Subrecipient Monitoring Preparation Donna
Description: Subrecipient Monitoring Preparation Donna White-Barnes, Branch Manager Donna.White-Barnesla.gov 225-358-5225 Instructor name Instructor email Instructor phone Federal regulations . . . Require GOHSEP to monitor program activities and
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slide1. Subrecipient Monitoring Preparation Donna White-Barnes, Branch Manager
Donna.White-Barnes@la.gov
225-358-5225
Instructor name
Instructor email
Instructor phone<br>
slide2. Federal regulations . . . Require GOHSEP to monitor program activities and program administrative requirements to ensure Subrecipients are in compliance with:
Federal laws
Regulations
Specific program requirements
2 CFR 200.328<br>
slide3. Subrecipient Monitoring Mission “The mission of the Subrecipient Monitoring section is to monitor + assess + assist Subrecipients to successfully implement and complete program requirements.”<br>
slide4. Monitoring assists Subrecipients by. . . Helping reduce risk of de-obligation in current disasters.
Bringing them into compliance so future audits and closeouts are a smooth process.
Helping them to better prepare for future events.<br>
slide5. How can Subrecipients Assist… By being knowledgeable of program requirements and program administrative requirements
Becoming familiar with the 2 CFR and Compliance Supplement 200 Part XI
Attending in person and/or online GOHSEP and FEMA trainings<br>
slide6. How can Subrecipients Prepare for a Monitoring Visit… Ensure that your agency operating policies and procedures are current and in compliance with program administrative requirements.
Ensure that your agency has adequate segregation of duties within business practices.
Ensure your program files and supporting documentation are in a centralized location and readily available.<br>
slide7. How can Subrecipients Prepare for a Monitoring Visit… Carefully review the Monitoring Visit Announcement Letter in it’s entirety
Have the project files being sampled available
Gather the requested documentation
Be prepared to attend the monitoring visit via Zoom Conference or in person<br>
slide8. How can Subrecipients Prepare for a Monitoring Visit… Be prepared to discuss and demonstrate the following:
Be prepared to discuss and demonstrate the following:
General Control Environment – to assess organizational structure and assignment of authority
Expenditures – to assess the expenditure approval process
Accounting – to assess the accounting system
Reporting and Project Progression – to review the accuracy of the project status
Equipment and Inventory – to determine if controls are in place to protect assets
Force Account Labor – to ensure the costs are accounted for and segregated from non project costs<br>
slide9. How can Subrecipients Prepare for a Monitoring Visit… Procurement and Contracts – to provide assurance that transactions are conducted using open competition
Sub-grantee Monitoring – to determine if the subrecipient monitors its sub-grantees, if applicable
Records Retention – to determine if program documentation is retained in accordance with federal requirements
Insurance – to determine the status of insurance proceeds and assess if they overlap with GOHSEP funds
Duplication of Benefits – to determine if benefits received overlap with GOHSEP funds
UEI Registration – to determine if the Unique Entity Identifier is active and registered at SAM.gov<br>
slide10. General Control Environment To assess whether the Subrecipient has a defined organizational structure and assignment of authority
Written general policies and procedures
Code of Ethics Policy
Personnel Packet with acknowledgement form
Controls in place to prevent fraud, waste and abuse
No recurring audit findings<br>
slide11. Expenditures To assess the Subrecipients expenditure approval process
Copy of the expenditure policy with adequate segregation of duties
Advance funds disbursement and cash management policy
Sample of invoices submitted for reimbursement
Chart of accounts, general ledger for matching contributions, support for in-kind contributions/donations<br>
slide12. Accounting To assess the Subrecipients accounting and budget system
Accounting policy with adequate segregation of duties
Revenue/Expenditure Report
Chart of Accounts
Budget system
Project/grant reconciliation
Bank Reconciliation
Accounting system process, access and authority<br>
slide13. Reporting and Project Progression To review the overall process of the Subrecipients project/program and status accuracy.
Process in place to monitor and track projects/program
Documentation to support GOHSEP reporting records (QR)
Accuracy of the Technical Site Inspection<br>
slide14. Equipment and Inventory To determine if controls are in place to protect assets
Equipment/Inventory policies and procedures
Does the policy assign the responsibility and recordkeeping of equipment/inventory;
How assets are managed; (What system is used)
What controls are in place to prevent loss, damage or theft?
Disposition of equipment/inventory > $10K permission
Physical inventory conducted at least once every two years with adequate segregation of duties<br>
slide15. Force Account Labor and Admin Costs To assess how employee time is charged to the project(s) and if those costs are segregated
Employee over-time policies/procedures and time records approvals by employees and supervisors
Type of time keeping system used
Supporting documentation for overtime hours worked
Travel policy, if applicable<br>
slide16. Procurement and Contracts To provide reasonable assurance that procurement/contracts of goods/services are made in compliance with federal, state, and local requirements.
