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Foundation Grant Compliance Assessment
33-Point Comprehensive Checklist for Grantmaking Organizations
Assessment Progress
IRS & Tax
Due Diligence
International
Governance
Financial
Operations
Risk
Overall Risk Score
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Compliance Score
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Vulnerabilities
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📋 IRS & Tax Compliance
High Priority
1. Does your foundation maintain expenditure responsibility procedures for all non-501(c)(3) grants?
IRS Section 4945 requires private foundations to exercise expenditure responsibility for grants to non-public charities.
Recommendation: Implement procedures including pre-grant inquiries, written agreements, segregated funds requirements, and detailed reporting from grantees.
2. Are you meeting the 5% annual distribution requirement for private foundations?
Private foundations must distribute at least 5% of assets annually for charitable purposes or face excise taxes.
Recommendation: Track qualifying distributions quarterly and ensure timely grant payments to meet the annual requirement.
3. Do you avoid prohibited transactions such as self-dealing?
Self-dealing between foundations and disqualified persons can result in severe penalties.
Recommendation: Establish clear policies identifying disqualified persons and requiring board approval for any related transactions.
4. Is your Form 990-PF filed accurately and on time?
Annual 990-PF filing is required with detailed grant listings and financial information.
Recommendation: Maintain detailed records throughout the year and engage qualified tax professionals for timely, accurate filing.
5. Do you properly classify grants vs. charitable activities in tax reporting?
Operating foundations have different requirements than non-operating foundations.
Recommendation: Clearly distinguish between grants to other organizations and direct charitable activities in all tax filings.
🔍 Grant Due Diligence & Monitoring
High Priority
6. Do you verify 501(c)(3) status for all domestic grantees before making grants?
Grants to non-501(c)(3) organizations require expenditure responsibility procedures.
Recommendation: Check IRS Tax Exempt Organization Search before every grant and maintain documentation of verification.
7. Do you have written grant agreements specifying charitable purposes and restrictions?
Written agreements protect foundations and ensure proper use of charitable funds.
Recommendation: Use standardized grant agreements that specify purposes, reporting requirements, and rights to recover misused funds.
8. Do you monitor grantee performance and use of funds?
Foundations must ensure grants are used for intended charitable purposes.
Recommendation: Require progress reports, financial reports, and conduct site visits for larger grants.
9. Do you maintain records of declined grant applications and reasons?
Documentation helps demonstrate fair processes and defend against discrimination claims.
Recommendation: Document decision criteria and maintain records of all grant decisions, including denials.
10. Do you have procedures for recovering misused grant funds?
Foundations have a fiduciary duty to recover charitable funds used improperly.
Recommendation: Include clawback provisions in grant agreements and establish procedures for identifying and recovering misused funds.
🌍 International Grantmaking Compliance
High Priority
11. For international grants, do you conduct equivalency determinations or exercise expenditure responsibility?
International grants require either equivalency determination or expenditure responsibility to comply with IRS rules.
Recommendation: Establish procedures for either path, with qualified legal counsel for equivalency determinations.
12. Do you screen all international grantees against OFAC sanctions lists?
Treasury prohibits transactions with specially designated nationals and blocked persons.
Recommendation: Screen all foreign grantees against OFAC lists before making grants and maintain screening documentation.
13. Do you have anti-terrorism compliance procedures for international grants?
Foundations must ensure charitable funds don't support terrorism or other prohibited activities.
Recommendation: Implement Treasury's voluntary guidelines including vetting procedures and certifications from grantees.
14. Do you understand FARA and FCPA implications for international activities?
Foreign Agent Registration Act and Foreign Corrupt Practices Act may apply to some activities.
Recommendation: Consult legal counsel about FARA registration requirements and FCPA anti-bribery provisions.
🏛️ Governance & Operations
Medium Priority
15. Does your board regularly review and approve grantmaking policies?
Board oversight of grantmaking ensures fiduciary duties are met.
Recommendation: Schedule annual board review of grantmaking policies and procedures with documented approvals.
16. Do you have conflict of interest policies for board and staff?
Conflicts of interest in grantmaking can lead to private benefit violations.
Recommendation: Require annual disclosure statements and recusal from decisions involving conflicts.
17. Are grant approval authorities clearly defined and followed?
Clear delegation of authority prevents unauthorized commitments.
Recommendation: Document approval levels (e.g., staff up to $X, committee for $Y, full board above $Z).
