monitoring of grantees by hud webinar slides · 2019-03-15 · • monitoring helps hud field staff...

U.S. Department of Housing and Urban Development

Monitoring of Grantees by HUD

Tuesday, May 3, 20112:00 PM – 4:00 PM

Community Planning and Development

Introductions

• Jessie Handforth Kome, HUD

• John Laswick, HUD

U.S. Department of Housing and Urban Development • Community Planning and Development 2

Agenda

• HUD goals, purpose and approach to monitoring.

• Risk analysis and monitoring. • Monitoring methods, levels and types. • The monitoring process. • Findings and concerns. • Monitoring follow-up and technical assistance. • Resources and contacts.


What Are the Goals of Monitoring?

• Assess the quality of grantee performance. • Determine the level of grantee compliance. • Address grantee management deficiencies and

design corrective actions. • Improve or reinforce grantee performance. • Highlight grantee accomplishments. • Identify grantee best practices that might be

replicated by other CPD program participants.


Why Monitor?

Why monitor?

• Improve subrecipient and contractor performance

• Carry out your CDBG program in a timely manner

• Comply with regulations

• Improve management quality

• Solve problems

• Improve communication

• Save time

• Avoid audit hassles U.S. Department of Housing and Urban Development • Community Planning and Development

Why Must HUD Monitor Grantees?

• Monitoring provides essential information about grantees to HUD that contributes to overall program effectiveness and management efficiency.

• Monitoring is an integral management control technique and a Government Accountability Office (GAO) standard.


The Role of Monitoring

• Monitoring plays a key role in HUD program management.

• Monitoring helps HUD field staff to: Stay fully informed concerning participant compliance

with program requirements.

Be aware of the extent to which technical assistance is needed.

Detect fraud, waste, and mismanagement or situations with potential for such abuse.


HUD Approach to Monitoring

• Not a once a year or periodic exercise. • An ongoing process involving continuous

communication and evaluation. • A cooperative endeavor. • An integral part of HUD field staff responsibility. • A conversation with the grantee.


The Monitoring Conversation

• Monitoring involves: Frequent telephone/email contacts.

Written communications.

Analysis of reports and audits.

Periodic meetings.


What is Monitoring?

• Quality control • Program management • Risk analysis • Guidance • Technical assistance • A conversation


Monitoring is NOT

• An “audit” • Static • One-way • Enforcement • “Gotcha!”


HUD Approach to Deficiencies

• Any deficiencies identified in grantee management practices during monitoring should be handled through: Discussion,

Negotiation, or

Technical assistance.

• And in a manner that maximizes local discretion.


Risk Analysis

• All monitoring is based on CPD’s risk analysis process.

• Part of the monitoring strategy for each HUD field office.

• Targets resources to grantees which pose the greatest risk to the integrity of CPD programs.


Risk Analysis

• Should result in identifying those grantees and activities that represent the greatest vulnerability to fraud, waste, and mismanagement.

• Formally conducted every other year. Informally, it is a continual process.

• Part of the ongoing conversation. • Individual grantee past performance is analyzed

in the national context of grantee performance, both competitive and formula.


Risk Analysis

• Ranks grantees in descending order, from highest to lowest risk.

• Three risk categories are used: high, medium, and low. – See CPD Notice 09-04 “Implementing Risk Analyses

for Monitoring Community Planning and Development Grant Programs in FY 2010 and 2011.”


Risk Analysis

• Assists HUD to identify grantees to be monitored. On-site and remotely;

The program areas to be covered; and

The depth of the review.


Risk Analysis

• Will determine: Who is monitored.

Frequency of monitoring.

Type or level of monitoring.

Programs or grants monitored.

Technical areas monitored.


