1. Subgrantee Monitoring and Risk Assessment Principles
Leslie O’Reilly, VOCA Program Specialist
Bob Haske, VOCA Auditor

2. CRIME VICTIM SERVICES COMMISSION
Assistance, Services and Aid to Crime Victims

3. NON TAX DOLLARS Victims of Crime Act (VOCA) Federal Crime Victims Fund
Crime Victim Compensation Act
Federal Fines and State Assessments
Crime Victim Rights Act
State Assessments

4. Crime Victim Compensation Crime Victim Assistance
Direct assistance to individuals
Last Resort for unpaid medical bills, loss of earnings, burial costs, counseling needs
Crime Victim Assistance
Federal pass through funds
Competitive grants to local public or non profit agencies to provide direct services
Training of professionals
Crime Victim Rights and Assessment Revenue
Funds to support Crime Victim Rights Activities
Grants to prosecuting attorneys and juvenile courts
MI VINE notification
Train advocates

5. VOCA GRANT AWARDS IN MICHIGAN
FY Grants to 86 agencies $18,728, Allocated
FY Grants to 109 agencies $30,204, Competitive
FY RFP – still in process of grant reviews

6. THINGS THEY ARE A CHANGING
2/2015 MERGER OF TWO STATE DEPARTMENTS
STAFF RETIREMENT, RESIGNATION, HIRING, TRANSFERS, NEW STAFF –INCLUDING AUDITORS
9/2015 VOCA 2015 AWARD $$$
1/2016 MOVE OFFICES TO NEW BUILDING
7/2016 NEW VOCA RULES
OCFO AUDIT
9/2016 DEPARTMENT GRANTEE MANAGEMENT AND MONITORING POLICY
OVC AUDIT
CHANGE IN AUDIT MANAGER
SIGNIFICANT TURNOVER IN VICTIM SERVICE LEADERSHIP

7. MDHHS Plan / Outline I. September 2016 II. New Policy
III. Risk Assessment Tool
IV. Monitoring Activities “Menu”
V. Monitoring Plan Development

8. PROGRAM OFFICES WERE TRAINED
Good Business Practice!
2 CFR requires:
(b) Risk Assessments
(d) Minimum Monitoring
(e) Other Monitoring Depending Upon Assessed Level of Risk
Proposal to comply
Learn about policy
Learn about required risk assessments / required monitoring
Applicable to “Grant Awards” to “Grantees”
Award provided to a grantee (subrecipient or recipient) for grantee to carry out a project or program to address a public benefit for the greater good.
DOES NOT include payments to contractors under procurement contracts
Program may have ADDITIONAL monitoring requirements
Check Grant Award Notification / Regulations / Policies specific to your program

9. What is 2 CFR 200?
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Replaces former:
Administrative Requirements (A-102, A-110, A-89)
Cost Principles (A-87, A-122, A-21)
Audit Requirements (A-133, A-50)
Applicable to FEDERAL awards granted AFTER 12/26/2014
Joint Interim Final Rule (12/19/14) (79 FR 75867)
Federal Awarding Agencies adopted guidance
May have made changes – see exceptions at:

10. OMB Circular A-133 (Prior Requirement)
.400 (d) (3) Pass-through entity responsibilities
Monitor 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.
A-133 Compliance Supplement gave guidance on monitoring.

11. 2 CFR 200.331 All pass-through entities must:
(b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:
(1) The subrecipient's prior experience with the same or similar subawards;
(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program;
(3) Whether the subrecipient has new personnel or new or substantially changed systems; and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).

12. 2 CFR 200.331 All pass-through entities must:
(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:
(1) Reviewing financial and performance reports required by the pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means.
(3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § Management decision.

13. 2 CFR 200.331 All pass-through entities must:
(e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:
(1) Providing subrecipients with training and technical assistance on program- related matters; and
(2) Performing on-site reviews of the subrecipient's program operations;
(3) Arranging for agreed-upon-procedures engagements as described in § Audit services.

