1. Jaimie Lewis Omnitrans San Bernardino, California SUBRECIPIENT MONITORING

2. Omnitrans RESPONSIBILITIES OF THE PASS-THROUGH AGENCY

3.  Pass-through entity is responsible for during- the-award monitoring, through:  Reporting: reviewing subrecipient financial AND performance reports;  Onsite reviews: review programmatic AND financial records and observe operations;  Regular contact; OR  Other means  STANDARD Per FTA: Monitoring efforts must provide a reasonable assurance that a subrecipient administers Federal funds in compliance with laws and regulations and that performance goals are achieved OMB CIRCULAR A-133 COMPLIANCE SUPPLEMENT

4. EXPECTATIONS OF THE PASS-THROUGH “ A pass-through entity shall..[m]onitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved.” OMB Circular A-133__.400(d)(3), issued under the Single Audit Act of 1984, P.L. 98-502, and the Single Audit Act Amendments of 1996, P.L. 104-156.

5.  More than on-site visits  Any action taken by grantee throughout the life of a grant to ensure legal compliance and program performance  Ongoing process WHAT IS MONITORING?

6. Step 1: Pre-Award Assessment, including Grantee Selection Step 2: Subrecipient Agreements Step 3: Orientation, Training, and Technical Assistance Step 4: Systems for Tracking Subrecipient Program Progress Step 5: Monitoring Strategies and Procedures Step 6: Follow-up Procedures MANAGING SUBRECIPIENTS FROM A-Z THE PROCESS…

7. 1.Yearly site visits  Self certification  Review of independent audit  DBE & Title VI Verification  Site Visit Summary. 2.Monthly invoice review  Does the invoice tie to back up documentation?  Is the claim in line with agreement? 3.Meetings when scope changes or just because 4.Triennial Review Preparation (FTA)  Is the project in motion?  Grant balance too high as it relates to year of allocation? 5.Sub-recipient agreement review  Year of allocation plus three HOW DOES OMNITRANS MONITOR ITS SUBRECIPIENTS?

8. As the FTA monitors grantees to determine whether their programs are in compliance, subrecipient management is an actively monitored area in which “findings” are commonly made. AUDIT

9. “Are we doing it right?” WHAT IS EFFECTIVE MONITORING

10. The two major factors for effective subrecipient management are: 1.Establishing a partnership where the agency understands the capacity of the sub recipient to comply with program requirements. 2.Creation of a framework of incentives and penalties.  Example: if the subrecipient submits invoices timely, they are paid sooner. Those who comply are considered for future opportunities. WHAT IS EFFECTIVE SUBRECIPIENT MANAGEMENT?

11. 1.Importance of Committed Leadership 2.Value of Trust and Good Relationships 3.Environmental Supports 4.Incentives for system creation and evolution FACTORS THAT INFLUENCE EFFECTIVE MANAGEMENT OF SUBRECIPIENTS

12. Identify that a grantee: (1)identifies problems and takes action before they become serious; (2)takes action to ensure that projects carried out by subrecipients contribute effectively to community needs and priorities; (3)keeps the program free of serious infractions; and (4)changes the mix of subrecipients in step with the changes in community development needs INDICATORS OF OPTIMAL SUBRECIPIENT MANAGEMENT SYSTEMS:

13. Assess the following:  (1) the subrecipients contribution to effective transportation services; and  (2) their value in safeguarding the public interest in the legal and financial integrity of its programs. IS MY MONITORING METHOD WORKING?

14. SUBRECIPIENT EXPECTATIONS

15. 1.Timely submission of invoices: New pressure from FTA to spend down grants. 2.Subrecipient to bring forward issues or concerns as they present themselves in an effort to collaborate and find solutions. 3.Transparency 4.Compliance with agreement terms WHAT DOES A PASS-THROUGH AGENCY EXPECT OF ITS SUBRECIPIENTS?

16. 1.General agreement compliance 2.Technical capacity 3.Satisfactory continuing control 4.Procurement 5.DBE 6.Title VI 7.ADA 8.Vehicle Certifications 9.Program Questions & Resources TOOL: SELF CERTIFICATION ANNUAL SITE VISITS

17. Thank you! QUESTIONS?