Shelter plus Care Monitoring

1. Shelter plus CareMonitoring

2. Risk Analysis So how do we choose who gets monitored? • HQ gives each Field Office a monitoring goal they must meet. • Each year HUD reviews all of its grantees and scores them on certain risk factors to determine who will be monitored in that year.

3. Risk Analysis Factors that are reviewed 1.) Financial 2.) Physical 3.) Management 4.) Satisfaction 5.) Services

4. Monitoring Work Plan • Field Office creates a Work Plan based on the Risk Analysis • Monitoring reviews are tentatively scheduled for the year • Most reviews are done on-site, however sometimes remote reviews are conducted.

5. Monitoring Exhibits • The HUD monitoring manual includes six possible checklists that can be used to review S+C grants. • Project Progress • S+C Housing • S+C Clients • S+C Match Documentation • S+C Subrecipient Management • S+C Overall Grant Management

6. Other Federal Requirements • Lead Based Paint • Visual assessments • Lead Pamphlet • Civil Rights/Fair Housing • Affirmative marketing • Collection of demographic data • Accessibility

7. File Sampling • Normally, HUD staff will • Request a list of all participants from a certain time period • Select a sample of files from that list to review • However, HUD can expand the file sample if needed.

8. Staff Interviews • In addition to file reviews, HUD staff will also likely interview staff to discuss the program. • Each program is different but common staff interviewed include: • Executive Director • Program Director • Housing Specialist • Financial Officer/Accountant • Case Manager

9. Areas of emphasis • Client eligibility and Service provision • Unit Inspection and Rent Calculation • Draw Review • Program Administration and Due Process

10. Client Eligibility and Services • Eligibility • Homeless documentation • Disability documentation • Services • Appropriate • Ongoing needs assessment • Adequate match amount provided

11. Unit Inspection and Rent Calculation • Unit Inspection • HQS inspection done • Rental Calculation and documentation Contract Rent - Tenant Contribution = S+C Subsidy • Contract rent is based on rent reasonableness • Tenant contribution is based on income

12. Draw reviews • Sometimes HUD staff will select a few draws from LOCCS for review • We would be looking for • Adequate source documentation for the draw amount • Sound overall financial management

13. Program Administration • Written procedures or program guidelines • Including participant termination due process policies • Grantee-Sponsor communication and division of duties • Administration costs and documentation

14. After the visit • Exit Conference • Discuss the results of the review and likely outcome • Monitoring Letter • HUD has 45 days after the exit conference to send out a letter that details the results of the review and any findings and correction actions • Monitoring Response • Normally HUD requests a response to the monitoring letter within 30 days (if there are findings to resolve)

15. Findings vs Concerns • Finding • Deficiency based on a statutory, regulatory or program requirement for which sanctions or other corrective actions are authorized. Grantee MUST respond to findings. • Concern • Potential deficiency or performance issue that could lead to future finding. Sanctions or corrective actions are not authorized for concerns.

16. Common Monitoring Findings • Homelessness Documentation • Rent Calculation • Service Match documentation • HQS Standards • Homeless/formerly homeless participation on Board