Risk Analysis Factors

• Financial factors: size of grant, timeliness, financial compliance, expenditure provisions

• Physical conditions of projects: acquisition, construction, and rehabilitation of assets

• Management factors: staff capacity, program complexity and design, submissions

• Satisfaction: citizen complaints, grantee responsiveness

• Services: program objectives, carrying out program activities, program progress


NSP Risk Factors

• Five NSP-specific risk factors: NSP/CDBG Grant Ratio

NSP Absolute Grant Amount

NSP Program Management

NSP Grantee Activities

NSP Program Progress


HPRP Risk Factors

• Three HPRP-specific risk factors: Management

Program objectives

Financial


Monitoring Methods

• Monitoring is an ongoing conversation. • HUD field staff review grantee progress via

IDIS/DRGR. • Review of Consolidated Plan, Action Plan, AI,

CAPER. • Evaluation of submitted reports and

documentation: environmental, contracting, labor compliance, cash transaction.


Levels and Types of Monitoring

• There are different levels, types, and areas of monitoring. Limited or in-depth

Remote or on-site

Program/technical area-specific

Grant-specific

Project-specific


Levels and Types of Monitoring

• Monitoring may also be in response to a complaint or concern. – Example: A complaint to FHEO alleging failure to

provide a reasonable accommodation may lead to monitoring focused on Section 504 compliance.

– Example: Prior findings regarding environmental review may lead to monitoring of a project that required mitigation measures.


Limited Monitoring

• A program compliance review reduced in scope and size.

• May include: A single activity, project, or program.

A sample of a selected activity/project/program.


In-Depth Monitoring

• A detailed grantee compliance review. • Can include: A concentrated review of specific activities, projects,

or programs.

A review of known high-risk areas or critical functions.


In-Depth Monitoring

• Involves: That more than a single area be evaluated such as

a project review, financial review, management review, or technical area review.

That there be a randomly selected activity/project/ program sample sufficiently large to draw a valid conclusion.


Remote Monitoring

• Conducted off-site, typically at the Field Office. • Based on analysis of information from the

grantee, including interviews. • Can incorporate: Review of performance reports and audited financial

statements.

Information in electronic databases (IDIS, DRGR).

Other documentation submitted by the program participant.


On-Site Monitoring

• Conducted at the program participant’s geographic location.

• Certain monitoring questions can only be answered during an on-site monitoring visit.

• Based on review of documentation maintained on-site in grantee offices.


On-Site Monitoring

• May involve: Review of original documentation and sources.

Interviews with program staff, financial management staff, sub-grantees, and others involved in the program being monitored.


Program Areas

• Monitoring may focus on specific technical areas: Labor compliance

Fair housing/equal opportunity

Environmental

Relocation/anti-displacement

Lead hazard reduction

Citizen participation

Others


Grant-Specific

• May focus on one or more specific grants: CDBG, HOME

ESG, HOPWA

Shelter Plus

• May focus on grant years or program categories: Formula or competitive

Disaster/economic recovery

Congressional grants


Focus on Critical Functions

• Monitoring may focus on certain critical functions or areas of concern: Record-keeping

Cost allocation

Timeliness

Sub-grantee management

Reporting


How Often Will HUD Monitor?

• Based on risk analysis. • Higher risk will be monitored more frequently. • Future frequency and level of monitoring may

be dictated by past monitoring results. • At grant milestones and critical project points. • Remember: Monitoring is an ongoing

conversation, not just a periodic event.


Who Will Be Monitored?

• Also based on risk analysis. • Higher risk are more likely to be monitored. • Economic recovery program grantees (NSP,

HPRP, CDBG-R) are by nature considered higher risk.

• New grant recipients may also be considered higher risk.


Who Will Monitor Me?

• HUD field offices are responsible for monitoring within each district.

• In general, your program representative will perform monitoring.

• Specific grant monitoring or technical areas may be conducted by specialized staff. Economic recovery or competitive grants

Environmental, relocation, labor compliance, FHEO


The Monitoring Process

• Monitoring Notice – Notice of monitoring scope and specific areas to be monitored; at least two weeks notice.

• Entrance Conference – Establish expectations for the monitoring; confirm purpose and intent.

• Assessment – Review of documentation; interviews with grantee staff and others.

• Exit Conference – Summary evaluation of monitoring results with the grantee.

• Monitoring Letter – Formal summary of the monitoring, including any findings or concerns.


