Standard

Grants Continuous Improvement Assessment Framework V1.1

Updated 4 December 2024

Figure 1: The structure and scope of functional standard GovS 015, Grants.

1. Purpose and scope of the assessment framework

1.1 Purpose of this continuous improvement assessment framework

This assessment framework is designed to help drive continuous improvement within and across government grant making organisations, by helping them to assess their compliance with, and practical application of key features in the Government Functional Standard GovS 015: Grants (PDF, 341KB)

This assessment framework is consistent with assessment frameworks for other government functions, so that senior leaders can take a consistent and coherent view of performance across all functions in their organisation. 

The assessment framework draws on, but does not replace, the Functional Standard GovS015, which should be complied with. The assessment framework should be read in conjunction with the Functional Standard. This assessment framework is designed for people undertaking assessments of their organisation’s grant making policies and processes, and for people taking organisational improvement actions as a result of the completed assessment.

Whilst the framework provides indicators of the Developing, Good, Better and Best assessment ratings, in terms of compliance, it should be read alongside the Government Functional Standard and supporting Minimum Requirements guidance.

For more information on continuous improvement, see the Guide to continuous improvement against functional standards.

1.2 Scope of this continuous improvement assessment framework

This assessment framework applies to the planning, delivery and management of Exchequer funded government grants activity in all central departments and arm’s length bodies, including general grants and grant-in-aid. Other public sector organisations in the administration of government grant funding, devolved or local, might find this document useful and should consider taking account of the guidance within.

This framework will be reviewed regularly by the Cabinet Office and partner organisations

across the public sector to reflect feedback and emerging trends. Any changes made will be communicated to participating organisations.

The structure and scope of the functional standard and this assessment framework was shown in Figure 1 on page 5.

2. Using this assessment framework

2.1 How the framework relates to the functional standard

This continuous improvement assessment framework draws on its related Functional Standard and includes a set of statements indicating different levels of organisational capability against aspects of the Standard, ranging from non-compliance or adopting (‘developing’), through ‘meeting the minimum’ (‘good’), to better and best, as shown in Figure 2.

The assessment framework draws attention to how the requirements of the Functional Standard can be implemented in organisations with different levels of maturity, so that the organisation’s leaders can plan improvement initiatives where needed. Not every organisation, or part of every organisation, needs to operate at best.

Figure 2: Developing, good, better and best

Assessment frameworks are based on statements drawn from the Functional Standard. Good means that all mandatory elements, and the most important advisory elements, are met.

2.2 The structure of the continuous improvement assessment framework

The structure of the assessment framework is designed to give an indicative picture of how well an organisation is doing. It covers:

• Theme: is the overall topic being addressed.
• Metric: what is being assessed.
• Criteria: the statements to be met.

Theme: A theme is the overall topic being addressed in that section of the assessment framework. The context and more information about the themes addressed can be found in the Functional Standard.

Metrics: Each theme comprises a metric. Each metric has an overall statement about what is expected. A metric might relate to one or more clauses in the Functional Standard.

Assessment criteria. Each metric is supported by a number of criteria. Criteria help to define what is happening in an organisation (observable in practice, backed up by documentary evidence). The Criteria denote the requirements of good, better or best performance. Refer to Government Functional Standard GovS 015: Grants (PDF, 341KB) for context and detail. For example, the required content of a ‘management framework’ is described in the governance section of the Standard.

2.3 Assessing an organisation

Before starting an assessment, the boundaries of the organisation being assessed need to be defined. A whole department or arm’s length body can be covered, or the assessment can be limited to a defined part. Be careful when defining the boundaries in terms of specific business areas, as the perceived remit of the associated management team might be too narrow for the assessment criteria to make sense. On the other hand, dividing a large organisation, where performance across the organisation varies, into its major groups can help pin-point where improvements are needed.

Important notes: When considering whether a criterion is being met, we would expect organisations to consider whether or not their policies and processes are meeting the criterion, but also whether those same policies and processes are being complied with consistently across the organisation.

For example, for the criterion “The Risk Register and Fraud Risk Assessment is considered alongside and as part of the development of the Grant Business Case” we would expect organisations to consider whether there is both an internal policy in place to communicate this requirement to grant practitioners but also whether there is documentary evidence of sufficient quality, for example, through sampling, that this specific policy is being complied with.

The self-assessment should include narrative on how the function meets the criteria along with applicable evidence to support the assessment. Departments should avoid optimism bias and ensure that the assessment is evidence-based.

An example of the type of documentary evidence required is provided below. When assessing the metric 3.1 Performance Monitoring, departments could, using a sample of grants, provide the following documentation to support an assessment of Good performance :

• an approved business case setting out the performance and financial review regime;
• the grant agreement communicating this requirement to the grant recipient;
• a performance and financial report submitted by grant recipient;
• assessment from grant manager on the performance of the grant recipient, and confirmation on whether future grant funds can be released subject to meeting performance thresholds; and
• evidence of expenditure, e.g., invoices, either directly by the grant team, or through independent audit.

The assessor should seek to secure assurance that the above documents are easily accessible and retained for future reference.

Attitude is key. This assessment framework is a tool to support organisational improvement, and the assessment will add no value unless there is honesty in response to the criteria.

Business leaders should set ambitions for their organisation based on business needs, as set out in their strategies and/ or plans. For some organisations, or some individual schemes, Good might be good enough.  For other organisations, their area of business might dictate that meeting Best is necessary.

Levels are cumulative. An organisation needs to meet all the criteria of any lower level in order to comply with the higher level, for example, an organisation cannot be Better if it doesn’t meet all the criteria for Good.

Most Functional Standards rely on other functional standards (as listed in clause 1.3 of every functional standard). This interdependence means that for an organisation to be operating effectively,  officials need to consider such dependencies carefully, including their impact on the organisation’s operations. For example, grant delivery in the public sector often relies heavily on recipients undertaking a significant amount of activities. Where this is the case, an organisation could not consider itself fully capable in grant delivery without an appropriate level of capability in counter-fraud work.

Further guidance on assessment frameworks can be found in the Guide to continuous improvement against functional standards.