14. Grantee Monitoring and Management Policy – APA 212
Distributed for Comment 8/15/ Effective 9/1/2016
Significant Definitions:
Grant Award – federally AND non-federally funded
Grantee – agency receiving grant award as recipient or subrecipient
Recipient – agency receiving a grant award that’s not federally funded
Subrecipient – agency receiving a grant award that’s federally funded
Subaward – grant award that’s federally funded (term used in 2 CFR 200)

15. Grantee Monitoring and Management Policy – APA 212
“Policy” Section – General list for involved parties:
Bureau of Purchasing (also administers grants management system)
Bureau of Audit
Program Offices:
Determine Subrecipient/Recipient/Contractor
Perform Risk Assessments Annually
Develop Monitoring Plan
Perform Monitoring Activities

16. Grantee Monitoring and Management Policy – APA 212
“Procedure” Section – More specific details related to:
Relationship Determinations
Grant Award Content
Grantee Risk Assessments
Grantee Monitoring Plan
Grantee Monitoring
Highlights of each of the above follow…

17. Grantee Monitoring and Management Policy – APA 212
Relationship Determinations
Program Offices make determinations
Grant Agreement V. Procurement Contract Determination Form ( CM-0091) optional
Grant Award Content
Purchasing makes sure subaward content meets requirements of 2 CFR (a)
Program Offices make sure special requirements are incorporated.
VOCA GRANT REQUIREMENTS ARE ATTACHMENTS TO THE STANDARD AGREEMENT.

18. Grantee Monitoring and Management Policy – APA 212
Grantee Risk Assessments
Audit providing tool that includes items “to consider” from 2 CFR 200
Program Offices ANNUALLY assess each grantee’s risk of noncompliance
Program Offices categorize grantees in risk categories.
Grantee Monitoring Plan
Program Offices ANNUALLY develop a monitoring plan based off risk assessment
Include minimum required monitoring
Include additional monitoring based on level of risk
Specifically identify activities in plan

19. Grantee Monitoring and Management Policy – APA 212
Audit providing “monitoring activities menu” and guidance
Program Offices perform monitoring and document monitoring
Minimally:
Review required reports
Follow up on deficiencies and ensure corrective action
Program specific monitoring
Additional monitoring based on risk assessment:
Training and technical assistance
Desk reviews
On-site reviews
Arranging agreed-upon-procedures engagements

20. DeMinimus Rate Calculation Tool

22. “Grantee Risk Assessments/Monitoring”
Risk Assessment Tool
“Grantee Risk Assessments/Monitoring”

23. Risk Assessment Tool Overview
Just a recommended template
Can use your own form as long as it meets the requirements of 331(b)
Additional risk factors can be added
13 Columns
9 columns are risk factors that you select the appropriate score
3 columns for entering the identifying information for each of your grant awards
1 column (total risk score) is automatically calculated
Avoid altering the formulas!
Double-check the math!
Written Instructions are available

24. Risk Assessment Tool Identify your Administration
Be sure to type in the appropriate name of your Administration and Program.
Be sure to specify the correct year

25. Risk Assessment Tool Grantee, Grant Award, Award Amount
Each Grant Award will be entered onto one line in the tool
You may have multiple entries for the same Grantee if they have multiple awards.
Grantee Name
Enter the Grantee’s full legal name
Grant Award Number
Enter the unique grant identification number for each award
Grant Award Amount
Enter the full amount of the grant award

26. Risk Assessment Tool Risk Factors
The Risk Assessment tool comes pre-populated with nine common risk factors and scores for each factor have been built into the tool
Simply requires the user to “click” on the appropriate answer for each question.
Definitions for each risk factor are included in the “Risk Definitions” tab of the tool, by “Hold and Hover” on the risk factor title, or by clicking the hyperlinked risk factor title.
If you would like to add additional risk factors add them to your risk assessment tool.

27. Risk Assessment Tool Total Dollar Amount
Total dollar amount is intended to help you capture any significant differences in the dollar value of your grants.
You set your own criteria for what is “Large”, “Medium”, or “Small”
Based on the dollar amounts of your grants.

28. Risk Assessment Tool Previous Grant Experience
Grant Programs may have requirements that are unique.
Grantees that have less experience with a particular grant program may be of higher risk due to the lack of familiarity with grant specific requirements.