18. Do you maintain adequate insurance including D&O coverage?
Directors & Officers insurance protects board members from personal liability.
Recommendation: Review insurance coverage annually including general liability and D&O policies.
💰 Financial Controls & Record Keeping
High Priority
19. Do you maintain segregation of duties for grant payments?
Segregation of duties prevents fraud and errors in grant disbursements.
Recommendation: Separate grant approval, payment processing, and reconciliation functions among different staff.
20. Are all grant files maintained for the required retention period?
Grant records must be retained for at least 7 years for IRS compliance.
Recommendation: Implement a document retention policy covering applications, agreements, reports, and correspondence.
21. Do you track restricted vs. unrestricted grants properly?
Proper fund accounting ensures donor restrictions are honored.
Recommendation: Use fund accounting to track and report restricted grants separately from general support.
22. Are multi-year grant commitments properly recorded?
GAAP requires proper recording of unconditional multi-year commitments.
Recommendation: Record full commitment as liability with clear conditions documented for conditional grants.
🚀 Modern Grant Management Operations
High PriorityNote: These operational best practices can be automated and streamlined using modern grant management software like Reviewr.
23. Do you provide a low-barrier, user-friendly submission experience for grant applicants?
Complex application processes reduce diversity and quality of applicant pools.
No: Paper applications or complex multi-step processes
Partial: Basic online forms without save functionality
Yes: Intuitive portal with progress saving and mobile access
No: Paper applications or complex multi-step processes
Partial: Basic online forms without save functionality
Yes: Intuitive portal with progress saving and mobile access
Recommendation: Implement streamlined online applications with save-and-return functionality, clear instructions, and mobile compatibility.
24. Do you have automated eligibility screening and opportunity matching?
Manual eligibility checking wastes time for both applicants and staff.
No: Staff manually review each application for eligibility
Partial: Basic filters but applicants can still apply for wrong programs
Yes: Automated pre-screening that guides applicants to right opportunities
No: Staff manually review each application for eligibility
Partial: Basic filters but applicants can still apply for wrong programs
Yes: Automated pre-screening that guides applicants to right opportunities
Recommendation: Use automated pre-screening to match applicants with appropriate opportunities and prevent ineligible applications.
25. Is sensitive applicant data collected and stored securely with proper encryption?
Data breaches can expose sensitive financial and personal information.
No: Storing files on shared drives or personal computers
Partial: Basic cloud storage without encryption or access controls
Yes: Enterprise security with encryption, SOC 2 compliance, and audit logs
No: Storing files on shared drives or personal computers
Partial: Basic cloud storage without encryption or access controls
Yes: Enterprise security with encryption, SOC 2 compliance, and audit logs
Recommendation: Use enterprise-grade security with encryption, access controls, and compliance with data protection regulations.
26. Do you use dedicated grant management software instead of spreadsheets/email?
Manual processes increase errors, inefficiency, and compliance risks.
No: Managing grants via email and spreadsheets
Partial: Using generic CRM or project management tools
Yes: Purpose-built grant management platform like Reviewr
No: Managing grants via email and spreadsheets
Partial: Using generic CRM or project management tools
Yes: Purpose-built grant management platform like Reviewr
Recommendation: Adopt purpose-built grant management software to automate workflows, ensure compliance, and improve efficiency.
27. Do you redact identifying information to reduce bias during review?
Unconscious bias can affect grant decisions and reduce equity.
No: Reviewers see all applicant information including names
Partial: Informal attempts to hide some information
Yes: Systematic redaction of identifying details during review
No: Reviewers see all applicant information including names
Partial: Informal attempts to hide some information
Yes: Systematic redaction of identifying details during review
Recommendation: Implement blind review processes that redact organization names and identifying information during evaluation.
28. Do you have a systematic process to pair applicants with appropriate review teams?
Manual reviewer assignment can create bottlenecks and conflicts of interest.
No: Ad-hoc assignment via email or meetings
Partial: Spreadsheet tracking but manual assignment
Yes: Automated matching based on expertise and availability
No: Ad-hoc assignment via email or meetings
Partial: Spreadsheet tracking but manual assignment
Yes: Automated matching based on expertise and availability
Recommendation: Use automated reviewer matching based on expertise, availability, and conflict of interest screening.
29. Do you use quantitative scorecards to standardize evaluation criteria?
Subjective evaluations can lead to inconsistent and unfair decisions.
