MONITORING OF SUBGRANTEES

MONITORING OF SUBGRANTEES

Session Objectives To understand key principles for effective monitoring and financial systems To understand how risk assessment helps determine appropriate monitoring strategy To review process and details of desk review and site visit monitoring

Assessing Risk for Subgrantees Complete risk assessment prior to awarding a new sub-grant Continuously consider changes in risk throughout the award period Address risk assessment FACTORS related to: 1. Grant Award 2. Organization 3. Financial and Compliance 4. Program Performance

Financial Factors Financial Factors Financial Condition Recent Audits Experience Compliance

Keys for Effective Monitoring Key Principles Develop clear subgrant agreements with expectations Develop mutual understanding of staff, participant and sponsor needs Keys for Effective Monitoring ___________________________________________________________________________ Invest time to train new sub-grantees Develop consistent expected level of accountability and required reporting Establish standards and requirements for reports , deadlines, and due dates

Key Principles (Continued) Communicate via onsite or telephone meetings Consistently and continually distribute & train on policy guidance, regulations Keys for Effective Monitoring ___________________________________________________________________________ Communicate monitoring expectations and level Encourage sharing best practices for effective management

Keys for Effective Financial Management Written accounting practices, policies, procedures Sufficient internal controls Clear audit trail from Accounting System to financial reports (FSR) Documented cost allocation plan Clear source documentation and retention policies Adequate time reporting dcontrols ___________________________________________________________________________

Keys for Effective Financial Management 2. Written Policies & Procedures 10. Internal Controls 1. Regulatory Requirements 3. Documentation of Expenses EFFECTIVE FINANCIAL MANAGEMENT 9. Reporting 8. Matching Requirements & In-kind Contribution 4. Managing Cash 5. Efficient Accounting System 7. Time & Activity Documentation 6. Budget Controls

Risk Based Approach to Monitoring Use a risk based approach to determine: each new or existing subgrantee’s risk level best methods to help mitigate risk for each subgrantee: - training - technical assistance - monitoring strategies most appropriate monitoring and oversight strategies for each subgrantee Consider the most effective and efficient use of your resources

Tools and Resources Financial management survey or questionnaire Audited financial statements Risk assessment results Monitoring policy Reports and Files Desk review checklists On-site monitoring tool or instrument ___________________________________________________________________________

Monitoring Feedback & Follow-Up Essential elements when monitoring sub-grantees: Identify and communicate issues, problems, deficiencies in writing Require corrective action plan and time schedule Ensure complete and thorough follow-up Require sub-grantees to report on actions taken Review sub-grantee documents, files, etc. to ensure required actions were taken ___________________________________________________________________________

Monitoring Strategies Desk Review Monitoring Site Visit Monitoring ___________________________________________________________________________

Desk Monitoring - In House Review of: Financial Status Reports (FSRs) for sub-grantees Documents to support reimbursement requests PER (Periodic Expense Report for AmeriCorps State) or grantee forms Special information requests: Policies & procedures, e.g. grievance procedures Supporting documentation for specific expenses or match Other Reports, E-Mails, Correspondence, Files ___________________________________________________________________________

Desk Monitoring – Document Review Review Documents for: Accuracy Timeliness Expected content and format and meeting requirements Other relevant issues Identification of follow-up monitoring needed Use checklists or other ways to document reviews ___________________________________________________________________________

Desk Monitoring – A-133 Audit Reports Develop and track schedule of subgrantee audit due dates Collect and review when completed Assess subgrantee’s financial position Review management letter Identify findings and issues Coordinate corrective action plan for CNCS programs and organizational findings (if applicable) Ensure all relevant findings addressed ___________________________________________________________________________

Site Visit Monitoring On-Site Visit Review Post Visit Phase Pre-Visit Preparation On-Site Visit Review Post Visit Phase ___________________________________________________________________________

Site Visit Monitoring Pre-Visit Preparation Visitation date(s) Coordinate with both sub-grantee fiscal officer and program director and others as appropriate Notify subgrantee in writing of: Visitation date(s) Purpose of review Necessary information you will need (include monitoring tool or instruments you will use) ___________________________________________________________________________

Site Visit Monitoring Pre-Visit Preparation (continued) Review materials in grant file: Sub-grantee program proposal Progress and financial reports Approved budgets Examine documents and information from desk reviews: e.g. financial reports, payment requests, audits, etc. Develop and distribute site visit agenda ___________________________________________________________________________

Site Visit Monitoring On-Site Review Conduct entrance meeting with sub-grantee program director, fiscal officer, and other appropriate officials Meet with administrative, fiscal and other staff. Review appropriate documents, information and materials (use various monitoring tools and checklists) Conduct exit meeting and discuss findings with program director, fiscal officer and other officials as appropriate ___________________________________________________________________________

Site Visit Review Items - Examples Review management policies & procedures in these areas: Time and attendance records for staff & members/participants Member/participant eligibility Travel Record Retention Personnel and Staffing Documentation, tracking of program match Procurement Financial accounting system ___________________________________________________________________________

Site Visit Review Items – Examples On-Site Monitoring Description of financial management system/software Organization’s accounting manual Chart of accounts Samples of source documents and expenditure transactions Samples of cash and in-kind match source documents Other policies, procedures, documents, etc. as needed or appropriate Completion of any Surveys, Self Assessment Tools, etc. Organizational Charts Financial Management Policies and Procedures Latest audits, 990 Position descriptions of key staff ___________________________________________________________________________

Site Visit Review Items - Examples On-Site Monitoring Key Areas to Review on a Site Visit Latest FSR and PER amounts (expenses and match) reconcile and track back to financial accounting system Staff time sheets or after the fact time records are signed and comply with applicable OMB cost principles Circular Source documents (sample 3-5 for expenses and for match) see how they are coded, entered, recorded and reported in the financial accounting system ___________________________________________________________________________

Site Visit Review Items - Examples On-Site Monitoring Key Areas to Review on a Site Visit – (continued) Member Files (sample 3 or more) contain appropriate eligibility documentation, criminal background checks, etc. Member time sheets (sample 3 or more) are signed by member and supervisor and these times are identical with those entered in WBRS Internal controls appear adequate ___________________________________________________________________________

Site Visit Monitoring Post Visit Phase Prepare report describing findings and recommendations Distribute to sub-grantee program director and other officials as appropriate Request corrective action plan, with due dates if needed Review and approve corrective action plan and dates Provide training and technical assistance, as requested or appropriate ___________________________________________________________________________

Site Visit Monitoring Post Visit Phase Follow-up on items in corrective action plan ensuring organization has taken required action Consider appropriate sanctions if the organization fails to implement corrective actions Ensure that site visit documentation, findings and report are maintained in appropriate files ___________________________________________________________________________

“Vox audita perit¸ litteras scripta manet: The spoken word vanishes¸ the written word remains” - Latin Phrases