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 

Professional Obligations

1) 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?

Response: Taking the time to go through the GPA Ethical Decision-Making Best Practices for Grant Professionals will help you in determining what response is best. Depending on the particular situation, some suggested re-framing approaches might be:

• 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 the Code of Ethics that I follow with you. 
• You can see under #x in the GPA Code of Ethics that what you are proposing may be considered unethical within the 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/us/the organization from 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 how you are tracking the measurable goals we promised so that I can prepare for the report? If you are having trouble, I may be able to help.

2) 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?

Response: While this offer may sound like a great deal, it presents a few concerns. Grants are used to purchase goods and services related to specific needs, and you need the software. However, purchases with grant funds must typically follow specific purchasing/procurement guidelines. This is particularly true with state and federal grants, where applicants must have in place specific policies on how to make small and large purchases. The expectation is that applicants will use competitive practices – receiving comparative price quotes and bidding, for example – before choosing a specific product from a specific vendor. Depending on the type of funding and the software’s cost, entering into such a pre-award arrangement may violate key rules and guidelines as well as your organization’s internal policies.

In terms of the GPA Code of Ethics, such action could violate at least two overarching principles and guidelines GPA Members are to follow:

• Adhere to all applicable laws and regulations in all aspects of the grants profession

• Ensure that funds are solicited according to funder’s program guidelines

In addition, the action could appear to violate or actually violate two standards within the code’s Professional Obligations requirements including a potential or actual conflict of interest and entering into an association that you know is misleading. As noted in the Code of Ethics:

Obligation 4. Members shall disclose all relationships that might constitute, or appear to constitute, conflicts of interest. 

Obligation 5. Members shall not be associated directly or indirectly with any service, product, individuals, or organizations in a way that they know is misleading.

Again, this relationship likely involves the procurement standards of your agency as well as, 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). Entering into this pre-arranged purchasing agreement may be deemed a matter of noncompliance and puts the agency at risk of a finding in a single audit.

As a final note, the offer of your vendor is not an uncommon process. For decades, organizations have used grants as a sales tool. Many such arrangements are based on good faith relationships between the grantee and the vendor; however, scams/fraud are also common. If something seems too good to be true, it probably is.

3) 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?

Response: While this may not be a violation of regulation or law, conversations about conflict of interests, perceived or real, are not always easy; however, grant professionals 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.  Therefore, evaluate your options through several lenses and think ahead for any consequences of your chosen actions. Ideally, this is something you should discuss with the funder, and in hindsight it would have been appropriate to discuss this probable conflict of interest, whether you did this work pro bono or not. Be sure to review your decision and take preemptive actions to avoid this conflict in the future.  (GPA Code of Ethics 3, 4, 6)

4) Writing a grant for a sponsorship – Sponsorships can be very different from grants for projects. What do I need to know?

5) 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?

Response: 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 contacting your legal counsel for advice about setting up a proxy. Even though this scenario is pretty straight-forward, it is still your responsibility to explain why forging a signature is illegal and unethical.  Be sure to communicate in a way that reassures the person asking this of you that you are protecting them as much as yourself, and why you need an alternative solution to forging.  These conversations must happen before the day you need to submit the letter in a grant portal, so choose authorized signers wisely. In time and with experience, this will become a standard operating procedure for you and your organization, with an outcome that reduces your professional risk as well as your organization's risk. (GPA Code of Ethics 1, 2)

6) 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?

