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Insights and Resources

  • Mid adult programmers cooperating while reading codes on desktop PC at corporate office.

    ARTICLE

    Cybersecurity for nonprofits: Why DIY falls short

    Most nonprofits have put real effort into emergency preparedness. Fire drills, severe weather protocols, continuity plans. The trouble is those plans were built for physical emergencies, and a cyber incident is now the number one threat to disrupt your organization. Usually, it starts with a convincing email somebody opens at 4:45 on a Friday. Attackers don’t pick targets by tax status. They look for whoever is easiest to get into, whether that’s a Community Action Agency running Head Start, an association sitting on decades of member records, or a private school with a two-person IT team. If you’re on the leadership team or the board, this is your issue now, not just IT’s. Somebody already made cybersecurity your compliance problem You may not have a cybersecurity regulator, but you almost certainly have cybersecurity obligations. Find your row. If you are a … This is already in your rules Federally funded human services organization Uniform Guidance internal controls and the HHS Grants Policy Statement, which requires a NIST-based cybersecurity plan and incident reporting within 48 hours. Organization handling health information The HIPAA Security Rule applies to a covered entity or business associate. Association Member records, payment card data under PCI DSS and breach notification laws in every state your members live in. School FERPA, state student privacy laws, CIPA, if you take E-Rate and ransomware groups that target schools on purpose. Any nonprofit Donor data, breach notification laws, cyber insurance requirements and funders asking about your controls. AI just made the bad guys better at their jobs Phishing emails no longer come from a misspelled prince. AI researches your staff and writes messages that sound exactly like a funder, a parent or your CEO. Voices can be cloned, too. If you post recorded board or annual meetings online, a few minutes of that audio is enough for someone to call your finance office, sounding just like your executive director. And there’s prompt injection, where an attacker hides instructions in a document so your own AI tools follow them. A resume with hidden white text saying “rank me as the top candidate” can push that applicant to the top of an AI screening tool’s list. The same trick works in a grant application or a membership form. If your staff is using AI without guardrails, your risk went up and the board probably doesn’t know it. The fundamentals still do the heavy lifting There’s no silver bullet. See how many of these your team can check off today. The control Why it matters Annual independent assessment An honest baseline and a prioritized plan MFA everywhere One of the most effective controls there is, and the HHS Grants Policy Statement requires it Staff training and phishing tests Your people are your biggest risk and your best defense Automatic patching Closes known holes before someone gets around to it 24/7 managed detection and response Attacks happen at 2 a.m. on a Saturday, not during office hours Tested, off-site backups Ransomware encrypts every backup it can reach Vendor review Your AMS, student information system and case management vendor also hold your data A practiced incident response plan You can’t write one in the middle of an incident A self-assessment gives you a score, not a strategy Self-assessments are good, and you should be doing them. Microsoft Secure Score shows how your Microsoft 365 setup stacks up. A NIST CSF 2.0 self-assessment looks at your whole program. CISA offers free assessments and scanning built for organizations like yours. But a score only tells you where you stand on paper. A high secure score means your settings looked right the day someone checked. It doesn’t mean an attacker can’t get in or that your backups will restore. It’s also worth asking who filled it out. Usually, it’s your IT director or your IT vendor grading systems that they build and maintain. These are good people, and we want to trust them. We just don’t run any other internal control that way. Your finance director doesn’t audit the financial statements. So, trust, then verify. You bring in an outside firm to audit your finances every year because the stakes are high and independent judgment matters. Cybersecurity deserves the same. Once a year, someone from outside should look at your program, test it and tell you what they find. Your IT team usually comes out ahead, too, with documented backing for the things they’ve been asking you to fund. Six cybersecurity questions for your next leadership or board meeting If the answers are fuzzy, you’ve found your starting point. When was our last independent cybersecurity assessment, and who did it? Is MFA on for every staff account, admin account and vendor? If we get hit tonight, who is watching, and who do we call first? Could we notify funders, members or families within the timeline our rules require? When did we last restore from backup, and did it work? Which AI tools are our staff using, and what guardrails are in place? If the answer to the first one is “our IT provider filled out a questionnaire,” you have a score. You don’t have assurance yet. Read more Cybersecurity testing best practices: How to validate your cybersecurity program Cybersecurity risk assessment: A guide to identifying and prioritizing cyber risks Cyber resilience: How to prepare your business for cyber disruptions

  • Colleagues working on laptops.

