Subgrantee Compliance February 27, 2013 Preparing TPPS Subgrantees for Monitoring Shelby County Grants Office presents:

Welcome Sandy Rutherford, Grants Compliance Officer Shelby County Government phone Role of the County’s Grants Compliance Officer SCGO works with Shelby County Grant Staff to insure that terms and conditions of the grant are met Subgrantee (TPPS partners) responsibilities

Why Does Shelby County Government Monitor its Subgrantees? It is required OMB Circular A-133 requires that pass-through entities monitor the activities of subrecipients as necessary to ensure that grant awards are used for authorized purposes in compliance with laws, regulations and the provisions of the grant agreements, and that performance goals are achieved. Monitoring scrutinizes two areas: compliance and performance, and requires four steps: 1) collecting information, 2) analyzing information, 3) taking appropriate action and 4) documenting findings with a corrective action request.

Evaluation of Subgrantees Evaluation Financial & Performance Reports Audit Random or Scheduled  Desk review  Inquiries into any facet of the project  Site visit  Open communication through telephone calls, or letters Observations, Recommendations or Findings Discuss with subgrantee Document in writing Corrective Action Plan will be requested from the subgrantee if findings occur

The Subgrantee’s TPPS Grant File Every subgrantee should have a grant file on-hand labeled (your agency name) TPPS Project that includes the following: Governing Rules - Grantor Agreement, Subgrantee Agreement with SCG, CFDA or statute authorizing the grant program, Applicable OMB Circulars (Administrative Requirements, Cost Principles and Audits), Code of Federal Regulations, Executive Orders  Subgrantee’s Agreement with Shelby County Government  Subgrantee’s Approved Project Budget with Shelby County Government Invoices and Back-up Documentation Grant Reports (financial, programmatic/performance, quarterly, semi-annual, close-out) Policies and Procedures

Policies and Procedures Manual Narrative of the Initiative Scope of Services Staff Org Chart Staff Job Descriptions Criteria for Determining Service Eligibility – Step by Step Program/Participant Flow Chart Procurement Policy Equipment Personnel Project Reporting and Tracking Accounting Policies Project Close-Out Procedures Compliance with Non-discrimination and Other Federal Laws Travel Policy Narrative of the Initiative Scope of Services Staff Org Chart Staff Job Descriptions Criteria for Determining Service Eligibility – Step by Step Program/Participant Flow Chart Procurement Policy Equipment Personnel Project Reporting and Tracking Accounting Policies Project Close-Out Procedures Compliance with Non-discrimination and Other Federal Laws Travel Policy

Insure that your Agency and all of its Staff Understand and Comply with Non-Discrimination Laws EEO – Equal Employment Opportunity Title VI – Insure your agency has a poster in place that may be viewed by all grant clients ADA – American Disabilities Act Limited English Proficiency – Obtain interpretive services if a communication barrier exists when serving clients

Internal Controls Questionnaire Due to Gwen Brown, Program Coordinator ASAP if your agency has not already submitted it.

Site Visit Schedule Site visits will take place very soon. Please be prepared for monitoring. Policies and Procedures Manual – Content Scope of Services – Status Financials Accounting System Documents check Project Staff

Any Questions? Shelby County Subgrantee Resource Page x?NID=2261