Response: Using the best practice decision model, it is clear that this is a violation of the Code of Ethics because grant professionals must act according to the highest ethical standards of their institution, profession, and conscience. Similarly, you and your organization may not misrepresent anyone’s credentials or provide false information in a grant proposal or application. In evaluating your options, you may find that if you first speak with your colleague and urge her to be honest about her credentials, she will understand the urgency of being honest and correct the information. If your colleague is not willing to make corrections, then your next decision may risk your relationship with your colleague but protects the organizations or clients that hire her. Think through the most respectful way to proceed by being transparent about your choice and allowing time for her to rectify the situation. If she is a member of GPA, you could report the unethical behavior to the GPA CEO and Ethics Committee. The Ethics Committee would likely forward the complaint to the Grant Professionals Certification Institute if the consultant is certified. In the end, you will have to assess your approach and the consequences, if there were any. Standing up to unethical behavior is uncomfortable at times but is expected as a grant professional. (GPA Code of Ethics 1, 2, 5)

7) 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?

Response: First, evaluate if this is an ethical problem. Given that the GPA Code of Ethics says that GPA members should be truthful about their individual capabilities, we advise you to be transparent about your limited expertise in the area requested. If the evaluation or grant writing request is beyond the scope of your education and/or expertise, then it is appropriate to tell the agency. In evaluating the task, you may decide that you have similar expertise that aligns with this particular work and you are confident you can still meet your clients’ needs successfully. In this case, you should still be honest about your past experience so the client can make the best decision for them. When debriefing, you generally will find that your honesty was a great career move. (GPA Code of Ethics 1, 7)

8) 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?

Response: 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, communicate to them that your obligation is to the grant-maker and your professional ethics.  Let the funder know that you have reason to believe that the proposal contained fraudulent information.  In the end, the grant-maker will decide what action to take from there, not you. From an ethical position, although difficult, the issue of whether you lose them as a client should not be a determining factor on how you handle the situation.  When debriefing, we believe your peers will support your decision to communicate honestly about your ethical decision. (GPA Code of Ethics 1, 2, 5)

9) 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?

Response: Given that you have identified the reason this is unethical, and you have evaluated the options available, and chose to tell the client your concerns, we assume you also thought through the consequences of these actions. Assuming that the changes made to the acronym were made to appeal to either the funder or the focus area of a funding opportunity, the best course of action from this point on is to counsel the client on making a final decision about their acronym, and then have them make contact with the grantors who funded them under the “wrong” acronym. Once the funder makes a decision on how to handle this oversight, you can debrief with your client about how it felt to be transparent and ultimately reduce further risk to the agency. (GPA Code of Ethics 1, 5)

10) What happens if a consultant is contracted to write a proposal but doesn’t follow through with anything and just keeps the money?

Response: 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.  Reporting a GPA Member for a suspected ethical violation is taken seriously and the process for doing so can be found here: Ethics Inquiries and Complaint Procedures - Grant Professionals Association 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 then forward the complaint to the Grant Professionals Certification Institute if the consultant is certified. Even though this seems like a cut-and-dry ethical violation, please take the time to utilize the best practice decision model to ensure that you have evaluated, thought ahead, effectively communicated and measured the outcome of your decision. (GPA Code of Ethics 1, 5, 6, and 11)

11) Is it possible for me to pursue a grant opportunity on behalf of my client without the expressed consent of my client?

Response: As you think through this situation, identify if it is a violation of law or ethics, or if it poses a risk for the client. Without proper permissions, it might be all three.  It is only ethical for a grant professional to submit a grant with the client’s written permission. To step beyond a contractual boundary would be an ethical and legal violation for a grant professional. One repercussion may be that the grant is awarded and the client refuses to accept it, which will damage their relationship with the funder. Another consequence might be that the client files legal charges against you for falsely submitting on their behalf.  Always evaluating an action like this ahead of time is prudent, and as you implement your decision, be sure to prioritize the rights of the client, which will result in long-term benefits in your career. (GPA Code of Ethics 1, 3, 6)

12) Is it ethical for a grant professional to work on applications for submission to the same funder from multiple clients?