29. Risk Assessment Tool Financial and Compliance Monitoring
Grantees not audited or subjected to an MDHHS monitoring review are typically higher risk than those that have.
BARQA is working on a report that will help you with identifying if the grantee had a single audit and if your programs were tested as a major program.

30. Risk Assessment Tool Frequent Turnover of Staff
Grantees that have a high staff turnover rate may encounter issues with consistency of operations related to your programs and are typically considered a higher risk.
If you are aware of higher than normal turnover, you should select “Yes”
If you are not familiar enough or don’t know of any issues, select “No”

31. Risk Assessment Tool Other Issues of Noncompliance
Over the course of a grant, you may become aware of other issues a grantee is having that would make them a higher risk.
Maintain documentation to support your concern.

32. Risk Assessment Tool Financial Management Problems or Issues
Grantees at risk of insolvency, with known financial management issues, frequent tardiness in submitting expenditure reports, etc. are considered a higher risk than those without these issues.
May be identified through an independent audit or through your own monitoring activities.

33. Risk Assessment Tool Significant Findings or Questioned Costs
If the grantee did have findings and/or questioned costs related to your grants, they should be considered a higher risk than those that did not.
If a grantee did not have an audit performed – select “No”.

34. Risk Assessment Tool Recurring or Unresolved Issues
Grantees that are unable to correct known issues in a timely manner should be considered a higher risk than those that are able to implement corrective actions.
If you are aware of previously identified issues that have not been corrected over the course of a full audit or review cycle, select “Yes”.

35. Risk Assessment Tool Programmatic Noncompliance
Grantees who have been found in noncompliance with the programmatic requirements of their grant in the past should be considered a higher risk than those that have not.

36. Risk Assessment Tool Total Risk Score
Automatically calculated based on your answers to the nine risk factors.
Not intended to be an “absolute” score.
Provides a guideline for completing your Annual Monitoring Plan.
Do not enter any information into this column.
This is the number that you will copy to the Monitoring Plan.

37. Monitoring What is Monitoring? Did we get what we paid for?
Anything that provides assurance that the Grantee is in compliance with the provisions of their Grant Award.
Programmatic AND Fiscal
Anything that answers the questions:
Did we get what we paid for?
Did the Grantee do what they were supposed to do?

38. Monitoring Activities “Menu”
“Menu” of 9 Monitoring Activities
May be Other Monitoring Activities Not on the List
Must perform items 1 – 3
Choose Other Activities Based on Assessed Level of Risk
Guidance on Each
Document, Document, Document!

39. Monitoring Plan “Grantee Risk Assessments/Monitoring”
Template will be available
“Grantee Risk Assessments/Monitoring”

40. Monitoring Plan
Not required to use this tool. May already have a tool that meets the requirements.
However… You are required to:
“Annually, develop a monitoring plan based on the results of the risk assessment. The monitoring plan will include the minimum required monitoring elements for each grantee … and other additional monitoring for grantees based on the level of identified risk. The activities to be performed for each grantee will be specifically identified in the monitoring plan.”
Just a Plan, subject to change and should be updated throughout the year.
Allows you to allocate your resources effectively based on the results of your risk assessment.

41. Monitoring Plan Overview
15 Columns
3 columns for identifying the grant award, grantee, and associated risk score from your risk assessment.
4 columns for planning fiscal monitoring activities.
4 columns for planning programmatic monitoring activities.
2 columns for pre-award monitoring.
2 columns for technical assistance.
There are no formulas, everything is to be entered manually.
Written instructions are available.

42. Monitoring Plan Identify your Administration
Be sure to type in the appropriate name of your Administration and Program
Be sure to specify the correct year

43. Monitoring Plan Grant Award, Grantee, Risk Score
Enter each of your grant awards onto one line and include the corresponding risk score from your risk assessment.
You may choose to sort by risk score, highest score to lowest.

44. Monitoring Plan Resources
Before continuing with the Monitoring Plan, you will need to determine the amount of resources that you will be able to dedicate to monitoring over the course of the calendar year.
Typically done using number of hours.
No minimum required number of hours.
Allocation of your hours should be based on:
Any Federal, State, Departmental mandated monitoring activities specific to your programs. (Remember items 1-3 of the monitoring menu are required!)
Your Risk Assessment results.