No: Free-form comments or informal ratings
Partial: Basic scoring but no standardized criteria
Yes: Structured scorecards with weighted criteria for all reviewers
No: Free-form comments or informal ratings
Partial: Basic scoring but no standardized criteria
Yes: Structured scorecards with weighted criteria for all reviewers
Recommendation: Implement structured scorecards with weighted criteria to ensure consistent, objective evaluations across all reviewers.
30. Do you have ethical guidelines for using AI in grant processes?
AI can introduce bias or be used inappropriately without proper guidelines.
No: No consideration of AI ethics or uncontrolled AI use
Partial: Informal guidelines but no enforcement
Yes: Written AI ethics policy with clear use cases and limitations
No: No consideration of AI ethics or uncontrolled AI use
Partial: Informal guidelines but no enforcement
Yes: Written AI ethics policy with clear use cases and limitations
Recommendation: Establish clear policies for ethical AI use that enhance rather than replace human judgment in grant decisions.
31. Can you collect ongoing impact reports from grantees post-award?
Manual impact reporting collection is inefficient and often incomplete.
No: No systematic impact tracking
Partial: Collecting reports via email attachments
Yes: Automated reporting portal with reminders and standardized forms
No: No systematic impact tracking
Partial: Collecting reports via email attachments
Yes: Automated reporting portal with reminders and standardized forms
Recommendation: Implement automated impact reporting workflows with reminders and standardized data collection forms.
32. Do you have dashboards to measure and visualize grant program ROI?
Without impact measurement, foundations cannot demonstrate effectiveness or improve programs.
No: No systematic tracking of grant outcomes
Partial: Periodic reports but no visualization or analysis
Yes: Real-time dashboards showing metrics, trends, and ROI
No: No systematic tracking of grant outcomes
Partial: Periodic reports but no visualization or analysis
Yes: Real-time dashboards showing metrics, trends, and ROI
Recommendation: Deploy real-time dashboards that track key metrics, outcomes, and ROI to demonstrate program effectiveness to stakeholders.
⚠️ Risk Management & Special Situations
Medium Priority
33. Do you have procedures for grants to individuals (scholarships, hardship, etc.)?
Grants to individuals require IRS advance approval and specific procedures.
Recommendation: Obtain IRS approval before making individual grants and maintain objective selection criteria.
34. Are you prepared for potential grant-related audits or investigations?
State attorneys general and IRS may audit foundation grantmaking practices.
Recommendation: Maintain organized files and designate staff to coordinate audit responses.
35. Do you have a process for handling complaints about grants or grantees?
Proper complaint handling protects foundation reputation and ensures accountability.
Recommendation: Establish a formal complaint process with investigation procedures and board reporting.
Assessment Complete!
Your Grant Compliance Assessment Results
Overall Risk Score
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Compliance Score
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Vulnerabilities
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Identified
Category Breakdown
📊 Overall Assessment
⚠️ Critical Vulnerabilities
✅ Compliance Strengths
🎯 Priority Actions
📋 90-Day Implementation Action Plan
🚀 How Reviewr Can Help
Based on your assessment results, Reviewr's grant management platform can help you:
Why Reviewr
Reviewr is a grant management platform built for modern, mission driven, organizations. We replace your scattered spreadsheets, disconnected tools, endless emails, and manual processes with one unified system that handles the entire grant lifecycle—from accepting applications to measuring long-term impact. The result? Your team spends less time on administration and more time making a difference.
84%Less time managing grants
Automated workflows eliminate manual data entry, email coordination, and spreadsheet updates—giving your team back 30+ hours every week.
5xFaster review cycles
Collaborative scoring, side-by-side comparisons, and automated reviewer assignments turn months-long processes into weeks.
94%Complete impact visibility
Real-time dashboards and automated grantee impact reporting mean you always know exactly how your grants are performing.
Solving real challenges
Take a quick tour
The Grant Applicant Experience
Empower grant applicants with the modern and user friendly experience they desire – promoting more engaged participants, increased participation rates, better quality submissions, and reduced support.
Optimize your grant program’s online presence with Reviewr’s landing pages, designed exclusively for grant management and the needs of Grantmakers. These landing pages are more than just a digital experience; they’re an integral part of Reviewrs comprehensive grant software. Landing pages are crafted to highlight grant details such as important dates and deadlines to eligibility criteria, ensuring all pertinent information is accessible and clear. Landing pages embrace your brand’s identity, allowing for primary and secondary color control to align with your style guide. Highlight your sponsors with dedicated spaces for logos, enhancing credibility and connection with your audience. With Reviewr’s grant management system, create a seamless, engaging experience for your applicants while maintaining the professional look and feel of your program.