Response: As long as the grant professional is transparent with all clients about the fact they are working on multiple proposals for the same funder, this is ethical. While this may not be a violation of regulation or law, or even the GPA Code of Ethics; however, there are steps in your decision-making that do involve the Code of Ethics. Evaluating how you respond, who you are transparent with, and how you bill all need to be considered. 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) Be sure to review your decision with your client in case there were, indeed, any unforeseen negative implications of your decision. (GPA Code of Ethics 1, 3, 4)

13) 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?

Response: In walking through the process of the best practice decision model, you may find that there are local guidelines that prohibit this behavior, and how to avoid any violations of the Code of Ethics. To be transparent, it is best for the grant professional to disclose their relationship to the board and the applicant, and the degree to which they were involved in the application process. Avoiding any conflict of interest, real or perceived, is valuable in this scenario. Deciding to recuse yourself from any decision on funding would ensure that the Code of Ethics is followed and would relieve concerns for all parties involved. The consequences of not being transparent and recusing yourself could be negative for the foundation and organization. In your review of how you handle this, be sure to reflect on the impact of your decision on the foundation, organization, and yourself. (GPA Code of Ethics 1, 3, 6)

14)  Is it permissible for me to “moonlight” and write grants for other entities?

Response: In identifying if this is a violation of law, guidelines or ethics, it may be that it depends on how you plan to “moonlight” in relation to your current employment. In evaluating your options, it would produce the most good for your employer, yourself, and your clients if you get permission from your current employer and do not use or share proprietary information with other entities. This will avoid any negative consequences and keep you in line with the Code of Ethics. Discussing this openly and being transparent reflects a commitment from you to consider all possible conflicts of interest. Revisiting your decision with your employer will alleviate any future mistrust.  (GPA Code of Ethics 1, 3, 4)

15) Recently, I attended a 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?

Response: Identifying if this is unethical would depend on if the presenter intentionally and deliberately provided false information.  Once you share the correct information with the presenter and find out if they will correct it, then you have to evaluate how you want to proceed.  Educating someone, assuming lack of knowledge and giving the benefit of the doubt to a colleague builds relationships and allows for growth.  Think ahead as to how you frame your concerns and effectively communicate your desire to elevate professional development in the field. If the misinformation is intentional, reporting the GPA Member for a suspected ethical violation would be the courageous and ethical choice to make. The process for doing this can be found here: Ethics Inquiries and Complaint Procedures - Grant Professionals Association If an Ethics Violation is filed with GPA, the Ethics Committee would consider all options in determining a fair consequence and could possibly forward the complaint to the Grant Professionals Certification Institute if the presenter is certified. (GPA Code of Ethics 1, 5, 8)

16) A grant professional has been invited to sit on the board of directors of a nonprofit agency for which they provide grant writing services. Is there a conflict of interest and should they accept or decline the invitation?

Response: 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 to compensate a board member for services is particular to an organization and, possibly, its by-laws. It is best to undertake this type of arrangement with a Board Approved Policy in place and after a full review of the board's conflict of interest statement regarding business dealings with board members.  When you evaluate the situation, review issues concerning this type of potential conflict of interest, perceived or real, on a case-by-case basis.  Be sure to communicate your decision process with your board peers and think ahead about possible consequences for the organization. In line with our Code of Ethics, a grant professional who serves as a board member should 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. For transparency and to assess any negative impact, be sure to assess your role annually for the best outcome for the organization. (GPA Code of Ethics 1, 2, 3, 4)

17)  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 report undone. Is this ethical?

Response: While this may not violate any laws or guidelines, it certainly would be viewed as unethical to leave without addressing the late reports. Evaluate your options and the consequences of those actions for your current employer as well as your professional well-being. An honest and open conversation with your supervisor to balance their contractual obligations, while honoring your decision to move on, might produce strategies that would reduce risk for both of you. Think ahead and discuss your decision with a peer or colleague. You may find having the courage to leave a job is stressful enough without risking future funding for a prior employer, which could harm your future position opportunities.  (GPA Code of Ethics 1, 7, 8)

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Solicitation and Use of Funds

18) 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?

