Monitoring of Grantees by HUD

Transcription

1 U.S. Department of Housing and Urban Development Monitoring of Grantees by HUD Tuesday, May 3, :00 PM 4:00 PM Community Planning and Development

2 Introductions Jessie Handforth Kome, HUD John Laswick, HUD U.S. Department of Housing and Urban Development Community Planning and Development 2

3 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. U.S. Department of Housing and Urban Development Community Planning and Development 3

4 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. U.S. Department of Housing and Urban Development Community Planning and Development 4

5 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

6 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. U.S. Department of Housing and Urban Development Community Planning and Development 6

7 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. U.S. Department of Housing and Urban Development Community Planning and Development 7

8 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. U.S. Department of Housing and Urban Development Community Planning and Development 8

9 The Monitoring Conversation Monitoring involves: Frequent telephone/ contacts. Written communications. Analysis of reports and audits. Periodic meetings. U.S. Department of Housing and Urban Development Community Planning and Development 9

10 What is Monitoring? Quality control Program management Risk analysis Guidance Technical assistance A conversation U.S. Department of Housing and Urban Development Community Planning and Development 10

11 Monitoring is NOT An audit Static One-way Enforcement Gotcha! U.S. Department of Housing and Urban Development Community Planning and Development 11

12 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. U.S. Department of Housing and Urban Development Community Planning and Development 12

13 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. U.S. Department of Housing and Urban Development Community Planning and Development 13

14 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. U.S. Department of Housing and Urban Development Community Planning and Development 14

15 Risk Analysis Ranks grantees in descending order, from highest to lowest risk. Three risk categories are used: high, medium, and low. See CPD Notice Implementing Risk Analyses for Monitoring Community Planning and Development Grant Programs in FY 2010 and U.S. Department of Housing and Urban Development Community Planning and Development 15

16 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. U.S. Department of Housing and Urban Development Community Planning and Development 16

17 Risk Analysis Will determine: Who is monitored. Frequency of monitoring. Type or level of monitoring. Programs or grants monitored. Technical areas monitored. U.S. Department of Housing and Urban Development Community Planning and Development 17

18 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 U.S. Department of Housing and Urban Development Community Planning and Development 18

19 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 U.S. Department of Housing and Urban Development Community Planning and Development 19

20 HPRP Risk Factors Three HPRP-specific risk factors: Management Program objectives Financial U.S. Department of Housing and Urban Development Community Planning and Development 20

21 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. U.S. Department of Housing and Urban Development Community Planning and Development 21

22 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 U.S. Department of Housing and Urban Development Community Planning and Development 22

23 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. U.S. Department of Housing and Urban Development Community Planning and Development 23

24 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. U.S. Department of Housing and Urban Development Community Planning and Development 24

25 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. U.S. Department of Housing and Urban Development Community Planning and Development 25

26 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. U.S. Department of Housing and Urban Development Community Planning and Development 26

27 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. U.S. Department of Housing and Urban Development Community Planning and Development 27

28 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. U.S. Department of Housing and Urban Development Community Planning and Development 28

29 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. U.S. Department of Housing and Urban Development Community Planning and Development 29

30 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 U.S. Department of Housing and Urban Development Community Planning and Development 30

31 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 U.S. Department of Housing and Urban Development Community Planning and Development 31

32 Focus on Critical Functions Monitoring may focus on certain critical functions or areas of concern: Record-keeping Cost allocation Timeliness Sub-grantee management Reporting U.S. Department of Housing and Urban Development Community Planning and Development 32

33 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. U.S. Department of Housing and Urban Development Community Planning and Development 33

34 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. U.S. Department of Housing and Urban Development Community Planning and Development 34

35 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 U.S. Department of Housing and Urban Development Community Planning and Development 35

36 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. U.S. Department of Housing and Urban Development Community Planning and Development 36

37 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. U.S. Department of Housing and Urban Development Community Planning and Development 37

38 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. U.S. Department of Housing and Urban Development Community Planning and Development 38

39 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. U.S. Department of Housing and Urban Development Community Planning and Development 39

40 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. U.S. Department of Housing and Urban Development Community Planning and Development 40

41 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. U.S. Department of Housing and Urban Development Community Planning and Development 41

42 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. U.S. Department of Housing and Urban Development Community Planning and Development 42

43 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. U.S. Department of Housing and Urban Development Community Planning and Development 43

44 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. U.S. Department of Housing and Urban Development Community Planning and Development 44

45 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. U.S. Department of Housing and Urban Development Community Planning and Development 45

46 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. U.S. Department of Housing and Urban Development Community Planning and Development 46

47 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. U.S. Department of Housing and Urban Development Community Planning and Development 47

48 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. U.S. Department of Housing and Urban Development Community Planning and Development 48

49 Resources CPD Grantee Monitoring Handbook CPD Notice Overview of NSP Monitoring NSP Monitoring Webinar -- June 17, U.S. Department of Housing and Urban Development Community Planning and Development 49

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