1. U.S. Department of Housing and Urban Development

2. Continuum of Care Program Monitoring Mark Sorbo Program Manager, Detroit Field Office Margaret Momon Senior Financial Analyst, Detroit Field Office Building Michigan Communities Conference 05/01/2019

3. Overview Regulations HUD Monitoring Activities
Annual Risk Analysis
Monitoring Visit
eLOCCS Payment Requests
Annual Performance Report (APR)
Other HUD Monitoring
Roles and Responsibilities
Grantee Monitoring Activities
Program Evaluation
Financial Management and Control
Sub-Recipient/Contractor Monitoring
Continuum Lead Agency Monitoring Activities
Continuum Lead Responsibilities
Continuum Member Responsibilities
Monitoring Resources
Questions

4. Regulations

5. Regulations 24 CFR part 578 2 CFR part 200
Continuum of Care Program Interim Rule
2 CFR part 200
Uniform Administrative Requirements, Cost Principles, and Audit Requirements
Applicable for Grants Awarded through FY2015 Program Competition and later
Regulations Contain Requirements on Monitoring for Compliance in Various Program Areas:
Uniform Administrative Requirements
Audit Requirements
Subrecipient Monitoring
Continuum Lead Agency Monitoring
Some additional regulations related to lead-based paint compliance when housing clients in pre-1978 properties

6. HUD Monitoring Activities

7. HUD Monitoring Activities
Timeline of HUD Monitoring Activities
Typical Date Ranges Included
Annual Risk Analysis
November -December
Program Monitoring
April - July
Monitoring Report
June -September
Ongoing Resolution
June - TBD

8. HUD Monitoring Activities
Annual Risk Analysis
Completed every year by CPD Representative
One analysis per organization
Can be for multiple grants/programs
Grantee staff may be asked to provide program documents
Results in overall risk score used internally at HUD-CPD for comparison across programs and grant recipients
Results used as factor in selection of monitoring visits

9. HUD Monitoring Activities
Program Monitoring Overview
Work Plan Development
Monitoring Notification Letter
On-Site or Remote Monitoring
Typically between 2-5 days in length
Usually completed by CPD Representatives and Fiscal Analysts
Coordination prior to monitoring start date

10. HUD Monitoring Activities
Pre-Monitoring Visit Activities
Locate Key Program Documents
Prepare Meeting Space and Location for File Review
Possibly Schedule Client and Community Site Visits (On-Site Visit Only)
Coordinate Program Staff Schedules for Meetings and Interviews
Maintain Contact With HUD Monitoring Staff

11. HUD Monitoring Activities
Monitoring Visit Activities
Entrance Meeting
Staff Involved
Topics Covered
Program Overview
Sample document review
Project File and Documentation Review
Policies and Procedures
Client Eligibility
Financial Management
Annual Audit Review
Client and Community Site Visits (On-Site Visit Only)
Client Interviews
Program Staff Interviews
Daily Debriefings
Exit Meeting

12. HUD Monitoring Activities
Monitoring Exhibits
Selected based on comprehensive knowledge of grant program areas
Risk Analysis, Work Plan Development, Program Knowledge, Client Complaints, Financial History, Required Monitoring Components
Common Exhibits Used in CoC Program Monitoring
29-1: Review of Homeless and At-Risk Determination/Recordkeeping Requirements
29-3: Overall Grant Management
29-4: Subrecipient Grant Management
29-11: Match Requirements
29-12: Financial Management and Cost Allowability
24-2: Lead-Based Paint Compliance
34-1: Financial Management and Audits

13. HUD Monitoring Activities
Monitoring Report
Timeline (60 Day Goal)
Cover Letter
Summary Information
Program Areas Reviewed
Monitoring Results
Finding
Concern
Recommendation
Comment

14. HUD Monitoring Activities
Monitoring Report Follow-Up
Report Response (From Grantee)
Typically Days (see report for specific window)
Resolving Findings
Review Corrective Actions Identified in Report
Coordinate with CPD Staff
Ongoing Process
Timeline and Outcomes Tracked by CPD Staff
Report Updates from HUD
Official Notice of Finding Update or Closure

15. HUD Monitoring Activities
electronic Line Of Credit Control System (eLOCCS) Payment Requests
Required and Periodic Reviews by CPD Staff
Infrequent Requests
Budget Line Item Issues
Requests in Grant Closeout Period
Typically 3-5 Days for Review
Supporting Documentation
eLOCCS Data Reviewed During Monitoring Visits

16. HUD Monitoring Activities
Annual Performance Report (APR) Review
Due by Grantee 90 Days After Grant End Date
Reviewed by CPD Staff
Typically Days for Review
Submitted through SAGE System
HUD Uses the APR to track progress and performance
Information populated from eSNAPS, eLOCCS, and HMIS
APR Data may be used in Risk Analysis and Monitoring Visit

17. HUD Monitoring Activities
HUD Field Office Responsibilities
Complete Annual Risk Analysis
Prepare Monitoring Work Plans
Schedule and Complete Monitoring Visits
Prepare and Issue Monitoring Report
Review eLOCCS Payment Requests
Review Annual Performance Reports
Review Annual Single Audits (if applicable)
Ongoing Monitoring and Evaluation of Grant Recipient
HUD Field Office Staff Roles
CPD Representatives / Fiscal Analysts
Program Managers
Director