Response: The most important thing is to ask before you spend. In identifying if this would be allowable, and regardless of whether this is state or federal funding, funders provide approved budgets for a reason. Evaluate the best option with the understanding that the professional standard is if you are moving 10% or less of your budget, you will not need written approval from your funder; HOWEVER, the expenditure must be an allowable expense. Thinking ahead by reviewing the specific grant contract itself, then visiting the 2 CFR 200, the Uniform Guidance, if these are federal funds, to find out if the expense is allowable, is the right course of action.  If you still cannot find the answer, this is a good time to reach out to your funder and 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.  When you communicate what you learn, this is a prime opportunity to educate your employer on the risks of spending outside an approved budget and having permission ahead of time. This will reinforce your value on the team. (GPA Code of Ethics 1, 9, 10, 11)

19) 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?

Response: If findings were found, then you have already identified the unethical and potentially illegal behavior. It could be intentional, but most of the time it is a lack of education in fully understanding grant compliance that results in a finding. In evaluating your options moving forward, we recommend that when a new grant is received, it would be 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. Putting additional safeguards in place will be necessary to avoid future findings. It is just as important to debrief after an award is closed as it is to have that informational meeting at the start of your funding. This will help you see if policies and procedures are being followed and what steps to take next to avoid this risk.  (GPA Code of Ethics 1, 2, 10, 11)

20) How do you make sure to not double dip or omit expenditures on grant financial reports?

Response: Financial reports done improperly can result in several ethical and legal violations. It is important to evaluate financial accounting practices prior to starting a grant project so think ahead and establish policies and procedures that reduce the risk as much as possible. First, you need to make sure the budget lines being funded by the grant are not also covered by another source of funding. If neglected, this can lead to double-dipping 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. Be sure to communicate internally the policies and procedures in place and the implications of inappropriately spending funds.  For reporting, start with 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. Be honest and accurate. In summary, 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. (GPA Code of Ethics 1, 11)

21) 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?

Response: In identifying this ethical question, the actions proposed could be a violation of law, guidelines, and the GPA Code of Ethics. Evaluate your options, and keep in mind what will reduce the college's risk for current and future funding, and your own professional obligations. Knowing that this would not be allowable without express written permission from the agency that funded the proposal, communicate this in writing, and discuss the possible repercussions from non-compliance such as findings at the time of an audit. 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. (GPA Code of Ethics 1, 2, 10, 11) 2, 10, 11)

22)  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?

Response: If you identify that what your CEO is asking of you is unwise and/or potentially unethical, and in this case an unallowable expense for the grant you are applying for, you must evaluate what action to take to avoid an unfunded proposal. You should explain that reviewers will be looking for expenditures that relate directly to the strategies identified to address the needs. Educate him/her that 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. Having the courage to point this out at the start of this project will avoid unrealistic expectations of the proposal being funded and educate him/her on your expertise and values. (GPA Code of Ethics 1, 10)

23) 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?

Response: This is a clear violation of the GPA Code of Ethics, and a misuse of grant funds. Evaluate your decision carefully as pre-award expenses are rarely allowable and would put their application at risk, not to mention what the negative consequence would be to your own professional career. Knowingly lying and misusing funds could be grounds for GPA Membership termination if you were ever reported, as well as jeopardizing your certification if you are a GPC. In addition, writing a grant and including yourself for evaluation services is allowable only if the agency’s procurement policy has been followed, and the funding agency has approved of this expenditure. Think ahead and be sure to consult the funder, or a peer or colleague with specific expertise in procurement compliance, if you are unsure. (GPA Code of Ethics 1, 10, 11, 20)

24) 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?