Attainment is scored on three levels as shown in the table below

Attainment Level	Definition	Value of Statement
Not, or seldom met	The organisation finds there is no evidence, or only isolated evidence, to satisfy consistent attainment of the criteria	0
Partially met	The organisation finds evidence of attaining the criteria but it is inconsistently applied.	0.5
Fully met	The organisation finds evidence that criteria is met in the schemes tested and is consistently applied.	1

The scoring methodology works in the same way for each metric area. Differentiated weightings are applied to criteria within the maturity levels with greater emphasis on criteria within the Good column, as these represent the minimum expectations of an organisation.  However, where Good criteria are not fully met, it is strongly recommended that targeted improvement projects are established.

The self-assessment tool aggregates the values entered for each criterion to give an overall percentage score and corresponding maturity rating for that area. Percentage bandings for each maturity rating are shown in the table below.

Maturity Rating	Applicable percentage ranges within the maximum available score
Developing	0% - 40%
Good	41% - 70%
Better	71% - 90%
Best	91% - 100%

Note: 40% corresponds to the minimum expectation for the administration of government general grants, to achieve a Good rating (40% plus), all elements under the criteria for the Developing rating must be met in full.

In some circumstances a theme may not be viable for assessment due to the scope of grants activity carried out by the organisation. This should be an exception, and should be agreed with a relevant department or the Government Grants Management Function (GGMF). Assessors should select the option ‘Not Applicable’ to  remove the criterion/ criteria from the scoring.

2.4 Characteristics of developing, good, better and best for Grants

The paragraphs below provide a broad definition of the four rating categories, used by the Grants Continuous Improvement Assessment Framework (GCIAF) in assessing the maturity of policies and processes in government grant making organisations, against the requirements of the Functional Standard and associated minimum requirements for general grants.

Developing: By default an organisation is developing if it doesn’t meet each of the criteria under the good category. For this reason, the continuous improvement assessment framework does not include criteria for developing. This category would indicate a perceived weakness and a robust improvement plan should be put in place and closely monitored.

Good: A cross-government grants and governance management framework is defined and established. Organisations have a clear grants strategy and plan. Grants are awarded using legally compliant, fair and transparent processes, in line with public law principles, guarding against corruption and fraud. Activities are always aligned with grants policy and organisational objectives, and conform with the Grants Functional Standard. Organisations contribute to the grants pipeline and develop capability to drive consistency in the planning and management of grants. Robust grant agreements and proportionate performance monitoring are in place to realise value for money and result in the delivery of high-quality public services.

Note: Good includes the mandatory requirements (‘shall’ statements) from the functional standard and the most important advisory elements - these are also summarised under each minimum requirement guidance document.

Better: The governance of grant activities is an integrated part of the organisation’s overall governance. The governance and management framework includes the development and monitoring of policies delivered via grant schemes. The grants strategy maximises synergy and efficiency between different organisations. Lessons learnt and best practices are systematically captured, shared and reviewed with stakeholders at the start and end of each activity. Continuous improvement is embedded in the organisation’s practices through updates to its continuous improvement plans, learning and development opportunities.

Best: There is active involvement of senior leaders in managing the grants environment and discussions take place at Executive Committee level on the grants strategy and landscape addressing any significant risks across the grants portfolio. The proposed grants landscape will be mapped out over the next 5 years. Benchmarking grant activities across other grant making areas takes place to identify good practice and share lessons learnt. There is a process in place to identify and re-prioritise resources and capacity to enable them to be flexed to higher profile areas.

2.5 Using the output of an assessment

Completed assessments can be used to help identify and share good practice, address perceived weaknesses in the performance of the organisation and to inform continuous improvement activity.

The completed assessment framework is for internal government management, designed to facilitate frank and open discussion around performance. Organisations should interpret the assessment outcome in line with their organisation or sector specific grant improvement model. Individual completed assessments are not intended for publication. Organisations should define improvement plans to target specific areas for development, informed by the recommendations in the Continuous Improvement Assessment Report.

There is a system in place with GGMF to monitor the improvement plan on a periodical basis (currently quarterly), to ensure actions are targeted and progress is being made. A range of engagements, interventions and communications activity takes place to support the sharing of best practice

• Self-assessment is a cyclical process. Organisations self-assess their maturity against the applicable metric areas within the improvement framework (currently every 2 years). Central government departments then define improvement plans to target specific areas for development and participate in good practice sharing across the network. Improvement activities should have defined owners with a timescale given for completion. There should be a system in place to monitor the improvement plan on a periodical basis to ensure progress.
• The framework is intended to form part of a wider culture of continuous improvement. The self-assessment data is used (where data has been authorised for sharing with Cabinet Office) to identify leading practices across the network and areas of common challenge across the public sector.
• When gathering evidence, the team conducting the assessment may be reliant on engagement with, or direct provision of, information from the wider business. Early engagement with the business can help to obtain information and evidence may be sourced through proportionate sampling of the relevant organisational processes.

2.6 The structure of this assessment framework

The table below sets out the structure of the assessment framework, listing the Metric areas addressed in each theme.

Theme 1: Grants Governance, Strategy and Planning

• Metric 1.1 Strategy, Planning, and Grant Pipeline
• Metric 1.2 Governance, Management Framework and Senior Grant Roles
• Metric 1.3 Leadership
• Metric 1.4 Ethical and Sustainable Grant Recipient Management

Theme 2: Grant Development and Award (Stages 1-4)

• Metric 2.1 Design and Development Stage 1
• Metric 2.2 Market Engagement Stage 2
• Metric 2.3 Application Assessment Stage 3
• Metric 2.4 Award Stage 4

Theme 3: Grant Management (Stages 5-6)

• Metric 3.1 Performance Monitoring Stage 5
• Metric 3.2 Final Evaluation Stage 6

Theme 4: Capacity and Capability

• Metric 4.1 Capacity
• Metric 4.2 Capability

Theme 5: Control Framework

• Metric 5.1 Risk Management
• Metric 5.2 Counter Fraud
• Metric 5.3 Assurance

Theme 6: Digital and Management Information

• Metric 6.1 Accuracy and Completeness of Grant data
• Metric 6.2 Reporting and utilising grant data

Theme 7: Grant in Aid and ALBs

• Metric 7.1 Grant in Aid Governance
• Metric 7.2 Grant in Aid Management Information reporting

3. Assessment framework

3.1 Theme 1 Grants Governance, Strategy and Planning

1. Metric 1.1 Strategy, Planning, and Grant Pipeline

The strategy and plan should outline the vision and objectives of the organisation’s grant portfolio, ensuring compliance with the organisation’s policy and processes and alignment with the business plan. Having a medium to long term strategic view of the organisation’s portfolio (a pipeline), and consideration of the resources to support delivery, support effective and efficient delivery of policy objectives.

Good

Criteria denoting good performance

a) The strategy contains detail on the grant making organisation including capability, capacity and responsibilities, and how it deals with its ALBs.  The strategy covers key areas of consideration including funding allocation, fraud risk, and governance, including clarity on who is responsible for what.

b) The annual Accounting Officer System Statement (AOSS)Formal statement includes a statement on the Grant Strategy and resourcing.

c) The Pipeline is aligned with financial constraints as to the value of available funding.

d) Demand management is considered, that is the impact that significant numbers of grant applicants can have on the capacity of the system.

e) Organisations will carry out adequate early market analysis (employing resources in a manner proportionate to the risk, and value of the funding initiative, as well as to the size and complexity of any potential market) to understand:

• the market’s appetite and need for the funding initiative;
• potential objectives, outcomes and impacts (which may feed into Business Case development);
• the best means of communicating the organisation’s intent;
• identify and understand the needs of potential market participants.
• Organisations have a clear understanding of the fraud and risk landscape, fraud risk capability in place, and an understanding of the specific risk appetite for individual grants.

Better

Criteria denoting better performance

a)There is a strategy that has clear and specific alignment to medium and longer-term business priorities, targets and budgets’

b) A pipeline of grants is held up to 18-months ahead, with the data held on the Government Grants Information System (GGIS).

c) There is a process in place to obtain independent challenge and advice on grant schemes (significant in value, importance or consequence) that are in development, as they arise, and to review existing schemes, for example, a Challenge Panel of internal and possibly external experts.

Best

Criteria denoting best performance

a) There is periodic review and resultant action to implement better grant making.

b) Benchmarking of other grant making areas is undertaken to identify good practice.

c) The organisation has mapped out the proposed grant landscape for the next five years, i.e. significant grant schemes to be progressed and sectors supported.

d) Areas of grant funding that would be defunded in the event of budget cuts have been identified.

1. Metric 1.2 Governance Management Framework and Senior Grant Roles

The governance and management framework should clearly define individuals filling required grant related roles within the organisation, their responsibilities and accountabilities, and delegations levels (financial authority) for grants. Individuals identified in the strategy should play an active part in ensuring the effectiveness of grant making in the organisation.

Good

Criteria denoting good performance

a) A clear grants governance and approvals framework is in place and communicated to and understood by stakeholders within the organisation.

b) There is someone in post for the following who all have clear roles / responsibilities:

1. Accounting officer.
2. Senior officer accountable for finance in an organisation.
3. Senior officer accountable for an organisation’s grants.
4. Senior officer responsible for a grant.
5. Grant manager.

c) A Grants Champion is appointed to act as the conduit for disseminating information and communications to grants practitioners in the department and associated grant making Arm’s Length Bodies.  The Champion also acts as the single point of contact for the GGMF and actively participates in the various boards and networks made available by the GGMF, to enable cross-government collaboration and information sharing.

d) There is sufficient and accurate reference in the Accounting Officer System Statement related to grant responsibilities.

e) Role holders have completed the basic overview training on Civil Service Learning, related to grants management.

Better

Criteria denoting better performance

a) Role holders have all had training for those roles, and have a good understanding of grant management.

b) Role holders can articulate their role in relation to the three lines of defence.

c) There is a clear approvals route and defined delegations.

d) There is allocation of sufficient grant making resources to support the activities of the role holders to deliver this activity.

e) Role holders have clear personal objectives related to the role.

f) The Grants Champion takes opportunities to present to peers on issues and best practice, via the Best Practice Network and other forums.

Best

Criteria denoting best performance

a) Active involvement of senior officers in managing the grant environment through membership of departmental Challenge Panels, representation on department level boards to discuss / champion the grants agenda.

b) Those filling Senior Grant roles have membership of New Grants Advice Panel or Complex Grants Advice Panel.

1. Metric 1.3 Leadership

This concentrates on the key individuals responsible for effective grant making, particularly the Senior Officer Responsible for a Grant (usually referred to as the SOR). Effective leadership by these individuals is key to the successful delivery of grant objectives.

Good

Criteria denoting good performance

a) The organisation has a Senior Officer Accountable in post, providing leadership and strategic direction in the administration of the organisation’s grants portfolio and oversight/ control of grant related financial decisions.

b) Every grant shall have a named SOR through the grant life.

c) The SOR will have undertaken suitable training, and have good knowledge and experience of policy development, project management and grants administration.

d) SORs lead periodic reviews of the performance of schemes, and considers the risks to delivery. This includes ongoing oversight of fraud, due diligence, and other risks

Better

Criteria denoting better performance

a) Individual SORs have membership of a network of grant making SORs across government.

b) The department has established a Continuing Professional Development programme to share knowledge and experience across all their SORs.

c) There is a named individual in the organisation who is responsible for, and actively taking forward grant making as a profession.

Best

Criteria denoting best performance

a) The organisation has identified their most effective or experienced SORs, who can be made available to support new or less experienced colleagues to address grant related complex questions, issues, risks and emergencies that may arise.

2. Metric 1.4 Ethical and Sustainable Grant Recipient Management

Summary: ethical grant management relates to the Public Sector Equality Duty and to the responsibilities of the grant recipient to deliver the scheme in accordance with the grant making organisation’s policies. Relevant to this are the Code of Conduct for Recipients of Government General Grants, and the responsibilities of government organisations to be responsible grant makers, including the Compact with the Civil Society Organisations. (PDF, 288KB)

Sustainable relates to the need to consider environmental factors in making grants, particularly in supporting the 2050 Net Zero target.

Good

Criteria denoting good performance

a) An Equality Impact Assessment is undertaken for each scheme, in line with the Public Sector Equality Duty.

b) All Grant Agreements contain reference to the Code of Conduct, and require grant recipients to have effective reporting and whistleblowing processes related to failure to respect the dignity, safety, security and well-being of end-users.

c) There are provisions in Grant Funding Agreements to promote ethical and sustainable behaviour.

d) Organisations apply the requirements of “The Compact” in their grant making including:

• consider how grants can be used to fund or resource Civil Society Organisations; - consider how the grants process can be simplified to make it easier for smaller Civil Society Organisations to obtain grants; - recognising that when Civil Society Organisations apply for grants they can include appropriate and relevant overheads;
• Organisations assess the impact of funding decisions, giving at least 3 months’ notice if grant funding is to cease.

Better

Criteria denoting better performance

a) The organisation has in place visible and effective whistleblowing arrangements to identify non-ethical/ sustainable organisations.

b) There is reference to 2050 Net Zero in the overall grant strategy, with practical translation to individual grant scheme design and administration.

c) There is a strategy/ objective to release awards and payments promptly, particularly in areas where cash flow can be challenging, i.e. within the voluntary sector.

d) There is periodic review of current Direct Award grants to consider if future grants can be competed – the rate of direct award, as a proportion of the overall grants portfolio, is kept under review to ensure appropriate volumes/ practice.

e) Detailed feedback is provided to unsuccessful applicants for grant funding.

Best

Criteria denoting best performance

a) There is identification and review of existing awards where there are allegations of unsustainable/ unethical behaviour.

b) There is effective intelligence sharing of grant recipients’ poor behaviour and concerns, etc., but this is undertaken ethically and within the bounds of applicable law.

3.2 Theme 2 Grant Development and Award

3. Metric 2.1 Design and Development Stage 1

This area focuses on the design, development, and sign-off of the business case, to authorise the scheme to proceed as planned. This stage is key to ensuring that there is a good justification of the value of the grant, and that the control framework proposed is effective. Risk and fraud risk assessment (covered in 5.2) are important at this stage, together with consideration of National Security Risk (covered in 5.1).

Good

Criteria denoting good performance

a) Organisations have in place, apply, and record the details and outcomes of internal processes covering:

· the organisation’s risk appetite; · an early risk assessment for the funding initiative; and · allocation of appropriate resources to develop a business case (or equivalent document) and carry out related work.

b) A thorough and robust business case is developed for all grants. Business cases should be proportionate to the value and risk of the scheme, and will include:

· justification of the funding initiative; · an early market assessment; · clear objective(s); ·alternative options, value for money; · the risks that the grant will be subject to; · the assurance framework needed; · checks undertaken to ensure no overlapping of funding; and · clear criteria on decision making, and approvals.

c) The Risk Register and Fraud Risk Assessment is considered alongside and as part of the development of the Grant Business Case.

d) Organisations make an early assessment on whether or not a referral should be made to the Complex Grants Advice Panel, and record that decision in the business case or equivalent document.

e) Where a scheme is referred to CGAP, action is taken to consider any recommendations made as a result of the referral, in particular where the Panel’s assessment is to give a ‘red’ rating, subject to addressing the Panel’s recommendations.

Better

Criteria denoting better performance

a) Organisations carry out internal checks on new grants with reference to lessons learned from the impact evaluation of previous similar schemes and awards.

b) Where useful, core grant documents, e.g. the risk assessment, are shared internally within the organisation for wider comment, i.e. practical use is made of the documents ensuring they are not conducted for the sake of the policy team’s handling the funding initiative.

c) Where possible, the organisation develops early thinking from the scheme’s objectives, to cover possible outcomes and impacts from the funding initiative.

d) Where appropriate, elements of the funding initiative are piloted and evaluated, to assess effectiveness and help mitigate against risks during full implementation.

e) GGIS data is routinely used to avoid duplication of activity and to identify opportunities to join-up schemes across government.

Best

Criteria denoting best performance

a) Organisations undertake external liaison with other government departments and/ or ALBs to share best practice and lessons learned.

b) Organisations establish and utilise an internal (or mixed) challenge panel to review new and existing grants.

1. Metric 2.2 Market Engagement Stage 2

Effective competition is key to the delivery of best value for money from grant expenditure. Managing the competition process effectively is important to reduce reputational damage, mitigate legal risk and claims of breaches of regulations on open and fair competition. It is also important that there is a sound, evidence-based rationale for any decision to make direct award of grant funding, in place of a competition, authorised at the appropriate level in the department. Where direct award is approved, the associated monitoring regime should be enhanced to ensure value for money is maximised, to off-set any loss in value for money usually achieved via a competition for funding.

Good

Criteria denoting good performance

a) On receipt of appropriate approvals, organisations engage with markets in a manner proportionate to the risks and value of the award in order to:

• identify potential recipients;
• update any earlier market assessment (see 1.1 above); and
• promote the funding initiative.

b) Engagement and assessment activity is recorded, and incorporated in the development of the competition assessment criteria.

c) Based on the results of market engagement, an evidence-based assessment is made as to whether or not full competition is possible, what form it should take, and how to best develop a call for applications. This assessment is taken in conjunction with additional evidence from the Business Case and the scheme’s objectives, outputs and longer-term impacts.

d) General grant schemes are competed by default, except where justification for a direct award is clear.

e) Exceptions to a competitive model for general grants are approved at the appropriate level - the SOR is responsible for ensuring direct award proposals are approved.

f) There is no automatic rollover of grants preventing consideration of competition.

g) Where, by exception, it is not possible or desirable to compete funding, there are alternative recorded processes that ensure risks associated with direct awards are mitigated. These may include: enhanced due diligence, covering estimated expenditure; regular reviews on outcomes; and the possible use of external assessors.

h) All exchequer-funded general grants which are competed or criteria-based are advertised on Find a Grant from 1st April 2023.

Better

Criteria denoting better performance

a) External, independent reviewers provide scrutiny over market engagement and competition assessments - these can be within the organisation, but external to the policy team, and include those with expertise in running funding competitions, for example, members of the commercial function.

b) There are processes to address multi-year grants with provisions to re-compete regularly, allied to efficiency targets to encourage sustainability and maximise value for money (where possible and appropriate to do so).

c) Where possible: processes are in place to encourage applications that allow for market participants and potential recipients to be involved in the development of funding objectives, i.e. to present in competition how they would use the funds, and possibly even respond to calls for evidence.

d) The organisation ensures the extensive use of match funding through its general grant schemes, to increase value for money and collective ownership of outcomes, using a flexible model to maximise the opportunity for recipients to engage, where applicable.

Best

Criteria denoting best performance

a) Organisations have an internal (or mixed) challenge panel that is systematically used to review new and existing grants, where it is appropriate to do so.  Including advocating the requirement to compete government grant funding and offering robust challenge to all proposals for direct award and making recommendations on best practice in all cases.

b) Creative use of competition models in partnership with the commercial function (where appropriate), for example, challenge funds and consortia models, to maximise innovation and value for money.

