policies and procedures for facilitating SVOG recipient monitoring activities and other key compliance requirements.

Compliance with all applicable Federal regulations – To effectively administer a novel program, the SBA was required to establish an internal audit plan; this plan would ensure the SVOG program was managed in accordance with statutory requirements, award terms and conditions, the Payment Integrity Information Act (PIIA), OMB Circular A-123 Appendix C (A-123), 2 CFR 200, and all other applicable Federal regulations.

Solution

Williams Adley deployed a range of tailored support services to assist the SBA with oversight and compliance of the SVOG program, including the following solutions:

  • Delivered audience-relevant audit expertise and support to the SBA. Williams Adley synthesized years of audit experience with grants management best practices to assist the SBA in developing audit requirements tailored to for-profit recipients and enhancing audit-related information contained in the SVOG Frequently Asked Questions document(s).

  • Developed and executed live webinars to educate recipients on complying with the requirements of 2 CFR 200 and SVOG program regulations. The webinars provided details on Federal grant audit requirements and helped inexperienced grantees understand the 2022 Office of Management and Budget (OMB) Compliance Supplement. Webinars also addressed audit eligibility, audit thresholds, and how to successfully complete a Single Audit or Program-Specific Audit. The team also developed high-quality templates and guides to reduce the audit burden and minimize the learning curve for recipients.

  • Established user-friendly processes and tools to assist the SBA in reviewing independent audits submitted by SVOG grantees, in accordance with 2 CFR 200 and other requirements. By integrating our audit expertise and Federal grants experience, SBA was able to work more expediently and support its program implementation staff with tailored guidance and checklists for reviewing activities.

  • Provided specific process recommendations based on the Payment Integrity Information Act (PIIA) and OMB Circular A-123, Appendix C for the SBA’s Internal Controls Department to ensure implementation of effective monitoring for the SVOG program. We created an SVOG-specific Audit Process Development Plan that established the level and degree of compliance with applicable regulations by leveraging our knowledge of the program, PIIA, and A-123. Further, we delivered tailored technical assistance trainings to the members of SBA’s Internal Controls Department to ensure universal understanding of the Audit Process Development Plan.

Impact

Williams Adley’s tailored and innovative solutions enabled expeditious delivery of targeted and thoughtful technical assistance for SVOG recipients. By equipping recipients with knowledge, tools, and insights, the SBA effectively increased the likelihood of compliance with the SVOG program audit requirements.  Additionally, our customized guides, checklists, and Audit Process Development Plan established an actionable and repeatable framework. These scalable tools position the agency for greater success in conducting post-award oversight and compliance activities in accordance with all applicable statutory requirements. Through our solutions, the SBA is empowered to more effectively administer not just the SVOG program, but any future appropriations within the Agency.