Monitoring Results

• As a result of monitoring, HUD may reach one or more conclusions: Performance was adequate or exemplary;

There were significant achievements;

There were concerns that need to be brought to the attention of the program participant;

Technical assistance was provided or is needed; and/or

There were findings that require corrective actions.


Identified Deficiencies

• Where a deficiency has been found, HUD staff will categorize it as a finding or a concern.

• The HUD reviewer will provide guidance regarding any identified deficiencies.

• Any conditions which may require serious corrective action will be identified.

– Serious corrective actions such as return of funds or disencumbrance of funds in a grantee’s line of credit will only be considered after discussion with HUD headquarters staff.


Finding Defined

• A finding is a deficiency in program performance based on material noncompliance with a statutory, regulatory, or program requirement for which sanctions or other corrective actions are authorized. – See Exhibit 2-2 of the CPD Monitoring Handbook for

sanction authority.


Finding Documentation

• Documentation of a finding will include: Condition: What was wrong or what the problem was.

Criteria: The regulatory or statutory requirements that were not met.

Cause: Why the condition occurred.

Effect: What happened because of the condition.

Corrective Action: Action(s) needed to resolve the problem and the time frame by which the grantee is to respond.


Concern Defined

• A concern is a deficiency in program performance not based on a statutory, regulatory, or other program requirement.

• Sanctions or corrective actions are not authorized for concerns.

• HUD staff will bring the concern to the attention of the grantee and may recommend actions to address concerns and/or provide technical assistance.


Concern Documentation

• Documentation of a concern will include the condition, cause, and effect as in a finding.

• HUD staff may suggest or recommend actions that the grantee can take to address a concern, based on sound management principles or other guidelines.

• Corrective actions are not required to address concerns.


Grantee Response

• Concerns do not require a response; findings do.

• Response to findings: Concur and undertake suggested corrective actions.

Concur and suggest alternate corrective actions.

Provide additional information to address the finding.


Grantee Response

• Response to concerns may also include concurrence and the provision of additional information.

• Remember: Monitoring is a conversation with the goal of improved grantee program management.


Monitoring Letter

• Sent to grantee within 60 days after completion of monitoring.

• Describes the results of the monitoring. • Provides detail sufficient to clearly describe the

areas which were covered and the basis for the conclusions.


Monitoring Letter

• Each monitoring letter will include: The program, project, or entity monitored.

The dates of the monitoring.

The name(s) and title(s) of the HUD staff who performed the monitoring review.

A list of the program/project/activity areas reviewed or not reviewed.


Monitoring Letter

• Monitoring conclusions and if applicable, clearly labeled findings and concerns.

• If there are findings, an opportunity for the program participant to demonstrate compliance.

• The time frame for a grantee response to the monitoring letter.

• An offer of any technical assistance found to be needed and/or description of technical assistance provided in the course of monitoring.


Monitoring Follow-up

• HUD staff will follow up on monitoring results. According to monitoring letter time frames.

Review of reports including the CAPER.

Subsequent monitoring will examine the implementation of corrective measures and program improvements.

• Grantees are encouraged to consult HUD staff and request further guidance.


Resources

• CPD Grantee Monitoring Handbook

http://www.hud.gov/offices/cpd/library/monitoring/handbook.cfm

• CPD Notice 09-04

http://portal.hud.gov/hudportal/documents/huddoc?id=09-04cpdn.doc

• Overview of NSP Monitoring

http://hudnsphelp.info/media/resources/CrosscuttingRegs_MonitoringOverview.pdf

• NSP Monitoring Webinar -- June 17, 2010

http://hudnsphelp.info/learning/index.cfm?do=viewLearningCenter


http://hudnsphelp.info/learning/index.cfm?do=viewLearningCenter

http://hudnsphelp.info/media/resources/CrosscuttingRegs_MonitoringOverview.pdf

http://portal.hud.gov/hudportal/documents/huddoc?id=09-04cpdn.doc

http://www.hud.gov/offices/cpd/library/monitoring/handbook.cfm

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monitoring of grantees by hud webinar slides · 2019-03-15 · • monitoring helps hud field staff...

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