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State expands grants oversight: pre-award risk checks, public evaluations and authority to suspend grantees

February 17, 2025 | 2025 Legislature MN, Minnesota


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State expands grants oversight: pre-award risk checks, public evaluations and authority to suspend grantees
Stacy Christiansen, Deputy Commissioner at the Minnesota Department of Administration, told a joint legislative committee that the Office of Grants Management (OGM) has implemented a slate of changes from the 2023 state government finance bill intended to strengthen oversight of state grants and reduce fraud, waste and abuse.

OGM has rolled out a mandatory pre-award risk assessment process that became effective Jan. 15, 2024; agencies must conduct those assessments for potential grantees and gather financial and background documentation when applicable. Christiansen said OGM has recorded more than 1,500 pre-award risk assessments, 56 instances where agencies requested additional information to resolve concerns, and that “I believe it’s been 3, 2 or 3 grants” that were terminated using the office’s new authority.

The new statutory framework also requires agencies to upload performance evaluations for grants of more than $25,000 issued after April 1, 2024; agencies must post evaluations within 60 days after grant closeout. Christiansen said the evaluation portal will let other agencies and the public view grantee performance information and that “most grant evaluations will be posted in or by the summer of 2025.”

Why it matters: those changes reallocate certain oversight responsibilities from individual agencies to a stronger central policy and compliance office and provide public transparency about grantee performance. The reforms affect state agencies that award grants, nonprofits and private entities that receive them, and Minnesota taxpayers who fund the appropriations.

What OGM can and cannot do

OGM’s statutory authorities, Christiansen said, now include the power to establish and enforce statewide grants management policies, audit grants, require agencies to cooperate with OGM oversight, suspend or debar grantees for up to three years for cause, and terminate grant agreements if continued performance “is not in the best interest of the state.” Christiansen emphasized that many aspects of grant management remain decentralized: "the ultimate authority in grants management sits within individual state agencies," she told the committee.

The committee discussed where authority sits for not awarding a grant to a potential grantee. Christiansen explained that the current statutory scheme gives agencies more explicit authority to delay or not award grants to potential grantees after a pre-award risk assessment; for legislatively named grantees, agencies must notify legislative committee leaders and may delay awards until the next legislative session. Those processes include contestable administrative steps under chapter 14. Christiansen said OGM receives notifications when agencies choose not to award and that, in the three terminations she referenced, "the state agency notified us that they wanted admin to kind of utilize that authority."

Pre-award checklist and grantee requirements

Christiansen described the information agencies can require as part of the pre-award risk assessment: recent IRS Form 990 or board-reviewed financial statements for nonprofits; federal and state tax returns and current financial statements or bankruptcy certifications for business entities; evidence of good standing with the Minnesota Secretary of State; independent audits when statute requires them; and certifications that specified officials have not been convicted of a felony financial crime in the last 10 years. OGM published a toolkit that contains workflows, checklists, sample letters, financial-review forms and risk-plan templates to support agencies in implementing the statute.

Training, staffing and scope

Christiansen said OGM was created in February 2007 and that the office expanded after 2023 appropriations. She said the Department of Administration’s own grants portfolio is about 130 grants totaling just under $60,000,000 and that OGM is funded for 12 positions with eight staff currently on board; additional positions will be filled as implementation continues. OGM offers nine on-demand trainings (seven produced in 2024), and Christiansen said roughly 300 state staff attended at least one training since July 1, 2024. She described ongoing development of learning pathways and an “introduction to grants administration” three-course series that OGM expects to make available in the state’s online employee training system.

Enterprise grants management system study

OGM has been running a feasibility study on a single enterprise grants management system. A consultant has worked on the study for about 11 months and Christiansen said the study will examine technology options, organizational changes, staffing needs, high-level system requirements, estimated costs and an implementation roadmap. Department staff later clarified the legislative appropriation for the study: "the legislature appropriated $735,000 in fiscal year 2024 and $201,000 in fiscal year 2025," Mr. Johnson told the committee, for a total appropriation of $936,000; Christiansen earlier described the amount "approximately $800,000," a figure the committee staff clarified as the originally cited approximate amount in OGM remarks.

Monitoring and enforcement questions from lawmakers

Committee members pressed Christiansen on enforcement and on whether OGM should use unannounced verification visits. Christiansen said current OGM policy covers monitoring visits that agencies and grantees prepare for in advance; she said unannounced verification visits are not in statute or in current policy and would be “a different kind of tactic” that the legislature and agencies could consider. The session also explored overlaps with other state offices: Christiansen said internal-controls and fraud-prevention training is currently within the scope of Minnesota Management and Budget’s internal controls unit and that OGM intends to partner with MMB on fraud-detection and prevention training.

Scope of state grants

Christiansen told the committee that the state’s grants landscape is large and decentralized. OGM counts 32 state grant-making agencies and about 775 grant programs subject to OGM policy; in fiscal years 2020–2023 the state executed an estimated 17,000 new grant contracts and managed about 30,000 active grant contracts. Christiansen said the partial data OGM currently has from nine agencies totals about $140,000,000 but that figure is incomplete and OGM is collecting more data.

Committee follow-up and next steps

Members signaled interest in clarifying statutory authority, potentially changing discretionary "may" language to mandatory "must" for particular enforcement steps, and exploring unannounced verification visits and broader fraud-prevention training. Christiansen said OGM is still implementing the 2023 changes and will continue building capacity; she also welcomed input on any legislative changes the committee might pursue.

Votes at a glance

Approve minutes from 02/10/2025 — Motion: "Approve minutes from 02/10/2025." Mover: Vice Chair Anderson. Second: not specified. Outcome: approved by voice vote; no roll-call recorded.

Ending note

Committee members scheduled further hearings to continue oversight and to consider statutory changes; Christiansen said she is preparing bill language and welcomed feedback.

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