Procurement policies and procedures
Conflict of Interest Standards 2 CFR §200.318 (c)(1)
Maintaining Records 2 CFR §200.318 (i)
Use of Time and Materials 2 CFR §200.318 (j)(1)
Selection Procedures 2 CFR §200.319 (d)(2)
Recovered Materials Section 6002 Solid Waste Disposal Act 2 CFR §200.322<br>
slide17. Procurement and Contracts Procurement Methods 2 CFR §200.320 (a-d and f);
Granting awards to responsible contractors 2 CFR §200.318 (h)
Avoidance of purchasing Duplicative Items 2 CFR §200.318 (d)
Protest Procedures 2 CFR §200.318 (k)
Method for conducting evaluations 2 CFR §200.320 (3) and
Contract Administration/Oversight 2 CFR §200.318 (b)<br>
slide18. Subrecipient Monitoring To determine if the Subrecipient passed project/program funds through to other organizations
Subrecipient Monitoring Program (risk assessment)
Samples of Monitoring Reports and Supporting Documentation
A-133 Monitoring<br>
slide19. Record Retention To determine if the Subrecipient maintains financial records, supporting documents, statistical records, and other records pertinent to the applicable program.
Record Retention Policy/Schedule
Maintenance of records for three years following the final expenditure report for that project/grant
Project files are organized by disaster/event and project number
All supporting documentation is in the project files and readily available<br>
slide20. Insurance Requirements To determine if the Subrecipient has obtained and maintained insurance coverage on property in which federal funds were used to repair or replace.
Declaration page for current insurance policy on facility
Coverage equals or exceeds amount of disaster assistance<br>
slide21. Duplication of Benefits To determine the status of duplicated benefits and assess whether proceeds overlap with project activities
Insurance settlements received are accounted for in the project/grant
Copy of insurance settlement statements
Evidence that settlement check was deposited into SR account
Settlement received are segregated from GOHSEP reimbursements<br>
slide22. Unique Entity Identifier (UEI) To determine if the Subrecipient has an active UEI and are registered on SAM.gov
Must have an active UEI number as long as projects/programs are open
Formerly required to have a DUNS number, but this has been replaced with the UEI.<br>
slide23. Monitoring Visit Process… Day 1 – Entrance interview to assess the status of policies/procedures and projects
Day 2 – Specialist work independently to review policies/procedures and project supporting documentation
Day 3 – Exit interview to discuss the determinations, best practices, and recommendations<br>
slide24. After the Monitoring Visit… The subrecipient will receive a determination letter
If there are recommendations the subrecipient will have 30 days to provide a corrective action plan
The corrective action plan will be reviewed and accepted or not accepted
A final determination letter will be issued
If the subrecipient has 10 or more recommendations a follow-up monitoring visit may be conducted within the next fiscal year<br>
slide25. In a Successful Monitoring Visit… The Subrecipient:
Is organized
Has updated written policies and procedures
Follows their policies and procedures
Is familiar with program requirements and program administrative requirements
Maintains required supporting documentation<br>
slide26. Questions?<br>
Donna.White-Barnes@la.gov
225-358-5225
Instructor name
Instructor email
Instructor phone<br>
slide2. Federal regulations . . . Require GOHSEP to monitor program activities and program administrative requirements to ensure Subrecipients are in compliance with:
Federal laws
Regulations
Specific program requirements
2 CFR 200.328<br>
slide3. Subrecipient Monitoring Mission “The mission of the Subrecipient Monitoring section is to monitor + assess + assist Subrecipients to successfully implement and complete program requirements.”<br>
slide4. Monitoring assists Subrecipients by. . . Helping reduce risk of de-obligation in current disasters.
Bringing them into compliance so future audits and closeouts are a smooth process.
Helping them to better prepare for future events.<br>
slide5. How can Subrecipients Assist… By being knowledgeable of program requirements and program administrative requirements
Becoming familiar with the 2 CFR and Compliance Supplement 200 Part XI
Attending in person and/or online GOHSEP and FEMA trainings<br>
slide6. How can Subrecipients Prepare for a Monitoring Visit… Ensure that your agency operating policies and procedures are current and in compliance with program administrative requirements.
Ensure that your agency has adequate segregation of duties within business practices.
Ensure your program files and supporting documentation are in a centralized location and readily available.<br>
slide7. How can Subrecipients Prepare for a Monitoring Visit… Carefully review the Monitoring Visit Announcement Letter in it’s entirety
Have the project files being sampled available
Gather the requested documentation
Be prepared to attend the monitoring visit via Zoom Conference or in person<br>
slide8. How can Subrecipients Prepare for a Monitoring Visit… Be prepared to discuss and demonstrate the following:
Be prepared to discuss and demonstrate the following:
General Control Environment – to assess organizational structure and assignment of authority
Expenditures – to assess the expenditure approval process
Accounting – to assess the accounting system
Reporting and Project Progression – to review the accuracy of the project status
Equipment and Inventory – to determine if controls are in place to protect assets
Force Account Labor – to ensure the costs are accounted for and segregated from non project costs<br>
slide9. How can Subrecipients Prepare for a Monitoring Visit… Procurement and Contracts – to provide assurance that transactions are conducted using open competition
Sub-grantee Monitoring – to determine if the subrecipient monitors its sub-grantees, if applicable
Records Retention – to determine if program documentation is retained in accordance with federal requirements
Insurance – to determine the status of insurance proceeds and assess if they overlap with GOHSEP funds
Duplication of Benefits – to determine if benefits received overlap with GOHSEP funds
UEI Registration – to determine if the Unique Entity Identifier is active and registered at SAM.gov<br>
slide10. General Control Environment To assess whether the Subrecipient has a defined organizational structure and assignment of authority
Written general policies and procedures
Code of Ethics Policy
Personnel Packet with acknowledgement form
Controls in place to prevent fraud, waste and abuse
No recurring audit findings<br>
slide11. Expenditures To assess the Subrecipients expenditure approval process
Copy of the expenditure policy with adequate segregation of duties
Advance funds disbursement and cash management policy
Sample of invoices submitted for reimbursement
Chart of accounts, general ledger for matching contributions, support for in-kind contributions/donations<br>
slide12. Accounting To assess the Subrecipients accounting and budget system
Accounting policy with adequate segregation of duties
Revenue/Expenditure Report
Chart of Accounts
Budget system
Project/grant reconciliation
Bank Reconciliation
Accounting system process, access and authority<br>
slide13. Reporting and Project Progression To review the overall process of the Subrecipients project/program and status accuracy.
