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INDIANA HPRP Training. Module 8 Monitoring. Role of Independent Financial Monitors. IHCDA is retaining an independent accounting firm to monitor its sub recipients under the HPRP. They will be conducting on-site monitoring of program documentation and procedures.
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INDIANA HPRP Training Module 8 Monitoring
Role of Independent Financial Monitors • IHCDA is retaining an independent accounting firm to monitor its sub recipients under the HPRP. They will be conducting on-site monitoring of program documentation and procedures. • IHCDA will allocate specific accounting staff for the HPRP, who will be in direct contact with each sub recipient about procedures and required documentation.
Monitoring of Sub-Recipients • HUD requires that grantees (State of Indiana) engage in remote and onsite monitoring of sub-recipients • Factors to examine include: • Adequate financial management systems • Appropriate qualifications required for staff and auditors • Adequate time distribution records if employees are on multiple grants • Appropriate policies and procedures to prevent conflicts of interest • Retain records for a period of at least 4 years
Monitoring of Sub-Recipients (2) • Additional monitoring factors: • Adequate systems to track sub-recipient property • A-133 Audits completed for all sub-recipients receiving $500,000 or more in federal funds • Audits reviewed by grantee • Grantee uses appropriate risk assessment process to select sub-grantees for on-site monitoring • Use of program income for program related purposes only • If funds are provided by advances: • Ensure that funds provided are not in excess of immediate needs • Funds are timely disbursed by sub-recipient • Funds used solely for eligible program purposes • Monitoring results communicated on a timely basis to sub-recipients
Monitoring of Financial Management • Budget established and tracked by eligible activity • Adequate source documentation maintained for expenditures (invoices, contracts, purchase orders, etc.) • Organization chart showing actual lines of responsibility • Segregation of duties to reduce opportunities for someone to perpetrate or conceal errors or irregularities • Internal controls adequate to prepare financial statements that are fairly presented and in compliance with GAAP • Draw downs match official accounting records of sub-recipients
Monitoring of Financial Management (2) • Sub-recipient’s audits confirm adequacy of internal accounting and control systems • audit costs are allowable as administrative fee
Common Monitoring Findings • Lack of internal controls • Staffing or financial assistance expenditures not supported by documentation • Reported and charged costs do not agree with financial records • Staffing costs not supported by time sheets
Remote Monitoring Includes: • Timely and accurate invoices • Adequate documentation to back-up invoices • Pace of spending is within expectations • Billing matches approved activities • Billing matches progress reports • Timely and accurate performance and outcome reporting • Audit reports received from sponsor and reviewed by grantee
On-Site Monitoring Includes • Set financial management monitoring priorities, based on prior or current concerns, audit findings, etc. • Verify that adequate financial policies & procedures in place • Verify that internal cash controls are in place • Verify adequate tracking of grant and activity-level spending • Check for timesheet-type documentation for all personnel costs, inc. administrative staff
Adequate Documentation for HPRP Expenditures • Beneficiary is eligible to receive HPRP assistance • Income • Homeless • At risk of homelessness • Personnel costs are supported by documentation of staff activity • Assistance provided to program beneficiaries meets program requirements • Time limits • Rent reasonableness • Units meet HQS and Lead Based Paint requirements • All payments have been made to 3rd parties
Procurement and Property Controls • Written procurement policies • Prevent conflicts of interest • Allow for open, competitive procurements • Property controls • Inventoried at least every other year • Equipment description • Serial number, model number, and/or other identification numbers • Source of equipment including award number • Acquisition date and cost • Location and condition of equipment and date information reported • Unit acquisition cost
IHCDA Requirements • HPRP funds be deposited in a separate bank account into which IHCDA may deposit. • Financial controls including segregation of duties, dual check signatures and use of a recognized computerized accounting system must be in place