A Division of Thompson Publishing Group Subrecipient Monitoring: Federal Policies and Sensible Practices Audio Conference, November 28, 2006 Presented by: Robert M. Lloyd Consultant on Public Management and Government Relations Telephone: (202) (864)

1 Do You Have Monitoring “Angst”  To avoid it, let’s review the actual federal requirements

2 A Working Definition of Subrecipient Monitoring  Continuous collection of relevant information about a subrecipient organization and its performance

3 OMB’s Compliance Supplement For A-133 Audits  Subrecipient Monitoring - 1 of 14 areas for compliance testing – What the supplement says about the real requirements – What it doesn’t say – Part 6 - On internal control – How do you get into trouble here?

4 Start Fresh and Organize the Process  “Step Back” Phase  Pre-Award Phase  Post-Award Phase  After-The-Subgrant Phase

5 “Step-Back” Phase  Agreement Review – Subrecipient v. Vendor? – Federal fund identification – Federal requirement identification – Shed excess weight – Organize the document – Provide citations

6 “Step-Back” Phase (cont.)  Submission Requirements for Applications – Create a useful file – Ask relevant questions  Checklist Review – Build in flexibility for the awarding agency? – Are there other ways to gather information? – Connect to the subgrant agreement

7 Pre-Award Techniques  Assess the Applicant Organization – Responsibility – Financial stability – Systems – Prior award activity  Assess the Program or Project – What’s “monitorable” – Performance indicators

8 Pre-Award Techniques (cont.)  Tailor the Agreement – Special “high risk” conditions – One size need not fit all  Organize Your Subgrant “Universe” – Size of your award – Size of the federal award portfolio – Extent of your past experience

9 Post-Award Techniques  “Kick-Off” so they can catch the ball  Use A-133 audits (obtain, review, follow-up)  Use limited scope audits (A-133, ___.230(b))  Review financial and performance reports  Document routine contacts

10 Post-Award Techniques (cont.)  Obtain and use third party information  Follow-up on significant developments  Conduct meaningful site visits  Provide feedback and technical assistance  Document, document, document

11 Dealing With Your Auditors  Look at their audit program  Understand their field work on subrecipient monitoring  What if there are findings?

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A Division of Thompson Publishing Group This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney-client relationship with the presenter(s). You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances.