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Ethics FAQs
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GPA Ethics FAQs
Updated June 2020


All GPA members have agreed to abide by the membership’s Code of Ethics. However, we encourage all grant professionals to abide by this code. GPA has authority to review and address only its membership.

 

The numbers following responses refer to the applicable standards in the GPA Code of Ethics.

Ethics Inquiry Process
Standards of Professional Practice
Professional Obligations
Solicitation and Use of Funds
Presentation of Information
Compensation


Ethics Inquiry Process

  • I think that one of my colleagues is not following the GPA Code of Ethics. What do I do next?
    The first step is to look at the list of Frequently Asked Questions to see if your question is addressed. If it isn’t or if you need clarification, contact the CEO either by telephone, letter or email with your concerns. A number will be assigned to your inquiry (confidential reporting) and recorded in the Ethics Logbook. The CEO will write a brief summary and forward it to the Ethics committee chair for review by the committee. If necessary, the form can be obtained from the CEO. To keep things consistent and equitable, all complaints must be on the required form. Click here for more information on the process.

  • I just received a note from the GPA national office telling me that I have been turned in for an ethics violation. What happens next?
    The CEO will send you the appropriate forms to respond to the complaint. Once returned, they will be sent to the Ethics Committee chair for review by the committee to determine if a violation has/has not occurred. Click here for more information on the process.

 

Standards of Professional Practice 

  • How do I discuss the importance of ethics with Executive Directors?
    It may be helpful to discuss ethics in a framework of risk management. The GPA Code of Ethics provides a professional code of conduct based on professional standards and the concept of responsible stewardship of resources and information. These standards reduce the likelihood of management practices and outcomes that result in penalties from funders, o repayment of grant funds, or audit findings. Therefore, ethical standards reduce the likelihood that grantees will experience negative consequences or disbarment. Beyond avoiding penalties, when grantees handle grants and contracts ethically, maintain transparency, and assure that what is promised can be delivered successfully, the funders begin to feel that they can trust the grantee. This often results in additional funding opportunities, and a greater likelihood of successful applications. (1, 2)

  • What is the best way to communicate with the Board level regarding grants (proper use, application process, etc.)
    Communicating with the Board of Directors is best accomplished in concert with the Executive Director or Administrators. How to coordinate this will often depend on the size and complexity of the nonprofit, and on the grant process knowledge of the Board Members. 

    A first step might be to learn how the Board of Directors currently operates and how the Board is involved in the grant process. Building relationships and working within the Board structure is the key to success. Start with research – what are current processes that include the Board? Are there Policies and Procedures in place that guide the Oversight and Accountability role of the Board? Is the organization at a point when a Development Committee has been established? Is the Board a resource to the nonprofit – do members donate financially to the nonprofit? What expertise does each Board Member bring to the nonprofit? Do Board Members help the organization connect with private and corporate foundations (hard resources) and other influential community members (soft resources)? 

    Be ready to educate or train. Without a solid understanding of the grants process, the Board may have unrealistic expectations, make impossible demands, or focus on dollars that do not move the mission forward. There should be a shared understanding of pre-award and post-award requirements, research to identify funders that support the mission and strategic plan, how the application process works, what is “allowable,” and the realization that all funders are different. 

    Board communication can come in many forms.  It can be a weekly or monthly report.  It can be in-person participation at weekly or monthly meetings, or in sub-committee meetings.  This really depends on current meeting schedules and the structure of the Board.  The important role for any grant professional is to be the expert in grantsmanship.  Some grant pros even participate in budget meetings to be aware of what is needed and a priority for the organization.  This often depends on leadership.  Remember, always train leadership and BOD members to avoid mission-creep and to align all grant applications to the organizational strategic plan.