2. Metric 2.3 Application Assessment Stage 3

There should be a systematic process to evaluate and select grant recipients, to undertake effective due diligence, and to notify applicants of the results, providing feedback to unsuccessful applicants.

Good

Criteria denoting good performance

a) The assessment process and criteria used to select successful applicants is clearly defined. The rationale for the subsequent award decision is retained for the audit trail.

b) Assessors are provided with a code of conduct, setting out responsibilities, including the declaration of any conflict of interest.

c) Successful grant applicants are sent a grant offer letter. Unsuccessful applicants are also notified in writing.

d) Every grant is subject to proportionate due diligence (proportionate being defined in Metric 1.1(e)).

e) Due diligence is tailored to the specific grant.

f) There are enough appropriately trained people to undertake due diligence activity, including the capability to interpret results.

g) Due diligence results, including higher risk areas, are identified and actioned.

h) Due diligence activity is updated during the lifetime of the grant scheme.

i) Appropriate digital tools, such as the GGMF’s Spotlight due diligence tool, are used to identify due diligence risk areas.

j) Practitioners have good knowledge of department risk appetite related to due diligence.

Better

Criteria denoting better performance

a) Unsuccessful applicants are always provided with feedback.

b) Due diligence activity is integral to the organisational strategy, or there is a standalone strategy for it, as is the case for the FCDO.

c) Experts, for example legal, finance, commercial and audit professionals, are used to supplement and provide additional assurance on due diligence assessments.

d) There is sharing of due diligence assessments within the department.

e) Best practice on due diligence is identified and communicated throughout the department.

f) There is a training strategy to upskill grant makers on due diligence.

g) Spotlight is routinely used for due diligence review for all grants.

Best

Criteria denoting best performance

a) The organisation has capability to provide resource to help other departments on due diligence activities.

1. Metric 2.4 Award Stage 4

The Grant Agreement sets out the terms and conditions for delivery of the grant, with which the recipient is required to comply.  Provisions include specific boundaries such as eligible and ineligible expenditure. It is therefore important that the Grant Agreement is appropriately tailored to specific requirements of the grant scheme and includes elements of the control framework that will support effective financial and performance monitoring and management.

Good

Criteria denoting good performance

b) Every grant has a Grant Agreement (GA) that is fully compliant with the grants Functional Standard (GovS: 015), for example, agreements are robust, tailored and proportionate, providing a clear statement of the purpose and objectives of the funding.

c) Grant Agreements contain terms of eligible and ineligible expenditure, which is specific to the grant and in line with the best practice guidance under minimum requirement 6.

d) The grant is awarded for a defined period.

r) Grant Agreements include terms and conditions that are appropriate to the scheme, with proportionate audit requirements.

f) Legal advisers are involved in signing-off grant agreements for use, in particular for divergences from the Model Grant Funding Agreement.

g) Every Grant Agreement provides a clear financial and performance monitoring, reporting and management regime.

h) Grant agreements, with effect from 5th December 2022, where appropriate, include a definition and clause to comply with Funded by UK Government Branding.

Better

Criteria denoting better performance

a) Examples of standard and specific clauses that reflect best practice are shared within the organisation.

b) There is consideration of actual performance monitoring requirements versus the burden on the grant recipient to provide reports, etc.

c) Electronic Grant Agreements are issued, saving on time and resources and supporting retention of the key documents.

d) Management tools, such as the setting of performance expectations/ tolerances, linked to payment suspension, termination and clawback clauses, are used flexibly to encourage delivery and maximise value for money.

Best

Criteria denoting best performance

a) Financial and performance monitoring models are flexible and responsive, with more stringent conditions targeted towards higher risk, higher value or more sensitive grants.

b) A grant system is used that details the monitoring timescales and framework that will be undertaken through the grant life.

3.3 Grant Management

2. Metric 3.1 Performance Monitoring Stage 5

To help realise policy outcomes, effective performance and financial management should be put in place, to help achieve delivery to time, within the agreed budget.

Good

Criteria denoting good performance

a) Grant teams have a schedule for performance and financial monitoring and review, as defined in the business case.

b) The grant team monitors the delivery reports from grant recipients to assess performance in accordance with their grant agreement.

c) The grant team undertakes appropriate and proportionate checks to ensure grant recipients are compliant with the Grant Agreement, including eligible and ineligible expenditure and submissions of monitoring reports.

d) The grant team actively reviews the performance of the grant recipient, and the release of future grant funds is subject to meeting performance thresholds, as set out in the grant agreement – note: grant funds should be issued in arrears in most cases.

e) The receipt of financial and performance monitoring returns are used as the trigger to make grant payments, for example, payment is released only on receipt of satisfactorily completed returns, which pass whatever validation process is in place.

f) There is checking of transactions against evidence of expenditure e.g.invoices (either directly by the grant team, or through independent audit). If 100% checks are not possible there should be an agreed percentage sample check, with provision to escalate where errors are found.

g) For grants administered under Section 31 of the Local Government Act, 2003, funding is not generally ring-fenced: the authority seeks reasonable confirmation from the local authority/ public body that the grant outcomes have been achieved, to inform value for money assessment and future policy making.

h) Performance and financial reports related to delivery are securely saved for future reference, in line with any applicable legislation, for example, payroll records should be retained for 3-years from the end of the tax year to which they relate.  Standard documents should be retained for a minimum of two-years from the end of the grant delivery period.

Better

Criteria denoting better performance

a) Grant Management Plans are put in place, which define the performance management and monitoring that should be undertaken for each grant scheme.

b) The organisation considers rotating grant managers to increase objectivity.

c) There are 2nd line checks on the effectiveness of grant performance management.

d) There are ongoing due diligence checks through the life of the grant.

e) Key performance indicators or key outputs are used to support effective monitoring of delivery and to inform decision making.

f) Financial forecasts of outturn have a high level of accuracy, with overspends or underspends reported by Accounting Period Month 3.

g) There is effective reporting of performance in place, so that the organisation can report to ministers or senior officials, at any point of time as required, on the performance of grant delivery and achievement of outputs.

Best

Criteria denoting best performance

a) There is an enhanced engagement strategy with the grant recipient, which includes, for example, site visits and face-to-face meetings.

b) Grants are rated according to risk, value and delivery importance, and the level of performance monitoring and management undertaken is structured, based on that rating.