Process in place to monitor and track projects/program
Documentation to support GOHSEP reporting records (QR)
Accuracy of the Technical Site Inspection<br>
slide14. Equipment and Inventory To determine if controls are in place to protect assets
Equipment/Inventory policies and procedures
Does the policy assign the responsibility and recordkeeping of equipment/inventory;
How assets are managed; (What system is used)
What controls are in place to prevent loss, damage or theft?
Disposition of equipment/inventory > $10K permission
Physical inventory conducted at least once every two years with adequate segregation of duties<br>
slide15. Force Account Labor and Admin Costs To assess how employee time is charged to the project(s) and if those costs are segregated
Employee over-time policies/procedures and time records approvals by employees and supervisors
Type of time keeping system used
Supporting documentation for overtime hours worked
Travel policy, if applicable<br>
slide16. Procurement and Contracts To provide reasonable assurance that procurement/contracts of goods/services are made in compliance with federal, state, and local requirements.
Procurement policies and procedures
Conflict of Interest Standards 2 CFR §200.318 (c)(1)
Maintaining Records 2 CFR §200.318 (i)
Use of Time and Materials 2 CFR §200.318 (j)(1)
Selection Procedures 2 CFR §200.319 (d)(2)
Recovered Materials Section 6002 Solid Waste Disposal Act 2 CFR §200.322<br>
slide17. Procurement and Contracts Procurement Methods 2 CFR §200.320 (a-d and f);
Granting awards to responsible contractors 2 CFR §200.318 (h)
Avoidance of purchasing Duplicative Items 2 CFR §200.318 (d)
Protest Procedures 2 CFR §200.318 (k)
Method for conducting evaluations 2 CFR §200.320 (3) and
Contract Administration/Oversight 2 CFR §200.318 (b)<br>
slide18. Subrecipient Monitoring To determine if the Subrecipient passed project/program funds through to other organizations
Subrecipient Monitoring Program (risk assessment)
Samples of Monitoring Reports and Supporting Documentation
A-133 Monitoring<br>
slide19. Record Retention To determine if the Subrecipient maintains financial records, supporting documents, statistical records, and other records pertinent to the applicable program.
Record Retention Policy/Schedule
Maintenance of records for three years following the final expenditure report for that project/grant
Project files are organized by disaster/event and project number
All supporting documentation is in the project files and readily available<br>
slide20. Insurance Requirements To determine if the Subrecipient has obtained and maintained insurance coverage on property in which federal funds were used to repair or replace.
Declaration page for current insurance policy on facility
Coverage equals or exceeds amount of disaster assistance<br>
slide21. Duplication of Benefits To determine the status of duplicated benefits and assess whether proceeds overlap with project activities
Insurance settlements received are accounted for in the project/grant
Copy of insurance settlement statements
Evidence that settlement check was deposited into SR account
Settlement received are segregated from GOHSEP reimbursements<br>
slide22. Unique Entity Identifier (UEI) To determine if the Subrecipient has an active UEI and are registered on SAM.gov
Must have an active UEI number as long as projects/programs are open
Formerly required to have a DUNS number, but this has been replaced with the UEI.<br>
slide23. Monitoring Visit Process… Day 1 – Entrance interview to assess the status of policies/procedures and projects
Day 2 – Specialist work independently to review policies/procedures and project supporting documentation
Day 3 – Exit interview to discuss the determinations, best practices, and recommendations<br>
slide24. After the Monitoring Visit… The subrecipient will receive a determination letter
If there are recommendations the subrecipient will have 30 days to provide a corrective action plan
The corrective action plan will be reviewed and accepted or not accepted
A final determination letter will be issued
If the subrecipient has 10 or more recommendations a follow-up monitoring visit may be conducted within the next fiscal year<br>
slide25. In a Successful Monitoring Visit… The Subrecipient:
Is organized
Has updated written policies and procedures
Follows their policies and procedures
Is familiar with program requirements and program administrative requirements
Maintains required supporting documentation<br>
slide26. Questions?<br>