Due Diligence Tips
(Amy L. Sherman, Hudson Institute, 2004)
So you got that government contract. Now what do you do???
Since welfare reform and the passage of the charitable choice rules, some faith-based organizations (FBOs) have—for the first time--competed for, and won, government grants and contracts to underwrite their social service programs. A recent survey of nearly 400 faith-based contractors showed that over half, 56 percent, were new to formal government partnerships.[1]
While government contracting with FBOs is on the rise, it remains controversial. Some critics fear that FBOs will not adequately protect clients’ civil liberties or will use government funds to promote a religious agenda. Others worry that FBOs that receive government funding will compromise their mission or be subjected to intrusive, entangling government monitoring. Clearly, faith leaders need to consider carefully both the potential benefits and costs of receiving government funding before deciding to compete for such.
But the careful thinking and planning doesn’t stop once the decision to compete for government funds is made. Once government funding is awarded, FBOs need to put into place deliberate, intentional strategies and practices that will help them, simultaneously, to safeguard their religious character and faithfully obey the rules regulating their contract.
Interviews with faith-based contractors that have successfully navigated the waters of government funding reveal several such practices from which new contractors can learn. Several tips on how to show “due diligence” in complying with regulations are listed below.
(1) Be transparent about your religious character. Commit yourself to open, straightforward, clear, consistent communication about your religious identity to your volunteers, service beneficiaries, donors, and government. Make it your goal to allow potential program participants and government partners to make choices about involvement with your organization on the basis of full and accurate information about your program content, ethos, goals, and methodology.
(2) Separate your government funds from your private donations. Maintain separate accounts and do not co-mingle funds. You will need to be able to show auditors how every dime of your government contract/grant was spent.
(3) Hold explicitly religious programs at different times or in different locations than the publicly funded services. Receiving government funding does not mean you must stop holding worship services or prayer meetings. It does mean that you must conduct those activities in a way that makes them clearly distinct from the social services you are offering that are paid for by public dollars. Let’s say your church owns a small community center building that sits next door to the sanctuary and you use it for your publicly funded job training program that operates Monday through Thursday mornings. You could plan to hold any optional religious programming, such as a prayer meeting or Bible study, in the church sanctuary in the afternoons. If the same facility is used for both the publicly funded programs and religious programs, you might want to hold the latter on different days than the former.
(4) Clearly communicate that client participation in explicitly religious activities is voluntary and optional. Feel free to inform participants in your government-funded program about the various religious services your organization may sponsor, just be sure that they understand that their attendance is not mandatory and will have no bearing whatsoever on their receipt of social services funded by your government contract or grant.
(5) Be intentional, deliberate, specific, and public about articulating to clients what their rights are. You may want to consider posting a sheet that lists clients’ rights in a prominent, public part of your facility. Provide written information to clients that emphasizes that their participation in explicitly religious activities is voluntary. Let them know that they have a right to seek an alternative provider of services if your program does not suit them.
(6) Have a client’s grievance procedure in place. It doesn’t have to be fancy. You just need to have an intentional, published process that indicates what steps a disgruntled client can take to air his/her grievance. Clients need to know to whom they can register a complaint, how to go about doing so, and what the procedure will be for seeing that program leaders address the issue.
(7) Provide specialized training for staff and volunteers about the rules governing the government grant or contract, so that everyone knows what activities are permissible. This training should be formal and documented. Program leaders should provide written handouts that describe the content of the training (and keep such handouts on file, so that outsiders who want to know what topics were covered in the training program can see for themselves). The training should cover issues such as explaining clients’ rights to program participants and how to “bill” staff time (hours devoted to the government-funded program can be charged to the government grant or contract but hours spent conducting religious activities cannot be). Provide staff with timesheets they can use to document the use of their time. You might also want to give staff and volunteers a list of examples of allowable and unallowable uses of government funds and role play different scenarios and how they should be handled.
(8) Have a brief, written policy about how to respond to spiritual inquiries from clients, and inform all staff and volunteers involved in the government-funded program of this policy. One good approach is to train staff and volunteers that if a query is raised by a program participant during the government-funded program, they should respond briefly and politely and then invite that person to have a more in-depth conversation with them at a time outside the scheduled times of the government-funded program. You organization can create an environment in which staff, volunteers, and program participants are free to speak autobiographically about their lives of faith. And you can welcome and lovingly respond to spiritual inquiries initiated by program participants. Just be sure that detailed conversations about inherently religious topics take place separate from the times of the government-funded program.
(9) If your organization has required behavioral standards for paid staff, be sure that your written literature (e.g., personnel policy manual) and verbal communication about those standards links them explicitly to your character as an FBO. You may assume the link between your religious beliefs and certain behavioral practices, but for those outside your creed, the connection may not be readily understandable. So, be sure that your personnel policies make it explicit that the required behaviors (or impermissible behaviors) are rooted in the religious beliefs of the organization. Ensure, too, that everyone in the organization, regardless of their position, receives the same communication about these standards and make the standards public knowledge. This will put your organization in a stronger position when you use such standards in employment-related decisions.
Over 90 percent of the faith-based contractors interviewed in the survey noted earlier assessed their relationship with government as positive and indicated that, given the opportunity, they would seek government funding again in the future. While working with government is not the right choice for all FBOs, some have found such a partnership beneficial for expanding or enhancing their programming. One key to fruitful collaboration with government is employing deliberate, intentional strategies, like those listed above, that help to ensure compliance with government’s expectations. Practicing these deliberate procedures will help you to protect your organization from unfair charges of abuse or noncompliance and will signal that you are serious about the accepting the duties attached to government funding.
[1] John Green and Amy L. Sherman, Fruitful Collaborations: A Survey of Government-Funded Faith-Based Programs in 15 States (Hudson Institute: 2002).
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