    Recent events have highlighted the issue of diversity, inclusion, and equity on the Board of Directors and leadership staff. Some funders have requested information on Board Member race, gender, and affiliations in the past, but we anticipate this to become immediately relevant and boards should expect to share this data with funders. If the Board of Directors and leadership staff do not reflect the community served, there should be a plan in place to achieve diversity, inclusion, and equity for the organization, including the board leadership. (1, 2)
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Professional Obligations

  • What are the best ways to address the “shenanigans” that come up in the course of being a grant professional, especially when it is difficult to leave the job.
    Depending on the nature of the “shenanigans,” here are some suggestions. (1-6)
    • There is less risk of losing the funding if you get approval from the funder to change the budget before you spend money on something. Would you like me to reach out?
    • Funders like to hear from their grantees and find out how things are going. Maybe we could send an email and tell them about the challenges we are facing and ask for some guidance? If we build a good relationship with them, they may give us more funding later.
    • I would like to share this Code of Ethics that I follow with you. You can see under #x that what you are proposing may be considered unethical in my profession. Would you like to talk about some other options for addressing this situation? 
    • I would love to offer an alternative course of action that might save you having to pay the money back later. Do you have time to chat about this?
    • It looks like we are going to have to report on our progress soon. Can you share with me how you are tracking these measurable goals we promised so that I can prepare for the report? If you are having trouble, I may be able to help.
  • There is a capacity building grant program that could help our agency purchase desperately needed software. A software company has approached us with the idea that they will write the grant application and, if awarded, we would use the funds to purchase their product. What should we do?
    While this offer may sound like a great deal, it presents many ethical concerns. You are being asked to apply for funds on behalf of a private organization that is not necessarily an eligible recipient. Clearly this would be misleading to the funder. In the GPA Code of Ethics, it states “Members shall not be associated directly or indirectly with any service, product, individuals, or organizations in a way that they know is misleading”. This predicament involves the procurement standards of your agency as well, or in the case of federal grants, regulations outlined in 2 CFR 200—Uniform Administrative Requirements, Cost Principles, And Audit Requirements for Federal Awards – Procurement (§200.318) and Conflict of Interest (§200.112). Noncompliance puts your agency at risk of a finding in your single audit, or suspension of all federal funding. (3, 4, 5)

  • As a consultant, I was able to work with a funder on a project.  Once this funder announced a Request for Proposal for the project, I was contacted by a new client to apply for this application.  It was clear to me that the client knew I had been involved in the project design.  What should I do?
    This is something you should discuss with the funder and it would have been appropriate to discuss this probable conflict of interest, whether you did this work pro bona or not.  Conversations about conflict of interests, perceived or real, are not always easy; however, as grant professionals we have an obligation to 1) disclose all relationships that might constitute conflicts of interest and 2) not be associated directly or indirectly with any service, product, individuals, or organizations in a way that they know is misleading. As a consultant, your obligation is to the client you already have, even if the project is complete.  (3, 4, 6)
  • Writing a grant for a sponsorship – Sponsorships can be very different from grants for projects. What do I need to know?
    Sponsorships often have benefits associated with the gifts.  You will want to ensure that the benefits promised are being fulfilled properly, that the benefits do not create private inurement to the donor, and that they do not violate your own conflict policy.

    Many corporate sponsorships come from both the philanthropic arm and marketing arm of a company. The grant application formats are often similar between the two sources of funds.  However, if you are requesting funds from the marketing arm, there are often slightly different benefits discussed in the proposal. You will want to take into account the type of products a company produces to make sure the sponsorship makes ethical sense for your organization’s mission. For example, a cancer agency would not accept funding from a tobacco company.

