MONITORING OF SUBGRANTEES

1. MONITORING OF SUBGRANTEES

2. MONITORING OF SUBGRANTEES

3. 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

4. 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

5. Financial Factors Financial Condition Financial Factors Audits Recent Experience Compliance

6. Develop clear subgrant agreements with expectations Develop mutual understanding of staff, participant and sponsor needs 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 Keys for Effective Monitoring

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

8. 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

9. 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

10. 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

11. 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

12. 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

13. Monitoring Strategies Desk Review Monitoring Site Visit Monitoring

14. 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

15. 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

16. 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

17. Site Visit Monitoring • Pre-Visit Preparation • On-Site Visit Review • Post Visit Phase

18. Site Visit Monitoring • Pre-Visit Preparation • 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)

19. 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

20. 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

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

22. 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

23. 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

24. 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

25. 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

26. 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

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