3. Metric  3.2 Final Evaluation Stage 6

This category is concerned with financial and performance reconciliation, to inform the decision as to whether to continue the grant from one year to another, and whether there is a good assessment on whether the grant has delivered the outcomes expected and achieved value for money. Formal impact evaluation is also part of this step and is distinct from the reconciliation – impact evaluation is concerned with assessing longer-term impact through qualitative and quantitative methods, to assess the efficacy of the scheme and how well it met its objectives.  Value for money is also considered under the evaluation.

Good

Criteria denoting good performance

a) A formal reconciliation is undertaken at the end of the year to consider if a multi-year grant should continue.

b) End of grant reconciliation is always undertaken to identify and confirm that business case objectives and outcomes have been achieved.

c) There is consideration of the extent to which all grant money has been used by the grant recipient based on a financial reconciliation exercise, and to identify any surplus funding for clawback. This includes a reconciliation of funding paid versus actual expenditure reported by the grant recipient against eligible categories.

d) Formal impact evaluation is undertaken internally based on approved research and evaluation methodologies.

Better

Criteria denoting better performance

a) There is periodic assessment, based on a grants forward pipeline on whether the grant should continue to be a grant, or be delivered through an alternative mechanism such as a contract, or be discontinued.

b) Formal impact evaluation is undertaken on completion of the grant, involving external evaluators and peer review, where appropriate, with the results widely communicated to grant managers, and used to inform future grant making.

c) A minimum of 10% of grant recipient transactions are subject to financial reconciliation to confirm expenditure was appropriate.

d) For Emergency Grants – the requirement to undertake a post award assurance exercise is considered given the higher risk of fraud and error arising from the rapid release of funding and reduced pre-award assurance and due diligence.

Best

Criteria denoting best performance

a) Decisions on multi-year grants are considered by a challenge panel, convened with experts, to consider the evidence for or against continuing the scheme into the next financial or calendar year.

b) Impact evaluation reports are published and shared across government, to raise standards and help improve government grant making.

3.4 Theme 4 Capacity and Capability

4. Metric 4.1 Capacity

Capacity relates to ensuring sufficient, appropriately qualified and expert resources are available to support grant making through the end-to-end (six stage grant lifecycle), as well as the resourcing of central supporting teams, such as a central grants portfolio team. While capacity principally relates to people, effective use of systems, including digital capability and efficient processes, also play an important part. There should be consideration of the need to be prepared to mobilise quickly to support emergency grant making when applicable.

Good

Criteria denoting good performance

a) The organisation has a clear structure in place, with oversight of resources, capability and the ability to respond quickly to unplanned events.

b) The organisation has assessed the requirements to manage its grants portfolio effectively.

c) The organisation’s central grants team is proportionately and adequately resourced, in line with the grant landscape, to provide timely and effective advice and support to grant makers.

d) The organisation has incorporated the need to make emergency grants into business continuity and emergency response plans.

Better

Criteria denoting better performance

a) Succession plans are in place for SORs managing significant grant schemes.

b) The organisation has a strategy or guidelines to quantify the number of grant makers that a scheme needs to be managed effectively.

c) Business cases detail the resource requirement, including resources and other systems such as digital capability, to manage the grant portfolio efficiently and effectively through the six stages of the lifecycle.

d) Risks related to insufficient resources are identified and action taken to provide the necessary remedy.

e) The organisation has identified scenarios in which emergency grants may be needed, and has a plan to support that activity.

Best

Criteria denoting best performance

a) There is a process to identify and reprioritise resource capacity to enable them to be flexed to higher profile areas.

5. Metric 4.2 Capability

Ensuring that those involved in grant making have good capability and access to further learning and development is essential if grants are to be effectively managed. Minimum Requirement 10 requires that all those involved in grant making undertake core training. It is important that organisations monitor and manage the uptake of that training to support grant management through the six stages of the lifecycle.

Good

Criteria denoting good performance

a) 100% of all staff involved in grants administration have undertaken the GGMF online Grants Awareness Programme (GAP) including: Introduction to Grant Management; General grants or Commercial learning;  Grant risks, controls and assurance and Fraud in Grants elearning or an equivalent training package provided by the organisation. GAP is accessible on the Learning Platform for Government (formerly Civil Service Learning) and Government Commercial College for departments. Where ALBs do not have access to the elearning, the equivalent PDF format provided by Cabinet Office on grants Centre of Excellence has been read and understood.

b) The organisation’s 2nd line of defence actively monitors the take-up of training to ensure grant makers are appropriately qualified.

c) All grant makers are registered on and make use of the GGMF grants Centre of Excellence.

d) Where internal guidance is provided to supplement that provided on the grants Centre of Excellence, it complements central guidance and provides the organisational context, and is easily accessible and regularly reviewed and updated where required.

Better

Criteria denoting better performance

a) The organisation has learning pathways to help grant makers map their development to improve their knowledge and capability over time – to include taking the GGMF’s additional  training modules and toolkits available on the grants Centre of Excellence Capability Page.

b) People undertaking Fraud Risk Assessments have undertaken counter fraud training via the Government Counter Fraud Function and are members of the Fraud Profession.

c) There is a process to remind individuals to refresh their grant training.

d) In house training is tailored to the policy objectives and priorities of the business.

e) The organisation has linked up with other grant training providers to broaden the range of training available to its grant makers and SORs.

Best

Criteria denoting best performance

a) Specialist internal and external resource such as legal, economists, scientists and social researchers, can be accessed or commissioned when required.

b) There is a process to ensure those making grants undertake the required training, for example, the DCMS process of issuing a grant reference number only when people have proven that they have completed appropriate training.

c) Grant licences are issued to experienced and capable grant makers.

d) The department has in place a buddy system, to support new grant makers as they join the organisation.

3.4 Theme 5 Control Framework

6. Metric 5.1 Risk Management

Effective risk management is required through the life of the grant to reduce risk and improve the likelihood of successful delivery of outputs, longer term outcomes and increased value for money. This area is focused on how risks to grant objectives are identified and managed by the organisation, working in partnership with the grant recipient.