Response: Using grant funds for an unallowable purpose not approved for in the originally approved budget is a violation of the GPA Code of Ethics and of the Uniform Guidance. Given that this action would be a clear ethical issue, you would need to decide how to handle it internally so that your agency can reduce its risks of future funding. Perhaps educating the agency on best practices, the law, and the GPA Code of Ethics would be one way to broach the subject.  When you evaluate who will be at risk, it becomes obvious that you need to inform your immediate supervisor of this unethical behavior. Suppose 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. In that case, they are opening themselves up to the 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. (GPA Code of Ethics 1, 10, 11, 20)

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Presentation of Information

25) 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 the information they provide since they will be responsible for the accuracy of the information?

Response: While this may be legal, it is the job of the grant professional to verify where the data came from and to cite it accordingly.  If you think that the information is incorrect, you have choices about what you do. If you ignore your concerns, and it turns out they are justified, it leaves the district vulnerable for a higher risk of being unfunded, and it is dishonest, which reflects on you negatively just as much as it does on them. From an ethical standpoint, it is the grant professional’s responsibility to ensure the accuracy and transparency of the data presented in the application to the best of their ability.  If you ask the district to confirm the data and then learn that your concerns were justified, it is important to update the citation to include the appropriate time frame. If you ask for more updated data, you may get pushback and it may be uncomfortable, however, it is your job to advise them on the professional standard in applying for grants. Educating others about our professional ethics is also part of our job. Communicate clearly and in writing your concerns and the risks of providing old data. Using good judgment and communicating respectfully, will hopefully result in them providing the most updated data sets to include in the application. If not, then think ahead of the possible repercussions for you, as well as the school district. This may require consultation with a peer, colleague, or the Superintendent.  Whatever your choice, be sure to prioritize professional ethics and assess the full impact of your decision. (GPA Code of Ethics 1, 5)

26) 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?

Response: The GPA Code of Ethics does not prohibit your spouse from working for one of your volunteers and If your volunteer told you about the upcoming announcement, then you should watch for the advertisement and point it out to your spouse. When thinking ahead about avoiding risk or remaining ethical, you should avoid lobbying with the volunteer to get your spouse hired, but let the process run its course. Use good judgment by being respectful of all involved. (GPA Code of Ethics 1, 4

27) 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?

Response: While this may not be a legal or guideline issue, this does speak to the GPA Code of Ethics.  It may also apply to your employer’s conflict of interest policy, so consult that as well.  Ignoring what you now know is not an option that best treats everyone fairly. You should talk to your boss and explain the situation to be totally transparent.  Make it clear the point at which you became aware of the conflict and that you have no intention of revealing any proprietary information.  This protects everyone involved, including your spouse. Be sure to also discuss this with your spouse so their company understands that you will be valuing their proprietary information. Debrief with your spouse and boss to be sure your decision was respectful of everyone involved. (GPA Code of Ethics 1,3,4)

28) Is it acceptable and ethical to use samples of proposals I have written in the past year? Do I need to notify my employer that I am using a particular document, or should I ask their permission to share the proposal with others? Of course, I would redact any sensitive information, such as salaries. Do I have a right to my own past work from my past employer?

I am interviewing with a new potential client. They requested a writing sample. I asked one of my current clients if I could share part of a proposal I had written for them and they agreed. Do I change the name of the nonprofit and the collaborating agency?

Response: These questions relate to Intellectual Property and who maintains the rights to the work as it has been created. As an employed grant professional, the work you create while employed by the organization is considered the property of the organization. Our job as Grant Professionals is to provide a service be it research, writing, program creation, board development, evaluation, budget creation, or any other aspects of a grant proposal. The grant is not ours to share but belongs to our employer or client. Therefore, using the past work of another client for a current client or employer would be a violation of the GPA Code of Ethics without permission from the organization for whom the original grant was produced. 

If past work is to be used to provide a writing sample for a prospective client or employer, and approval has been received by the organization owning the document, appropriate redaction should be done to satisfy the confidentiality of any sensitive information of the applicant. Be sure to evaluate your options and prioritize the confidentiality of your clients’ information. One option that would do the least harm would be to produce sample documents (letter of intent, budget, grant proposal) using a fictitious organization rather than using actual grant applications.