    Policies such as gift acceptance and naming policies at your organization can reduce your risk when it comes to sponsorships. With sponsorships, creating a sponsor contract that outlines the funds being donated, the benefits (if any) the sponsor will receive in exchange for the gift, and timelines will avoid any misunderstandings on expectations.  The sponsorship contract should reference your policies in case a sponsor does something illegal or reflects poorly on your organization.  This will protect your agency if you decide to return a gift and or change the name of a building or program.  Inherently, people and companies are good, and you will not have to worry about these policies.  However, you need one in place prior to accepting a sponsorship to reduce your agency’s risk. (1, 2)

  • As a member of a grant writing team, I have been asked to collect signatures of consortium partners on a memorandum of understanding. I was instructed to “forge” signatures if I could not find the appropriate person. Is this legal?
    No. Unless the appropriate person who is to sign the paperwork has given you permission to sign on their behalf, this is in direct violation of local, state, and federal laws. Under no circumstances should a GPA member “forge” the signatures of others. Alternatives may include finding another authorized signer at the organization or contact your legal counsel for advice about setting up a proxy. (1, 2)

  • A colleague of mine frequently indicates she has received a master’s degree to other professionals, and has it listed on her professional resume. However, in private she confided that she did not complete the required thesis within the time frame required. Should I tell my employer?
    A grants professional must act according to the highest ethical standards of their institution, profession, and conscience. We suggest that you first speak with your colleague and urge her to be honest about her credentials. If your colleague is not willing to correct her information, then you should tell your employer. You and your organization may not misrepresent anyone’s credentials or provide false information in a grant proposal or application. (1, 2, 5)

  • I have been asked to evaluate a grant opportunity in an area for which I have no prior expertise. Is it wrong for me to refuse the assignment? Would it be better for me to find an alternative solution for the client before I refuse? 
    GPA members should be truthful about their individual capabilities. If the evaluation or grant writing request is beyond the scope of your education and/or expertise it is appropriate to tell the agency. (1, 7)  

  • I am a consultant, and my best client has just told me that they “doctored up” a set of minutes for a meeting that didn’t occur in order to be eligible for a grant. The funds have been awarded already, and I don’t know what to do. On the one hand, I know that what they did was wrong; on the other hand, if I report them (even anonymously) I’m certain I’ll lose them as a client. The person who did this feels really bad about it and she’s afraid she’ll get caught. What do I do?
    This is a clear ethical violation and you have an obligation to act. You also need to state that this behavior can be seen as contractually illegal by the grantor. The best option would be to help your client see why she should contact the grantor to discuss options. It is important for them to work with the grant-maker to create a relationship based on trust so that they continue to be eligible for future funding.

    If the client refuses to contact the grant-maker, your obligation is to contact the grant-maker confidentially and let them know that you have reason to believe that the proposal contained fraudulent information. They will decide what action to take from there. From an ethical position, the issue of where or not you lose them as a client should not be a determining factor on how you handle the situation. (1, 2, 5) 

  • I am an independent consultant and I’ve recently noticed that one of my occasional clients changes the meaning behind their acronym periodically.  When I explained to them that what they were doing wasn’t honest, they were really embarrassed and immediately saw that they should make a decision about the meaning of the acronym and stick with it.   We’ve submitted four proposals in the last 18 months; do I need to take any additional action?
    In this case, the best course of action is to counsel them to make the decision about their name, and then have them make contact with the grantors who funded them under the “wrong” name. (1, 5)  

  • What happens if a consultant is contracted to write a proposal, but doesn’t follow through with anything and just keeps the money?
    If a member has agreed in writing to provide services, it is unethical for the member not to perform the work and could also result in adverse legal consequences to the member. If an Ethics Violation is filed with GPA, the Ethics Committee would likely find the member in violation and recommend that the consultant’s membership be terminated. The Ethics Committee would likely forward the complaint to the Grant Professionals Certification Institute if the consultant is certified. (1, 5, 6 and 11)

  • Is it possible for me to pursue a grant opportunity on behalf of my client without the expressed consent of my client? 
    Unless the grant professional has the consent of the client beforehand, they may not pursue the grant opportunity. The grant professional must not step beyond the contractual boundary between the client and themselves. (1, 3, 6)