Good

Criteria denoting good performance

a) All Grant Schemes, and grants above £100k or high risk, should hold Risk Registers through the life of the grant. The risk register is discussed with the SOR when managing the grant.

b) Significant grant risks have been outlined in the Grant Business case, along with mitigating action/ controls.

c) The due diligence activity should include risk assessments to determine the risk profile and monitoring required.

d) There are effective processes and systems to communicate specific grant risks to the organisation’s senior management, and grants central team.

e) Specific high risks related to National Security, value for money, loss of personal information, high levels of fraud or error are escalated for management review.

f) Those involved in grant making have undertaken the Grant Risk, Control and Assurance training module.

g) There is Executive Board level scanning of the environment for grant risks and issues (where grants are significant to the organisation).

h) For relevant organisations there is an appropriate process to consider national security risks, for instance for sensitive research.

Better

Criteria denoting better performance

a) The Board has discussed and considered an overall grant risk appetite, and taken reasonable action to reduce the risk of the Accounting Officer being required to appear before the Public Accounts Committee (PAC).

b) The organisation has agreed and communicated its grant risk appetite to grant managers, so that they are clear what risks they should be especially aware of.

c) The organisation uses the risk profile of grants to help focus attention and assurance activity.

d) A risk assessment tool is in place that supports decision making as to what are High / Medium or Low risk grants.

e) Grant risks are communicated to the grants central team who have a good picture of risk, delivery and financial performance.

f) The central team meet periodically with grant teams to discuss the grant risks.

g) High risk grant risks are escalated and are managed effectively.

h) Grant recipients of significant grants are asked to maintain a risk register detailing risk to delivery of their objectives, for view and discussion by the grant making organisation.

i) There is communication of the organisation’s risk appetite to the grant recipient.

Best

Criteria denoting best performance

a) There is independent peer review of the grant recipient risk registers / risks, perhaps through deep dives or internal audits focused on risk.

b) Grant risks and issues are discussed at Board and Audit Committee level.

7. Metric 5.2 Counter Fraud

Effective counter fraud assessment and activity maintained through the life of the grant, is important to reduce the risk of loss or misuse of grant money, and subsequent reputational damage.

Good

Criteria denoting good performance

a) There is sufficient reference to counter fraud assessment and mitigation, which is specific to grants, in the department Counter Fraud Strategy.

b) A specific fraud risk strategy for grants is maintained (and reviewed annually). There is a good understanding by grant teams of the fraud risk appetite of the department.

c) Fraud Risk Assessments are undertaken for all grants at the grant design stage, and updated and maintained through the life of the grant.

d) Appropriate controls are built into grant management and provision included in the grant agreement, to enable monitoring, reporting audit and remedial action, including termination and clawback, in relation to the identification of fraud.

e) For multi year grants, the Fraud Risk Assessment is reviewed and updated at least annually.

f) Due diligence requirements as defined at the grant design stage, included in the business case, and as part of the Fraud Risk Assessment, are maintained through the life of the grant.

g) The department Counter Fraud Champion, or another fraud expert, has played an active role in reviewing significant grants.

h) Digital tools are used to undertake due diligence and counter fraud activities, i.e., Spotlight.

i) There is an internal process to report suspected grants fraud for subsequent action.

j) Grant recipients are required by the terms of the grant agreement to report instances of suspected and actual fraud, related to the grant awarded to the organisation.

k) Grant recipients are required by the terms of the grant agreement to have a process for employees to feed back to the authority, common areas of fraud related to the grant.

l) The Grant team has undertaken the Grant Counter Fraud training.

Better

Criteria denoting better performance

b) Grants are referred to CGAP for advice, where applicable, and effective action is taken on any Counter Fraud advice and recommendations provided.

c) Training capability is available and used to improve consideration of grant fraud.

d) Fraud results, lessons learnt and root causes, are shared widely in the department.

e) Specialist counter fraud experts (other than the CF Champion) are drawn upon.

f) Grant recipients are encouraged to actively identify and manage fraud risks.

g) The department undertakes a range of data analytics, and activities are undertaken to identify instances of fraud.

Best

Criteria denoting best performance

a) The organisation is seen as leading on counter fraud activity and engages in work to improve capability in other departments.

b) All the department’s fraud experts are part of the Government Counter Fraud Profession.

1. Metric 5.3 Assurance

Summary: this relates to the extent to which the organisation obtains ongoing assurance that its grants administration is in accordance with the rules of the organisation and is compliant with the Functional Standard for grants (GovS: 015), and the associated process minimum requirements.

Good

Criteria denoting good performance

a) Organisations have mapped out their two lines of defence using the GGMF template, and have in place, effective controls in many of the areas. Assurances obtained from the third line, e.g. Internal Audit, are also mapped out.

b) The Board and Audit Committee periodically discuss the control framework related to grants, and perceived risks and issues, and discuss key assurance reports (these are appropriate where grants’ activity is significant).

c) The organisation considers taking appropriate assurances from other assurance providers.

d) The organisation has regular internal audits on high value and high risk grants.

e) The requirement for the grant recipient to seek proportionate assurance from independent auditors is clearly set-out in the terms of the Grant Agreement.

Better

Criteria denoting better performance

a) A programme of audits focused on risk areas is undertaken by the third line, e.g. Internal Audit.

b) There is a testing regime to assess the effectiveness of the organisation’s grant controls.

c) IT systems are used in the automated testing of the effectiveness of grant controls.

d) The organisation references the results of this self-assessment in its end of year governance statement, and in the annual Accounting Officer System Statement (AOSS).

e) The organisation seeks additional assurances from grant recipients that it has effective controls over high risk areas such as Safeguarding, Protection of Personal Information, Health and Safety, etc.

Best

Criteria denoting best performance

a) There is a systematic approach to ensure that the Third line, provides assurance in grant risk areas.

3.5 Theme 6 Digital and Management Information

2. Metric 6.1 Accuracy and completeness of grants data

This area focused on the accuracy and completeness of the data loaded onto the Government Grant Information System (GGIS). It is important that data is accurate and complete, because it provides important management information, and it is also released externally for public visibility as part of the Government’s transparency commitment in the UK Open Government, National Action Plan.

Good

Criteria denoting good performance

a) Accurate and complete general, formula and grant in aid scheme data are held on the GGIS, at the appropriate level, scheme and award, for each completed financial year.

b) 100% accurate general award data for departments and ALBs is held on the GGIS.

c) Accurate and complete general grants award data for previous financial year are uploaded to the GGIS in line with the deadlines set out in the Memorandum of Understanding (MoU), which governs the GGIS data capture process.

d) The data has been internally reviewed to ensure accuracy and efficacy.

e) All data entered onto the GGIS is complete and accurate.

f) Departments confirm that Grant recipient information such as addresses and company identifiers are accurate and complete.

