06/10/2026
Expert guidance powered by Kim Joyce & Associates — elevating the practice of grants management nationwide.💡 🔎
Never assume a cost is allowable just because “we’ve always done it that way.”
In grants management, past practice is not proof of compliance. The Uniform Guidance doesn’t care about organizational habits — it cares about necessity, reasonableness, allocability, consistency, and alignment with the award terms.
When grantees rely on historical precedent instead of current regulations, that’s when findings happen. A stronger approach:
📌 Re check the cost against 2 CFR 200 Subpart E
📌 Confirm it aligns with the specific award conditions
📌 Ensure your policies and actual practices match
📌 Document the rationale every time
Remember, good grants management isn’t about doing what’s familiar — it’s about doing what’s defensible.
- D'Laun Oubre, MBA
KJA Director - Grants Management Services
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