Defend the Spend Recipient Guide

Defend the Spend Recipient Guide

Captain Tala Hooban: Hi everyone. My name is Tala Hooban. I'm the acting director for the Office of Head Start. Thank you for joining us on this webinar. I'm pleased that you're able to take some time out of your busy schedule to learn more about the implementation of Executive Order 14222. Implementing the President's Department of Government Efficiency, cost efficiency initiative.

Which has also been referred to as Defend the Spend. This new process has been created to enhance transparency and accountability for federal funding. Today, our very own Nekeya O'Connor, the Office of Head Start’s, fiscal specialist, will walk through the requirements of this initiative. 

She and other OHS colleagues have worked hard over the past few weeks to make sure that we have the understanding and tools in place to help our grant recipient community be compliant with the new requirements. As always, I appreciate the Head Start community's resilience to meet new expectations. Without further ado, I will turn it over to Nekeya to provide you with the important information you want and need about Defend the Spend.

Nekeya O'Connor: Thanks Tala. Welcome everyone to the Office of Head Start's Payment Justification recipient Guide. The purpose of this webinar is to provide a complete guide for recipients to properly submit their drawdown requests with your payment justifications as required, and to learn how to adequately defend your spend.

Let's get started. In today's session, we're going to cover some key information that we believe will assist you in properly defending your spend. First, we will discuss the defendant spend notification that each program should be aware of. We will then discuss the Administration for Children and Families approach to the payment justification requirement from the administration's executive order.

Then finally, we will provide you five key tips to properly submit the payment justification and review the highlights from our discussion today. The Office of Head Start led by the Administration for Children and Families is taking an intentional approach to ensuring that our recipients are ready and prepared to answer any questions regarding their request for funds.

Our hope is that our programs, while they are continuing to provide high quality child and family outcomes, are able to continue to be as transparent and clear around how federal funds are being properly allocated and used to conduct essential services of the program. On April 22nd, 2025, through HSCS, the Administration for Children and Families released an announcement to all recipients regarding the agency's efforts to comply with Executive Order 14222, implementing the President's Department of Government Efficiency, cost efficiency initiative. 

In the announcement, it was shared that the payment management system, which was also known as PMS and used by recipients to request a drawdown of their awarded funds will be implementing a new mandatory field at the sub-account level. This new mandatory field requests a payment justification explaining the purpose of the requested funds. To support this request the Administration for Children and Families has asked that all requests for federal funding specifically outline the purpose and the use of the funds as they will now be made public in an effort to promote transparency and accountability. 

To receive an approval of your payment requests, recipients will be required to summarize the use of the funds in alignment with their approved funding requests. If these approved activities or the use of the funds should be related to what has already been awarded through your baseline application, your continuation application, or any amendment request that has been approved, amendment requests may come in the form of a budget revision, a one-time supplement or a carryover.

Recipients are to provide short summaries outlining the purpose of the funds and include details for each cost category as provided on your notice of award. Just as a quick, gentle reminder, your notice of award is released in grant solutions to your assigned point of contact. One thing to note is that any failure to provide proper descriptions with your payment request may result in significant approval delays. 

In order to avoid these delays, we have five tips that we believe will help you to be successful in meeting the payment justification requirement and minimize the delays in approval. The five tips that we're going to cover include proper time management, which means that you want to plan accordingly.

How to simplify your draw request. Being clear, removing any personally identifiable information and being ready to defend your spend. Let's hop into the first tip. Tip number one, plan accordingly. Recipients will need to plan for when their funding is needed in order to complete the approved activities that are also allowable.

This includes activities such as your payroll, your supply purchases, and your facilities projects, just to name a few. Every recipient should already have a process for how they conduct their payroll and meet the timeliness of paying their bills. As such, it is imperative that each program allows for extra time between when payments are due and when the payment is requested.

To do this, this is gonna mean you're gonna have to talk to each other. We encourage you between your programs and your fiscal offices to work together in understanding the payment deadlines and the plan for the timeliness of meeting those obligations. We also want you to keep in mind that if the program is not on an ACF directed or a self-directed cost reimbursement.