Better

Criteria denoting better performance

a) All departmental ALB formula grant award data are loaded onto the GGIS.

b) Business units have the capability and access to enable them to enter data directly onto the GGIS.

c) The risk rating of the grant, required by the GGIS, is revisited during the life of the grant and re-assessed as required.

d) Non-mandatory monitoring information is maintained on the GGIS.

e) Budgeted spend, and actual grant spend at year end, is input to the GGIS in line with the MoU.

f) The department has a resource plan to meet the GGIS annual upload requirements, as outlined in the MoU.

Best

Criteria denoting best performance

a) Grants information is uploaded at the design stage and updated regularly as the scheme progresses.

b) The department ensures differentiation between grant recipients and beneficiaries on the GGIS.

3. Metric 6.2 Reporting and utilising grants data

Effective production of management reports using accurate and complete data is important to support effective decision making and good financial management.

Good

Criteria denoting good performance

a) Grants data are used to produce useful management information for decision making.

b) Existing grants information is used to inform new grant making.

c) Existing grants information is used to support due diligence and counter fraud assessments.

d) For those departments using Spotlight to run due diligence checks, the system is updated at the appropriate time, to denote that the grant has been issued to the recipient.

Better

Criteria denoting better performance

a) The department communicates grants information available on the GGIS and other grants systems widely, to support management review and decision making.

b) Grants information is used to support responses to external queries or Parliamentary questions.

c) Basic analysis is undertaken such as trend analysis, sectoral analysis, regional, etc.

d) Specialist analysts are routinely involved in using GGIS data for research.

e) Clear and useful dashboards and management reports are produced from GGIS data, to inform users.

f) Lessons learnt activity is undertaken on the process to upload data to the GGIS.

Best

Criteria denoting best performance

a) There is an overall, preferably annual assessment and report on the outcomes and value achieved from the organisation’s grant expenditure, and how successful grant schemes were in supporting departmental policy objectives.

3.6 Theme 7 Grant in Aid and Arm’s Length Bodies

4. Metric 7.1 GIA Governance

This relates to Grant in Aid governance arrangements for funding issued by departments to their Arm’s Length Bodies to be issued as general grants. For example, framework documents which define the governance arrangements between the department and ALB should contain appropriate reference to funding provided for general grants.

Good

Criteria denoting good performance

a) The framework document for the ALB clearly outlines the funding provided for expenditure on general grants, and provides reasonable detail on the control framework, including conformance to the Grants Functional Standard and associated processes, including data capture and reporting, which the department requires of the ALB.

b) The department has created a process for significant grant risks to be escalated from the ALB to the department for review.

Better

Criteria denoting better performance

a) The department provides functional support to its ALBs, such as through an advice and guidance forum.

Best

Criteria denoting best performance

• No criteria have been identified

1. Metric 7.2 GIA Management information reporting

Information related to grants awarded by ALBs needs to be complete and accurate and loaded onto GGIS to ensure the government has a picture of all grants provided. Departments should have visibility of the grant information loaded on by its ALBs.

Good

Criteria denoting good performance

a) All ALB exchequer funded grants data are loaded on the GGIS, either directly by the ALB, or by the department on its behalf, as per the requirements as follows:

b) Accurate and complete general, formula and grant in aid scheme data is held on GGIS for the completed financial year, in line with the MoU.

c) 100% accurate general award data for departments and ALBs is held on the GGIS.

d) Accurate and complete general grants award data are uploaded to the GGIS in line with the deadlines set out in the Memorandum of Understanding (MoU), which governs the GGIS data capture process.

e) The data have been internally reviewed to ensure accuracy and efficacy.

f) All GGIS mandatory fields are fully completed and accurate.

Better

Criteria denoting better performance

a) ALBs are provided with access to the GGIS, to enable them to upload data directly to the system.

Best

Criteria denoting best performance

• No criteria have been identified

b. References

ID	Description
1	HM Government, GovS015: Grants
2	Cabinet Office, Functional standards and associated guidance (collection)

c. Glossery

Term	Definition
accounting officer system statement (AOSS)	The accounting officer system statement is to provide to Parliament a single statement setting out all of the accountability relationships and processes within a department, making clear who is accountable for what, from the principal accounting officer down.
assessment criteria	Each metric is supported by a number of criteria. Criteria help to define what is happening in an organisation (observable in practice, backed up by documentary evidence). The Criteria denote the requirements of good, better or best performance
functional standard	Functional standards are government standards designed to provide a coherent, effective and mutually understood way of doing business across organisational boundaries, and a stable basis for assurance, risk management and capability improvement.
governance and management framework	A governance and management framework sets out the authority limits, decision making roles and rules, degrees of autonomy, assurance needs, reporting structure, accountabilities and roles, together with the appropriate management practices and associated documentation needed to meet this standard.
Government Grant Information System (GGIS)	Holds data on schemes, awards and grants in aid across government. It aims to do this by providing a consistent view of grants data fields, ensuring data can be compared and aggregated across departments. departments and arms length bodies are responsible for the input of data.
Grant in Aid (GiA)	Grant-in-aid provides general support, usually for an Arms length Body, with fewer specific, but more general controls on the body, which may mean less oversight by the funder; for example, to fund running costs
local	In the context of assessment frameworks, ‘local’ denotes local to a business unit or team within the organisation. Typically used to describe locally defined methods and processes.
metric	Each metric has an overall statement about what is expected. A metric might relate to one or more clauses in the Functional Standard.
organisation	In the context of government functional standards, ‘organisation’ is the generic term used to describe a government department, arm’s length body, or any other entity, which is identified as being within the scope of the functional standard.
post award assurance exercise	is undertaken to establish the effectiveness of the grant, and the potential fraud and error that may have occurred. The organisation should use the FRA created during the design stage (and periodically updated throughout the delivery period) to check for instances of fraud and should review a sample of awards, in light of the top risks, to see if any instances of fraud can be identified.
theme	A theme is the overall topic being addressed in that section of the assessment framework. The context and more information about the themes addressed can be found in the Functional Standard.