Monitoring & EnforcementBy

Alan Conway & Debbie Chen

MONITORINGThe purpose of project monitoring is to ensure that the terms and conditions of awards are fulfilled. Project monitoring shall be the joint responsibility of the Grants Officer, Program Officer, award recipient, and/or their designees. Monitoring may take the form of site visits, written and/or oral reports, meetings, or any other form of communication deemed appropriate by the Grants Officer for keeping apprised of project progress.

Performance (technical) reports shall contain brief information as prescribed in the applicable uniform administrative requirements incorporated into the award, unless otherwise specified in the award provisions.

PROGRESS REPORTS

• Reporting Frequency: The Grants Officer, after coordination with the DOC operating unit, shall prescribe the frequency with which the performance reports shall be submitted. – Performance reports shall not be required more

frequently than quarterly or less frequently than annually.

– Required to submit report no later than 30 days after the required reporting period and 90 calendar days for annual or final reports.

PROGRESS REPORT CONTENT

• Comparison of actual accomplishments with the goals and objectives established in the approved application. – Whenever appropriate and the output of programs or

projects can be readily quantified, such quantitative data should be related to cost data for computation of unit costs.

• Reasons why established goals were not met, if applicable.• Other pertinent information including, analysis and

explanation of cost deviation or budget costs.• Recipients shall immediately notify the DOC operating unit

of developments that have a significant impact on the award-supported activities. – For example, notification of any problems, delays or

adverse conditions preventing the objectives of the award

PROGRAM OFFICER RESPONSIBILITY

• Ensure reports are received on time• Review reports • Provide feedback and follow

up on problems• Verify that the recipient: –Provides sufficient information; and–Is making adequate progress

RESEARCH PERFORMANCE

PROGRESS REPORT• Research Grants Require different reporting than

other grant types, a Research Performance Progress Report (RPPR) format was developed to meet those needs.– “The RPPR resulted from an initiative of the

Research Business Models (RBM) Subcommittee of the Committee on Science (COS), a committee of the National Science and Technology Council (NSTC)”

• A need was identified to create consistent reporting among all Federal Agencies. Grants Online is working to implement this action by 2015.

FINANCIAL REPORTING

• Each DOC award shall require recipients to use the SF-425 Full Report or SF-425A Cash Flow Report to report the status of funding.

• Reporting Frequency: The DOC shall determine the frequency of the submission of the Financial Status Report for each project or program, taking into consideration the size and complexity.– The report should be submitted biannually for periods

October-March and April-September.– Required to submit report no later than 30 days after

the required reporting period and 90 calendar days for annual or final reports.

REVIEW OF FINANCIAL REPORTS

Evaluate for the following: • Recipients are expending funds at an appropriate

rate and that matching requirements are being met.• Federal disbursements are comparable with the

period covered by requests for payment.• Recipients are not maintaining excess cash on hand.• Reports submitted by the recipient agree with DOC

accounting records of disbursements.• Reports contain information on indirect costs and

program income if included in original budget.• Reports are completed correctly.

The Federal Funding Accountability and

Transparency Act (FFATA)• The FFATA Subaward Reporting

System (FSRS) is the reporting tool where:– the prime recipients are required to

report subawards; – the prime contract reports

subcontracts and executive compensation data.

• The FFATA is government-wide for both contracts (procurement) and grants.

FFATA (Continued)

• The prime recipient is required to report any subrecipients or subcontracts greater than or equal to $25,000 at the end of the month following the agreement.

• Prime recipients report subaward information at the FFATA Subaward Reporting System (FSRS): http://www.fsrs.gov/. 

• The subaward information entered in FSRS will then be displayed on www.usaspending.gov associated with the prime award furthering Federal spending transparency.

SF 270 – Request For Advance or

Reimbursement• For Grantees not enrolled in ASAP System.• For Grantees with limited/poor financial

history.• For Grantees designated as High Risk.

SF270 is designated to be a temporary means of receiving funds and is usually associated with a special award condition.

Post Award Monitoring

Prior approvals, including these funded actions:• Release of Funds• Continuations / Supplemental Funding–Due Diligence• SAM Website (excluded parties)• Budget analysis (if applicable)• Single Audit• NIST Debt List / Do Not Pay List• Review of current performance

SF-428/SF-429 Tangible Personal Property Report• SF-429 is used for inventory/disposition of

real property.• SF-428 is the cover sheet.• SF-428A if required, is used to provide annual

inventory listing of Federally-owned property• SF-428B is used at closeout to report on

Federally-owned property• SF-428C is to request disposition instructions

at any time other than closeout• SF-428S is the supplemental sheet.

SF-428/SF-429 Tangible Personal Property Report• Federally-owned property consist of

property on loan from Federal government, acquired equipment with Federal funds and residual unused supplies with a fair market value exceeding $5,000

• Disposition is required if the recipient no longer needs equipment for project objectives or if there are not other Federally sponsored activities in need of equipment

Site Visits

– Pre-visit• Discuss internally (GMD/FPO) and notify recipient• Plan agenda and

–Onsite• Interview project staff• Review management procedures and financial records• Observe activities• Present findings in an exit interview with recipient

Audit Resolution Process– Required pursuant to Departmental Administrative Order (DAO) 213-5

“Audit Resolution and Follow-up” – Audit Resolution Process:• OIG submits audit reports to the GMD with audit findings and

recommendations were questioned cost is $10,000 or greater.

• GMD conducts review , makes proposal for audit resolution, notifies the FPO and sends to OIG for concurrence.

• GMD establishes an Audit Determination Letter and establishes a debt.

• Recipient is afforded the opportunity to appeal the audit determination.

• GMD renders a final decision on appeal.

A-133 Audit Requirements

• Applies to: States, Local Governments and Non-Profit Organizations.• Required if: Expenditures are $500,000 or more in one fiscal year.

• Frequency: Annually, following audit fiscal year end date.

• Due: 30 days after the auditor completes independent audit review or nine months after the end of the recipients audit fiscal year end date.

• Submission of Audit: Audit reports and Data Collection Forms should be submitted to the Federal Audit Clearinghouse: http://harvester.census.gov/fac/collect/ddeindex.html

Common Audit Findings

Payments initiated and approved by the same individual.

Reports not filed in a timely manner; incomplete or missing reports.

Expenditures are not properly supported.

Cost expended are not supported under the applicable costs principles of the award

Lack of financial or performance monitoring.

Enforcement Actions

• Failure to report after the 30/90 day windows will initiate emails from the Grants Online system to recipient.

• If report is still not submitted, the following enforcement actions can be taken by the Grants Officer:– Corrective action plans (high risk SACs)– Suspension of payments – Suspension of the award (or both)– Termination of the award– Debarment and suspension of the recipient

(Recommendation)

Questions???