  • Is it ethical for a grant professional to work on applications for submission to the same funder from multiple clients?
    Yes, as long as the grant professional is transparent with all clients to the fact they are working on multiple proposals for the same funder. A grant professional should reassure all clients they will be attentive to their individual agency’s needs and write the proposals accordingly. The grant professional should take care to ensure no privileged information from either client is shared with the other. Also, the grant professional should stay mindful of the research they conduct for a particular application/proposal. If research is completed that potentially assists both clients at the same time, then those clients should share the cost of research evenly. Charging multiple clients for the same research is a breach of ethical standards. (1, 3, 4)

  • I am on the board of a foundation that awards grants to organizations with a 501(c) (3) designation. Is it OK for me to help an applicant develop an application that I know the review board will likely fund if I tell them I like it?
    The grants professional should disclose their relationship to the applicant and the degree to which they were involved in the application. They should recuse themselves from any decision on funding. (1, 3, 6)

  • Is it permissible for me to “moonlight” and write grants for other entities? 
    Yes, provided you get permission from your current employer, do not use or share proprietary information with other entities. (1, 3, 4)

  • Recently, I attended training where the presenter was a member of GPA. Throughout the session, misinformation was given on a number of different topics, including, use of grant monies, reporting requirements, management of funds, confidentiality and compensation. What should I do about this?
    It depends. This question does not have enough information to render a definitive answer. If the presenter intentionally and deliberately provided false information, it would be an ethics violation. Share the correct information with the presenter and find out if they are willing to correct. If the misinformation is intentional, please submit a query to the Ethics Committee. (1, 5, 8)

  • A grant professional has been invited to sit on the board of directors for a nonprofit agency for which they provide grant writing services. Is there a conflict of interest and should they accept or decline the invitation? 
    The GPA Ethics Committee recommends that grant professionals review issues concerning this type of potential conflict of interest on a case-by-case basis. 

    The GPA Code of Ethics does not prohibit a GPA member from serving on the board of an agency and simultaneously receiving remuneration for services from that agency. The determination of compensating a board member for services is particular to an organization. However, it is best to undertake this type of arrangement with a Board Approved Policy in place. It is recommended that the grant professional reviews the board's conflict of interest statement regarding business dealings with board members. The GPA Ethics Committee also recommends that a grant professional who serves as a board member recuse themselves from all voting decisions pertaining to the hiring/contracting of a person/agency for grant writing services. Full disclosure should be paramount in all dealings. (1, 2, 3, 4)

  • I’m a grants manager and I’m swamped to the point that I’m two quarters behind on the reporting requirements for two of our big federal grants. I’ve been offered a different position and am thinking about just leaving with the reports not done. Is this ethical?
    It is not ethical to leave your position without addressing the late reports. You should let your supervisor know the situation and see what strategies he/she suggests to ensure that the reports are completed. (1, 7, 8)

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Solicitation and Use of Funds

  • Is it ethical for a grant professional to work on applications for submission to the same funder from multiple clients?
    Yes, if the grant professional is transparent with all clients about the fact they are working on multiple proposals for the same funder it is ethical to submit for multiple clients. A grant professional should reassure all clients they will be attentive to their individual agency’s needs and write the proposals accordingly. The grant professional should take care to ensure no privileged information from either client is shared with the other. Also, the grant professional should stay mindful of the research they conduct for a particular application/proposal. If research is completed that potentially assists both clients at the same time, then those clients should share the cost of research evenly. Charging multiple clients for the same research is a breach of ethical standards.