45. Monitoring Plan Physical Location of Monitoring Activities
If you are going to perform the monitoring activities at the grantee’s place of business, often referred to as “onsite monitoring”, then the monitoring activities should be placed in the “At the Grantee’s Office” column.
If you are going to perform the monitoring activities at your MDHHS place of business, often referred to as “Desk Monitoring”, then the monitoring activities should be placed in the “Not at the Grantee’s Office” column.
This is important to differentiate as you complete the plan because the two different types most often consume different levels of resources.

46. Monitoring Plan Actions
Actions indicate the types of monitoring activities that you plan on performing for each grant award.
Use the “Monitoring Activities Menu” and enter the corresponding number for each monitoring activity you plan on performing for that grantee (remember 1-3 are required!)

47. Monitoring Plan Hours
Hours should indicate the total number of hours you think it will take to complete all of the monitoring actions you indicated.
Again, just a plan and your best projection based on your past experience.
If possible, if any hours are left over after completing your mandatory monitoring activities, the remaining hours should be allocated based on your risk assessment scores with higher risk grant awards receiving more monitoring than those with lower scores.

48. Monitoring Plan Monitoring Categories
Fiscal Monitoring
Programmatic Monitoring
Any set of activities designed to determine compliance with fiscal requirements.
Activities designed to determine compliance with program requirements
Pre-Award Monitoring
Technical Assistance
Functions involved with the development and awarding of a grant to a grantee.
Assistance provided to grantee to assist in compliance with grant requirements.

49. CVSC Monitoring Plan Monitoring Categories
Fiscal Monitoring
Programmatic Monitoring
Annual Risk Assessment
On-site audit visit for high risk
Quarterly Desk Reviews
Subrecipient Questionnaire
Audit Review
Review of financial and programmatic reports
Ensuring compliance with OVCPMT
Pre-Award Monitoring
Technical Assistance
Functions involved with the development and awarding of a grant to a grantee.
Assistance provided to grantee to assist in compliance with grant requirements.

50. SUBRECIPIENT QUESTIONNAIRE
REQUIRED BY DEPARTMENT
COMPLETED ANNUALLY
ATTESTED TO CURRENT STATUS

53. SPECIAL CONDITIONS
ATTACHMENT G
VOCA Crime Victim Assistance Grant Program
PERFORMANCE / PROGRESS REPORT
REQUIREMENTS FY 10/1/2017 – 9/30/2018
The purpose of this attachment is to impose additional special conditions on this Agreement.  
The Executive Director will continue reporting on a bi-weekly basis, beginning October 6, 2017, to the MDHHS team the status of the investigation and include chronological updates until the resolution of this matter. Provide updates on:
Summary of issues
Summary of impact to awards (amount of impact by funding source)
Forensic Audit
Insurance Claim
Criminal Case

55. Statement of Independence

56. DOCUMENTING Tools – Salesforce and Team Mate Grants Management System
Accounting System

57. TOOLS WILL BE AVAILABLE ON THE NAVAA WEBSITE POLICIES AND PROCEDURES
RISK ASSESSMENT TOOL
RISK ASSESSMENT TOOL INSTRUCTION
SUBRECIPIENT QUESTIONNAIRE
MONITORING PLAN
MONITORING PLAN INSTRUCTIONS
VOCA ON SITE PROGRAMMATIC CHECKLIST
DE MINIMUS CALCULATION WORKSHEET with INSTRUCTIONS
AUDIT PROGRAM FOR ON SITE AUDITORS AVAILABLE UPON REQUEST

58. CONTACTS MICHIGAN VOCA SAA VOCA AUDITOR Leslie O’Reilly
VOCA Program Specialist
Crime Victim Services Commission
Grand Tower, Suite 1113
235 S. Grand Avenue
P.O. Box 30037
Lansing, MI 48909
Robert Haske, CPA
Auditor
Population Health and Community Services Section
Bureau of Audit, Reimbursement, and Quality Assurance
PO Box 30479
Lansing, MI 48909
(phone)
(fax)

59. Questions?