Streamline the grant application process with Reviewr’s intuitive and robust grant application functions. Designed with both grant applicants and grant providers in mind, Reviewer simplifies the submission process, allowing applicants to provide all necessary information efficiently and accurately. If you can dream it up, the Reviewr grant application form builder can power it.
Grant applicant profiles are a core component to the Reviewr grant management software. Profiles empower grant applicants to create and manage their information, centralizing their grant journey from the initial application to final selection and more. Profiles enable grant applicants to apply to multiple grants, submit necessary files and deliverables, add additional content tailored to different program stages of the grant process, receive communication, and access grant selection results.
Supplemental forms are an exciting and innovating new feature to Reviewr. Supplemental forms enable grant applicants to either request additional information from external sources or add additional submission forms to their profile for different stages of the grant process. Supplemental forms are often used to collect reference requests and grant reporting forms/templates directly from the source. Grant applicants can also access their grant profile and add dedicated forms/deliverables requested by grant providers at different stages of the program.
The Grant Management Experience
Increase grant management efficiency by an average of 84%, saving time and money that can be better allocated to other high-impact activities. Manage the entire program lifecycle in one place – eliminating the back and fourth between paper, email, web forms, spreadsheets, exporting, databases, file sharing, and more.
Transform your grant administration with Reviewr’s Grant Manager Dashboard, the command center at the heart of our grant management software. Leverage the dashboard for real time monitoring of dates, deadlines, and activities. Navigate to dedicated grant management tools such as managing users, creating workflows, viewing grant applications, communicating with both applicants and staff, generating reports, and much more.
Easily search, filter, and sort grant applications from the grant management software. Designed for efficiency, grant providers can view grant applicant profiles, view submitted grant applications, access files and deliverables, communicate with applicants, leave internal notes, and more!
Streamline your review process with Reviewr’s dynamic feature for assigning grant applicants to review committees, a vital tool within our comprehensive grant management software. This feature offers versatile assignment options to accommodate your program’s unique needs, ensuring a fair and unbiased evaluation process. Manually assign individual grant applications to specific committee members for a tailored review approach, or utilize groupings to distribute batches of applications efficiently among different reviewers. For a more impartial distribution, leverage the automated assignment system, which randomly allocates a set number of submissions to judges, mitigating potential biases and promoting a fair assessment environment. This assignment flexibility ensures that each application is reviewed thoroughly and fairly, enhancing the integrity and credibility of your grant program.
With Reviewr, simplify your review process while maintaining a high standard of fairness and transparency in applicant evaluation.
The Review Experience
Reduce volunteer workloads by 79% and promote a professional and time-conscious online review and selection experience resulting in higher quality reviews, feedback, and increased year over volunteer retention. Ensure program integrity and confidence through non-bias, accurate, transparent, consistent, and data-driven decision-making.
Elevate your grant review process with Reviewr’s online review and selection tools, an essential part of our grant management software designed to enhance efficiency and decision-making. This feature empowers review committee members to sort, filter, find, and view detailed information on grant applicants seamlessly. Looking to blind data, don’t worry – grant providers have direct control over what data is visible to review teams.
Maximize the effectiveness of your grant review process with Reviewr’s innovative side-by-side interface, a key feature of our grant management software that creates significant efficiency for review team workflows. This intuitive interface allows review committees to simultaneously view grant applicant profiles and materials alongside an online scorecard/selection tool, streamlining the evaluation process. This side-by-side approach helps minimize switching between forms, documents, notes, and scoresheets for an engaging experience.
Reviewr offers embedded document viewing experience significantly improves the grant review workflow for review teams. The seamless integration ensures that all necessary materials and files are accessible directly in Reviewr without having to download and open in external tools. This approach ensures the ability to conduct side-by-side review in a centralized grant management software.
What would be a grant management software without a dedicated portal to view results for data driven decision making? Eliminate complicated spreadsheets and manual tabulations. The real-time decision making tools provide an overview of the applicants, who reviewed them, how they were reviewed, total scores, and averages. Seamlessly advance applicants to different workflows or leverage the data for informed decision making.