18. HUD Monitoring Activities
HUD HQ Responsibilities
Review NOFA Applications and Award Funds
Determine Annual Monitoring Goals and Objectives
Revise Monitoring Exhibits (as needed)
Provide Policy and Technical Assistance to HUD Field Office Staff (as needed)
Program and Organizational Oversight
HUD HQ Roles
HUD Office of Field Management
HUD Office of Special Needs Assistance Programs (HUD-SNAP)
HUD Office of Inspector General (HUD-OIG)

19. Grantee Monitoring Activities

20. Grantee Monitoring Activities
We expect grantees to regularly and thoroughly monitor and evaluate their activities throughout the entire grant period
Policies and Procedures
Program and Staff Activities
Sub-Grantee Activities
Program Costs and Expenses
The proposed approach for this monitoring and the evidence that it is occurring should be documented

21. Grantee Monitoring Activities
Types of Grantee Self-Monitoring Activities
Program Evaluation
Policies and Procedures
Annual Performance Report
Financial Management and Control
Budget Management
2 CFR 200
Annual/Single Audit
Sub-Recipient / Contractor Monitoring
Risk Analysis
Monitoring Plan
Monitoring Results/Reports

22. Grantee Monitoring Activities
Program Evaluation
Policies and Procedures
Must be documented and available for review
Should be reviewed and updated regularly
Typically referenced and involved in HUD Monitoring and Resolution
Should include complaint resolution, client termination, and sub-recipient monitoring policies
Annual Performance Report
Submitted for each CoC Grant and reviewed by CPD Staff
Should be used to measure achievement based on stated objectives

23. Grantee Monitoring Activities
Financial Management and Control
Budget Review and Reconciliation
Financial staff should monitor budget regularly to ensure budget categories are aligned with expected program area costs and in compliance with 2 CFR 200.
Budget revisions should be submitted to HUD in a timely manner
Applicant Match must be tracked and documented
Annual Single Audit
Required for all recipients that expend $750,000 or more in Federal Funding in a fiscal year
Due within 9 Months of end of organization fiscal year
Must be submitted to Federal Clearinghouse
Included in other HUD Monitoring activities

24. Grantee Monitoring Activities
Financial Management and Internal Controls
2 CFR 200: Uniform Administrative Guidance, Cost Principles & Audit Requirements
Subpart A – Acronyms
Subpart B – (Pre- and Post) Financial Management
Subpart C – Procurement Activities
Subpart D: Cost Principles
Subpart E: Audits Requirement

25. Grantee Monitoring Activities
Sub-Recipient and/or Contractor Monitoring
HUD Responsibilities
Primary Grant Recipient (Grantee)
Grantee Responsibilities
Frequency: At Least Annually
Policies: Risk Analysis, Monitoring Plan, Corrective Actions
Key Documents: Procurement, Contracts, Agreements, Financial Records, Audits, HUD Monitoring Exhibits
Reports: Monitoring Results, Quarterly Financial and Performance Summary, Annual Audits (if applicable)

26. Continuum Monitoring Activities

27. Continuum Monitoring Activities
24 CFR Part 578 (CoC Program Interim Rule)
Formalizes the composition and responsibilities of the CoC and establishes minimum requirements for its operation and management.
Establishes seven responsibilities that must be carried out by the CoC. All responsibilities must be thoroughly documented in the CoC’s governance charter.
(5) …develop, follow, and update annually a governance charter, which will include all procedures and policies needed to comply with subpart B of this part and with HMIS requirements as prescribed by HUD…
(6) …monitor recipient and subrecipient performance, evaluate outcomes, and take action against poor performers.
(7) Evaluate outcomes of projects…and report to HUD.
(9) …establish and consistently follow written standards for providing Continuum of Care assistance...

28. Continuum Monitoring Activities
Continuum Lead Responsibilities
Policies and Procedures
Grievance Policy (internal and external)
Flexible Design
Use of Positions or Titles when Possible
To prevent future gaps due to staff turnover
Transparency and Fair Treatment
Documentation Requirements
Coordinated Entry, Complaint/Request Intake, Processing, and Resolution
Communication Protocols
Response Timeliness
Between Continuum Members

29. Continuum Monitoring Activities
Continuum Member Responsibilities
To Clients
Clear line of communication
Appropriate staff responsible for client interactions
Timeliness of response(s)
Protection of personal information
To Continuum
Follow local continuum policies in place
Communicate client needs as required
To HUD
Respond to information requests in timely manner
Provide updates as requested or when issue is resolved

30. Monitoring Resources

31. Monitoring Resources HUD Exchange www.hudexchange.info
CoC Grant Administration Guide:
CoC Program Monitoring:
CPD Monitoring Handbook (6509.2) and Exhibits:
HUD-CPD Detroit Field Office Staff
CPD Representatives
Fiscal Analysts
Program Managers
Director

32. Questions Mark Sorbo 313-234-7334 Margaret Momon 313-234-7331
Margaret Momon