Who’s Minding the Store ? The Adventures of Subrecipient Monitoring

Powering Up… 24 CFR (b) and Subpart J 24 CFR Part 85 states that: “the grantee is responsible for ensuring that CDBG funds are used in accordance with all program requirements. The use of subrecipients does not relieve you the recipient of this responsibility. The recipient is responsible for determining the adequacy of performance under subrecipient agreements… and for taking appropriate action when performance problems arise. Supart J 24 CFR Part 85 further details: “Grantees must monitor…subgrant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved.”

Using GPS... IMPORTANT: Keep track of your subrecipients’ activities and help them avoid problems and improve performance.  3 Focus Areas: Program performance Financial performance Regulatory performance

Mission Possible… ENSURE THAT SUBRECIPIENTS: Comply with all regulations governing administrative, financial, and programmatic operations; and Achieve performance objectives on schedule and within budget.

“ We look forward to monitoring visits because we know they’re not out to get us, and we usually wind up solving a problem.” Relationship Climate…

Common Misconceptions…  Catch you making a mistake on purpose!  AHAAA Gotcha!  Nail you with blame!  To take your money back!

Usual Suspects… 3 EFFECTIVE STRATEGIES: On-site field visits; Open communication; Assisting subrecipients in creating good record-keeping systems.

Monitoring Objectives… DETERMINE IF THE SUBRECIPIENT: Is in compliance with federal requirements 24 CFR (b); Is carrying out activities according to their agreement; Is expending funds in a timely manner; Is ensuring the costs are eligible expenses; Has adequate control over program and financial performance; and Has capacity to carry out project.

Objectives…continued HOW CAN WE: Identify any potential problem areas; Assist with applicable laws; Help to resolve compliance issues; Provide adequate follow-up measures; and Ensure required records are maintained.

Helpful tips… THE DO’S & DONT’S OF MONITORING: DO…develop an on-going monitoring process of planning, implementation, communication, and follow-up. XDON’T… have a “one-time event” policy. DO…create a method to decide which subreicipients are the highest risk for serious problems. XDON’T… ignore subrecipients you think won’t have serious problems. Problems are found even with the most experienced subrecipients. DO… create a monitoring checklist to promote thoroughness and consistency. XDON’T… use the same checklist for all activity areas. DO… research, print, and study the monitoring exhibits provided by HUD or your Grantee. XDON’T… digress from the tools that have been provided by HUD or your Grantee.

Tips…continued DO…set up standing meetings with staff. XDON’T…try to be a “superhero” and brave this alone. DO…research historical data and pull old program files. ХDON’T…be too proud to ask for guidance from peers or even a predecessor. DO… start your day with a great breakfast and cup of coffee. XDON’T… consume an adult beverage to loosen your nerves (even if it is 5 o’clock somewhere)!

Information System…  Commitment drives the system…assures that everyone using it follows the established procedures.

Systems…continued  Purpose – help subrecipients attain program goals and observe program rules.  People – systems are only as good as the training and motivation of those who use them.  Process – knowing what, when, how, and who will measure the information; What is the purpose and the end user of the information.

Most Importantly… Monitoring is a healthy tool and not a means of intimidating Subrecipients! Win-Win Scenario Reference from today’s presentation: Managing CDBG A Guidebook for Grantees on Subrecipient Oversight