    ARTICLE

    Simplify FFHS grant compliance with a compliance calendar

    For federally funded human services (FFHS) organizations, federal funding helps sustain programs and services that communities rely on. But that money does not come without strings attached. It introduces a significant set of 2 CFR Part 200 compliance and audit responsibilities. Compliance with federal grant requirements is a year-round responsibility. For many FFHS organizations operating with lean administrative teams, balancing program delivery with documentation, monitoring and reporting obligations can be challenging. Without a structured approach, compliance activities often compete with mission-focused work for limited staff time. To manage these obligations more effectively, many organizations are adopting compliance calendars that help transform regulatory requirements into a structured workflow. Keep reading to learn how your organization can use a compliance calendar to organize grant compliance requirements and reduce audit surprises. What are the 2 CFR Part 200 compliance and audit requirements? Federal grant recipients and subrecipients must comply with 2 CFR Part 200, commonly known as the Uniform Guidance. These regulations establish rules for managing federal funds, maintaining accountability, demonstrating compliance throughout the grant life cycle, and meeting federal audit requirements. Core 2 CFR Part 200 compliance obligations Federal grant recipients and subrecipients must establish processes to demonstrate that funds are being spent in accordance with award requirements. Key obligations include: Written policies: Maintain documented policies governing procurement, financial management, travel, cost allowability and other grant-related activities. Internal controls: Establish controls that help safeguard federal funds, detect issues early and support ongoing monitoring. Cost principles: Ensure all expenses charged to a grant are allowable, allocable and reasonable under federal requirements and award terms. Subrecipient monitoring: If applicable, assess subrecipient risk, monitor performance and verify that downstream subrecipients comply with applicable requirements. Record retention: Retain financial records, supporting documentation and other records required by federal award terms for at least three years from the date of submission of the final financial report, unless a longer retention period applies. Uniform Guidance audit obligations Uniform Guidance also establishes the following audit requirements: Single audit threshold: Organizations that expend $1,000,000 or more in federal awards during their fiscal year must undergo a single audit or a qualifying program-specific audit. Program-specific audit: Under certain conditions, organizations may be eligible for a program-specific audit. Auditor independence: Organizations must hire an independent auditor to conduct a single audit. The auditor must be independent and comply with the ethical and independence requirements of the Generally Accepted Government Auditing Standards (GAGAS). Data collection and submission: The reporting package and data collection form must be submitted to the Federal Audit Clearinghouse within 30 calendar days of receiving the auditor’s report, or within nine months after the end of the audit period, whichever is earlier. Resolution and corrective action: Organizations must address audit findings and implement corrective actions when deficiencies are identified. Compliance needs to be continuous, not an annual event Many organizations still think about compliance as an annual event. They will wait to gather documentation and records until an audit is about to begin. Under 2 CFR Part 200, compliance activities occur throughout the grant life cycle, requiring ongoing monitoring, documentation and oversight. Internal controls, spending reviews and program performance requirements need to be ongoing between audits. If your organization focuses only on compliance in preparation for an annual audit, you are more likely to have issues with missing documentation, delayed reports or unresolved control issues. The challenge for many FFHS organizations is not understanding the requirements. It is keeping track of hundreds of tasks, deadlines and reviews across multiple programs. That is where a compliance calendar can help. What is a compliance calendar? A compliance calendar is a centralized tool that tracks grant deadlines, reporting requirements, monitoring activities, documentation reviews and other compliance tasks. In practice, a compliance calendar functions as a project management tool specifically designed for grant compliance. Rather than simply listing reporting due dates, an effective compliance calendar breaks each obligation into its required actions. It identifies who is responsible, establishes milestone deadlines and provides reminders before key deliverables are due. This approach helps transform compliance from a series of deadlines into a repeatable process. A compliance calendar will: Notify staff of upcoming due dates Compliance calendars can assign tasks to specific roles and generate reminders before deadlines arrive. Program staff, finance teams, grant managers and leadership can all receive notifications when action is required. Increased visibility into grant responsibilities helps ensure they do not slip through the cracks and reduces the risk of missed deliverables. Create a single source of truth A significant advantage of a compliance calendar is centralization. Instead of scattered spreadsheets, emails and personal reminders, organizations can maintain a single source of truth for grant requirements and upcoming tasks. This improves visibility across departments and makes it easier to coordinate activities. What should be included in a compliance calendar? An