    Keep in mind that there are many variables in the selection of an award. No two applying organizations have the same exact capacity or past outcomes, so the conflict is only real if a grant professional does not support both organizations to the best of their ability. (1, 4)

  • My employer is always asking me if we can spend funds on items that are not in our originally approved budget. What should I do?
    The professional standard is if you are not moving more than 10% of your budget, you will not need written approval from your funder, HOWEVER, the expenditure must be an allowable expense. This is a prime opportunity to educate others in your agency on the value of a grant professional, an expert in all things grants!  If the answer is not in the specific grant contract itself, then you can visit 2 CFR 200, the Uniform Guidance, which is a resource for all federal grants that all grant pros should be familiar with. In it, there are guidelines on expenditures from A to Z. If you still cannot find the answer in either of the places mentioned, this is a good time to reach out to your contact at your funders to pose the question to them. Be prepared to justify the expense as it relates to your implementation plan and outcomes. Most Grant Managers (federal, state and foundations) are more than happy to discuss this with you and will let you know if you need a formal amendment request. The most important thing is to ask before you spend. (1, 9, 10, 11)

  • Our agency just received another federal grant. In our last federal grant, we had issues with unallowable expenses and lack of outcome attainment. We received a finding from the auditor. How can this be avoided in the future?
    These are serious findings. When a new grant is received, it is important that the staff fully understands the purpose of the funding and the intent of the federal agency providing these funds. A walk-through meeting with staff and your accounting department to review the approved budget would help all to work together to avoid incurring expenditures that are not allowable. Ensuring that the staff understand the agreement, outcomes, and required reporting, is essential. Counsel your agency about the importance of compliance. If your agency chooses to ignore the advice, and continue in its path of non-compliance, you are obligated by law to self-disclose potential fraud or improper conduct impacting the award. (1, 2, 10, 11)

  • Budget reporting - how do you make sure to not double or omit?
    Budget reporting can lead to several ethical considerations. First, you need to make sure the budget lines being funded by the grant are not also covered by another source of funding. When you are submitting grant reports, it is easy to record that funds were used for a specific project without taking into account the specific charges funded within the project. This can lead to double reporting on the same item, which is supplanting. Omitting how the funds were actually used, or possibly using funds for a line item that isn’t supposed to be funded by the grant can be avoided with accurate record-keeping.

    Make sure you have a copy of the originally approved budget and compare it to what you actually spent. If you went over or were under on an expense, just make sure that you can explain it (as long as it is allowable and not more than 10% of the total budget). You can get yourself into an additional ethical predicament by incorrectly stating in your budget report how funds were expended.

    To assist you in your budget reporting, ensure that accurate records are kept from the start of the project, communicate with various program and finance staff on how funds are to be used, and review monthly financial reports to ensure nothing has gone awry. (1, 11)

  • I work for a large college and helped write and now manage a federal grant. My bosses want to direct the funds to help pay for stadium lights rather than paying for the upgrade of the lighting in the dormitories. Is this OK?
    No, not without express written permission from the agency that funded the proposal. Since the project was written for lighting in the dormitories, if the college now wants to use funds for stadium lights, they would need to contact the agency that funded the project and amend their original proposal. (1, 10, 12)

  • Our CEO really wants to digitize our organization’s library resources. We are working on a federal proposal for a program to provide more secure facilities for our after-school program for disadvantaged youth. After we have designed the security program to meet our needs there is enough budget cap that we could fit in the digitization of our library resources. Should I tag this extra expense on?
    Unless the proposal includes the digitization of the library resources, you should not try to sneak it in and hope that it will be funded. Reviewers will be looking for expenditures that relate directly to the strategies identified to address the needs. When a budget line item shows up that is unrelated to strategies and more importantly unrelated to the RFP, this is a misuse of funds and will likely decrease your proposal score. (1, 10)

  • I am a contractor who does both grant writing and program evaluation. Is it ethical for me to include an extra $5,000 in the program evaluation portion of an application to provide compensation for the successful writing of the application?
    No, this is not "ethical” and is a misuse of funds. (1, 10, 11, 20)