Meaning that you have expensed the activity and paid for it prior to requesting your drawdown. Don't forget the 72-hour rule. Federal funds should be dispersed within 72 hours of the deposit into your account, and they should not be collecting interest. Tip number two would be to keep it simple. There is no need for you to complicate or overcomplicate if you don't have to.

Whenever possible, only include one awarding agency in your request. We know that many of our programs receive funding from other sources that may also pay out of the payment management system. Try to group your Head Start payments within the same Head Start award together and leave the others to a separate request.

Do the best that you can to not mix and match your rewards. As this may lead to further delay, our next tip is to be clear, be clear, and as concise as possible. No need to fluff. No need to overexplain. Just be honest and transparent. When you submit your justification, be sure to include the cost categories, their respective amounts, the time period for the activity, and a summary of what the request is for. 

If you have not requested a drawdown at this point, consider this a treat. Here is a preview of the payment request screen where the programs submit the draw of their awarded funds request. As you can see in the red box to the right, this is the place where the payment justification will be identified and placed.

You will not be able to submit your payment request without completing this box. Here is an example of an approvable payment justification. As you can see, the recipient has summarized that this request is for reimbursement of the Head Start and Early Head Start expenses. They have provided a clear breakdown of the request by amount and a cost category.

They have included a timeline for when the activities have occurred because of their clear, concise, and transparent justification. This payment was approved, and funds were delivered to the recipient's account.

The next tip, and this one is really important. Under no circumstances, please do not include any personally identifiable information in your payment justification. Always remember that your payment justification should be limited to the activity or high level to the organization. It should not identify a person's name, address, or any other information that would be inappropriate.

Our last and final tip is to be ready. Be ready to defend the spend justification that you have submitted with your drawdown request. We're all human. We understand that time may get away from us and we, so we try to do things in a rush, and it may be that you submit your request because maybe something like payroll or a payment is due, and it is to be released in a few days, and you don't want to miss the window.

I get it. We all get it. Things happen. However, it is possible that while your intentions are very good, you may receive a request for payment clarification. Don't be alarmed, don't be afraid. Just give us a little bit more. Be ready. Be prepared to update or respond to any questions that may come as a result of your submission.

Be ready to share the good of what your program does on a daily basis and how it ties to the request that you've made. Do everything you can to respond as quickly as possible, as to not pose any further delays in the review process. Yes, for those of you who have received a notification, the defendthespend@hhs.gov is a legitimate email from the department.

If you receive a notification, please respond as soon as possible. Just as we showed you an approvable payment justification request, we also wanna show you an example of what that was returned for Additional information. As you can see on the screen, the only justification with that provided was the term payroll.

This unfortunately is considered insufficient. As such, the recipient received the above payment clarification request to ask for more information about the purpose of the funds.

As a quick and gentle reminder due to this newly enacted payment justification review, the processing time of your drawdown request may vary.  Back to sharing tip number one, please plan accordingly. As a recap, we want to remind you that all drawdown requests submitted through the payment management system will require proper justification.

Your payment justifications are short summaries of how the funds are going to be used, and they should only be used for approved activities for the Head Start award. Recipients should be diligent in your planning for the timing of the request submission in order to meet your financial obligations. Do everything you can to not include any PII and be sure to simplify the request when possible.

Make sure that you do everything you can to reduce the potential of any approval delays. Requires you to do proper submission. If you have any questions about the payment justification process itself, please send an email to the defendthespend@hhs.gov. If you have any other questions or updates about the award itself, as in the process to submit a pay a budget, justification or understanding allowable costs, please connect with your regional office.

Thank you for joining us today. We invite you to stay connected with us. Visit hhs.gov for all of your program, service, fiscal, and facility’s needs. If you need additional support, please reach out to your regional office and also visit HeadStart.gov on behalf of the Office of Head Start. We thank you for listening and your willingness to support our efforts to remain as transparent as possible.

Our goal is to be able to demonstrate proper stewardship of the federal funds, and we can only do that with your help. As Tala shared, the work you do is imperative and we are here to support you as you continue to provide high quality child and family services. Thank you again and be well.