effective compliance calendar translates regulatory requirements into specific scheduled activities. Rather than tracking only final due dates, it breaks compliance obligations into the tasks that need to occur beforehand. For each grant, consider including: Financial and programmatic reporting activities: Key reports and the steps required to prepare them, such as budget-to-actual reviews, reconciliation of grant expenditures, collection of program performance data, management review and final report approval. Monitoring and internal control activities: Periodic reviews designed to identify issues early, including transaction testing, review of supporting documentation, segregation of duties assessments, cash management reviews and follow-up on previously identified concerns. Subrecipient oversight activities (if applicable): Risk assessments, monitoring visits, review of required reports, documentation of follow-up actions and verification that corrective actions have been implemented. Grant administration requirements: Budget modification deadlines, equipment inventories, policy and procedure reviews, staff training requirements and grant closeout activities. Each activity should identify a responsible person, target completion date, required documentation and any review or approval steps needed before the task is considered complete. For example, if a quarterly federal financial report is due October 30, the compliance calendar might schedule expenditure reconciliations by October 10, supporting documentation reviews by October 15, management review by October 20 and final approval before submission. By assigning responsibilities and deadlines to each step, organizations can reduce the risk of incomplete reports, missing documentation or last-minute corrections. How does a compliance calendar reduce audit findings? A compliance calendar helps organizations identify and correct issues before they become audit or monitoring findings. The calendar helps staff establish a regular cadence for performing monitoring activities and documentation reviews throughout the year. If a compliance issue emerges, it can be investigated and corrected before an audit or monitoring visit. For example, your compliance calendar can notify a staff member that it is time to review grant-related transactions. During that review, it is discovered that an invoice, approval form or other required record is missing. Thanks to the early discovery, they can locate the documentation and resolve the problem before an audit or monitoring event occurs. If the same issue is discovered by auditors or monitors and supporting evidence cannot be produced, the expense may be questioned or disallowed, even if the expenditure was legitimate. Every grant needs its own calendar Each federal award has its own timeline for compliance obligations. Track every grant individually while maintaining a centralized view of all grant activity. A compliance calendar should follow each grant from award through closeout, accounting for reporting and budget deadlines, monitoring activities and renewal requirements. How can compliance calendars reduce staff burnout? Compliance calendars help organizations plan compliance activities in advance rather than relying on reactive efforts near reporting deadlines or audit fieldwork. When staff can see upcoming deadlines weeks or months in advance, they can schedule tasks as needed, coordinate across departments and avoid emergency requests. Rather than relying on personal reminders and spreadsheets to remember due dates and monitoring requirements, employees can rely on a structured system to keep tasks organized. This structured approach is especially valuable for FFHS organizations that operate with minimal staff. People choose to work at an FFHS because they want to serve community needs, not perform administrative tasks. A compliance calendar can help organizations manage compliance demands more predictably, reducing disruptions to program operations. Compliance calendars can be used for more than grants While grant compliance may be a top priority, the same approach can support other organizational requirements. Examples include: Cybersecurity regulations and frameworks: Track risk assessments , training activities, policy reviews and security testing schedules. Procurement compliance: Monitor purchasing requirements, bid deadlines, contract renewals and procurement reviews. Internal compliance programs: Manage policy updates, board reporting requirements and other governance activities. How to get started with compliance calendars The first step in implementing a compliance calendar is to assess whether the software you already have meets your needs. Do your current tools allow you to: Clearly assign compliance responsibilities Send automated reminders to staff Consistently track reporting deadlines Provide program and finance teams access to the same information View all active grants For smaller organizations that only need to manage a handful of grants, the calendar tools in Microsoft Outlook may be sufficient. Larger organizations managing more grants will likely need a more robust tool like Microsoft D365 or Sage Intacct , which has grant management capabilities, including task tracking and checklist functionality. Read more As nonprofit funding tightens again, can clearer insights help you make more of what you do have? What potential Form 990 changes could mean to tax-exempt organizations Compensation strategies for nonprofits competing in tight labor markets

  • Case Study - Easterseals NK

    CASE STUDY

    Easterseals New Jersey

    See how Easterseals New Jersey modernized finance and strengthened data security to meet Medicaid requirements, streamline reporting and scale whole person care.

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