  • My agency routinely asks me to “write-in” services provided by the agency which have no direct relevance to the RFP. If the grant is funded, they indicate this money would then be transferred to my operating budget as my “grant writing fee.” Would this get me in trouble ethically with GPA if I allow this practice to continue?
    Yes, as the grant professional, you are obligated to inform your immediate supervisor that the practice is unethical and violates the code of ethics of your professional organization. If the funder discovers that your agency isn’t providing the services requested in the original proposal and that an amendment hasn’t been written to reflect the changes, they are opening themselves up for consequences ranging from having to return any funds already expended to losing the grant altogether. The inclusion of irrelevant activities in an application could very easily cause the reviewers to lower the score significantly, thus losing the award. (1, 10, 11, 20)

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Presentation of Information

  • What is self-plagiarism?
    Self-plagiarism is the practice of presenting one’s own previously published work as though it were new. Work created for an organization (an employer or client) belongs to that organization and should not be used in a proposal for another employer or client without permission or citation. The work can, however, be used again for the original organization without citation. (1, 14)

  • May I use the work of others in my proposal?
    You may use the work of others PROVIDED you cite any information or data that is not your original work. Citing the work of others is an expected practice and courtesy. Plagiarism is illegal and is considered a serious breach of ethics by GPA, Section 14 of Code of Ethics. It should be noted that work created for an organization belongs to that organization and can be used without citation. (1, 14)

  • I’m pretty sure that the information that was provided by the XYZ school district on the academic achievement and poverty levels are not correct. I think they took the data from four years ago and are reporting it without identifying the year. Is it OK if I use that information they provide since they will be responsible for the accuracy of the information?
    As the grant professional, if you think that the information is incorrect, you should ask the district to confirm the data and insert the proper reference. Data used from previous years must be cited with the correct year. (1, 5)

  • I was selected to give a presentation at a national conference and took several pieces out of a grant application that I was writing for an organization. The agency did not receive the grant, but I have now found out that another agency used the exact tables and charts from the grant and also received funds. Did I act unethically by presenting the information from the unfunded grant to others? 
    If you did not have permission from your client, you violated confidentiality by presenting their information without their explicit permission. The exception would be statistical community/public information. Once the grant proposal/application was submitted, certain documents become available for the public to see, but it still would be better to ask permission from your client to share this information before using it.(1, 13)

  • I work for a small private preschool, and one of our volunteers recently indicated that there would be an opening in their company that would be perfect for my spouse. I would really like to encourage my spouse to apply, but I don’t want to cross any ethical boundaries. What do I do?
    The Code does not prohibit your spouse from working for one of your volunteers. If your volunteer told you about the upcoming announcement, then you should watch for the advertisement and point it out to your spouse. What you should not do is lobby with the volunteer to get your spouse hired! (1, 4)

  • Through my work as a grant professional, I’ve discovered that my employer is interested in purchasing a parcel of land that my wife’s company owns. Purely by accident (I wasn’t really paying attention to which parcel it was), I have become privy to confidential information such as the amount they plan to offer and the maximum amount available. I know that I can’t give this information to anyone outside the agency, but do I need to tell my boss about this? 
    Yes, you should talk to your boss and explain the situation, making clear the point at which you became aware of the conflict and that you have no intention of revealing any proprietary information. We encourage you to refer to your employer’s conflict of interest policy. (1, 3, 4)

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Compensation

  • I am a consultant, and in addition to my regular salary, I receive profit-sharing bonuses from my company. Is this a violation of the Code?
    No. If profit sharing is a regular practice in your company and is not based on the amount of funds raised or number of awarded proposals, it is not a violation of the code. (1, 18)

  • Is it okay to be paid a commission/percentage of the grant total?
    No, as a member of GPA, we are not to take a commission/percentage of the grant total but are to work for a salary or fee. The agency/organization is paying the grant professional to write the proposal for a project or need that the organization has identified. The funder is awarding dollars for the project/need, not the skills of the grant professional. (1, 19)

  • Is it OK to include my compensation directly into a grant/ renewal grant if the funder thinks it’s OK?
    Yes, if the funder agrees that compensation is an allowable expense, it could be written into the grant/renewal grant. It would be unethical if you included an amount for something else with the intention of using if for your compensation. (1, 20)

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