Instances where a consultant can use past work without violating intellectual property rights include where a consultant's contract terms state that the consultant retains the copyright of the original work and grants the client a royalty-free license to the work.  Conversely, if the client retains the copyright but gives the consultant a royalty-free license to the work, typically with a non-disclosure agreement (NDA) for organization-specific or other confidential information, the consultant would be permitted to use the information covered by the NDA.

Federal and other public grants funded by public funds/taxes become part of the public domain when they are funded. Therefore, a funded proposal may be available through normal public disclosure and no longer is considered the intellectual property of the funded organization. Grant proposals that are not funded would not necessarily be included in the public domain and would require the permission of the organization for sharing with other parties.

29) May I use the work of others in my proposal?

Response: First, identify if it would be ethical to use the work of others. According to the GPA Code of Ethics, you may use the work of others provided you cite any information or data that is not your original work. Plagiarism, taking passages from another's work and using them, either word for word or in substance, as one's own, is illegal and is considered a serious breach of the GPA Code of Ethics. Evaluate what best respects the author of the work and think ahead about the consequences. Work product created for an organization belongs to that organization and can be used without citation in other work produced for that same organization. (1, 14)

30) 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 received funds. Did I act unethically by presenting the information from the unfunded grant to others? 

Response: Your question describes a situation related to intellectual property (sharing the information without permission) and plagiarism (someone copying it without permission or citation). It sounds like you have identified a possible violation of the GPA Code of Ethics and if you did not have permission from your client, you violated confidentiality by presenting their information without their explicit consent. By thinking ahead about who owns the specific grant information, it becomes clear that you must have permission to share it. The exception would be statistical/community data that is public information. Even so, evaluate the consequences of sharing this information. Once the grant proposal/application was submitted, if certain documents become available as public information, they could be used with proper citation.  If you have mistakenly shared confidential grant information or content, you should discuss it with your client and determine what steps, if any, should be taken.  (GPA Code of Ethics 1, 13)

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Compensation

31) 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?

Response: This does not sound unethical or illegal given that you receive a regular salary and the salary is not based on a percentage of awarded grants.  Would it put you, your organization, or your clients at risk?  That seems unlikely as well. If profit-sharing bonuses are a regular practice in your company, then this scenario does not violate the Code of Ethics. If you have any sense that the bonus is based on a percentage of awards raised, then effectively communicate the unethical practice as a violation of the Code of Ethics. (GPA Code of Ethics 1,18)

32) Is it okay to be paid a commission/percentage of the grant total?

Response: While this may not violate laws or guidelines, it definitely violates the GPA Code of Ethics.  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. This type of proposed payment method hurts all grant professionals as all funders are awarding dollars for the project/need, not the skills of the grant professional. Evaluate your options and communicate the reasons why this is not supported and not in line with your values. It can be a teachable moment that could impact your GPA membership and GPC credential if you are one. (GPA Code of Ethics 1, 19)

33) Is it OK to include my compensation directly into a grant/ renewal grant if the funder thinks it’s OK?

Response: If the funder agrees that compensation is an allowable expense, it could be written into the grant/renewal grant. Otherwise, you may be violating 2 CFR 200 or the funder guidelines. Be sure to reduce risk for you and your client/employer by ensuring this is not extra funding for pre-award writing, which in most cases is unallowable and unethical. One must also evaluate their procurement policy and the guidelines of such. Always review these carefully as the consequences could put the client/employer in jeopardy of receiving future funding.  It is best practice to keep the communication from the funder approving this compensation in writing, in case at the time of the audit, this is an issue that raises red flags. Effective, documented communications should be clear about what the compensation is for. You should also review your decision with a peer, colleague, or the finance department, etc. (GPA Code of Ethics 1,20)

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