Pre-award monitoring. Off-site monitoring.
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1 CPM of 5 CONTRACT INTRODUCTION Contract monitoring is a review process used to determine a contractor s compliance with state and federal regulations, the terms of the agreement, and expected results and outcomes. Monitoring also includes the review of internal controls to determine if the financial management and accounting system are adequate to account for program funds in accordance with state and federal requirements. ASSIGNMENT OF CONTRACTS TO PROGRAM OFFICE The Office of Monitoring and Internal Controls (OMIC) is responsible to assign the contract monitoring responsibility for human service contracts to a program office. OMIC s assignment of each contract to an organizational unit is based on the relationship between the program office and the contract. Factors of the relationship include: Developing the contract. Establishing the social worker model. Responsibility to the federal or state funding source for compliance. It is possible that these factors may be shared among organizational units for the same contract; in that case, the organizational unit with the preponderance of factors will be assigned the monitoring responsibilities. Once the contracts are assigned to the organizational unit, the monitoring responsibility stays in effect until modified by OMIC. ANNUAL CONTRACT COMPLIANCE PLAN Each DHS organizational unit assigned monitoring contract responsibility must develop an annual contract compliance plan and perform the functions within the plan. This plan has three major components: Pre-award monitoring. Off-site monitoring.
2 CPM of 5 CONTRACT PRE-AWARD On-site monitoring. Pre-award monitoring is the monitoring of the functions involved in the development and awarding of a contract to a contractor. This monitoring is to determine whether or not the DHS administration complied with policies and federal regulations related to the issuance of contracts. Each contract compliance plan must contain a pre-award monitoring contract checklist that identifies certain steps that the organizational unit must perform in the development and awarding of a contract. There are a set of minimum steps that all program offices must perform for all contracts administered. Please visit the OMIC website at Pages/default.aspx and read the Contract Compliance Assurance Guide for more information. Each organizational unit should add any additional steps to this checklist that are either required by their funding source or will enhance the quality of their contract development process. The organizational unit must complete the checklist for newly issued contracts only. OFF-SITE Off-site monitoring is a plan to monitor functions in place that provide DHS with assurances that the contractor is complying with the contract provisions and federal requirements. This monitoring is designed to determine whether or not the DHS administration is using all available tools to monitor the contractor for compliance. The off-site monitoring contract checklist is a document that identifies certain oversight steps that the organizational unit must perform on all outstanding contracts. There are a set of minimum steps that all organizational units must perform for all contracts administered. Please visit the OMIC website and read the Contract Compliance Assurance Guide for more information. Each organizational unit should add any additional steps to this checklist that are either required by their funding source or will enhance the quality of their contract oversight process. The organi-
3 CPM of 5 CONTRACT zational unit must complete an off-site checklist for all newly issued and outstanding contracts. ON-SITE The on-site monitoring techniques are a set of monitoring activities that the organizational unit will undertake when the pre-award and off-site monitoring are not adequate to ensure contractor compliance with the requirements. The Contract Compliance Plan must identify the contractor on which the on-site monitoring will be performed. The contractor(s) will be selected based on a risk analysis performed by the organizational unit. Note: Please visit the OMIC website and read the Contract Compliance Assurance Guide for more information. RISK ANALYSIS The risk analysis should identify contractors that have a high risk of noncompliance in which this risk cannot be reduced by any method other than an on-site visit. All on-site monitoring must comply with on-site monitoring standards. All on-site monitoring reports are issued to both the contractor and the OMIC by the director of the organizational unit. CONTRACT COMPLIANCE PLAN DUE DATES AND APPROVALS Organizational units annual Contract Compliance Plans are due to OMIC no later than August 15th of each year. OMIC will review the plans and provide recommendations to the organizational units related to the completeness of each plan. In addition, OMIC will ensure that each plan provides adequate monitoring coverage as required by federal regulations. From all plans submitted by the organizational units, OMIC will develop a department monitoring plan. This will ensure that the plans from each organizational unit do not overlap with other plans and that all high-risk contractors are scheduled for monitoring visits. OMIC will submit these monitoring plans to the chief deputy director of DHS for approval.
4 CPM of 5 CONTRACT DEPARTMENT PLAN Once the department plan is approved, each organizational unit is responsible for administering their monitoring plan. Note: The department plan will be posted on the OMIC website. OMIC OMIC is responsible to monitor the progress of each organizational unit s plan to ensure that monitoring functions are performed as prescribed and that monitoring standards are adhered to during the pre-award, on-site, and off-site monitoring processes. In addition, OMIC will perform on-site monitoring of selected contractors and will assist other organizational units with the on-site monitoring procedures. REPORT Each organizational unit must issue a report to OMIC that describes the monitoring steps performed and their results. The report is to identify the steps taken and the results from the pre-award checklist and the off-site monitoring. The report must also identify all on-site monitoring reports issued. Each report is to cover a six-month period. REPORT DUE DATES Report due dates are April 30 (covers the period October 1 through March 31) and October 30 (covers the period April 1 through September 30). TRACKING SYSTEM Each organizational unit must enter their completed on-site monitoring reports into the monitoring tracking system maintained by OMIC. The report must also be entered into the OMIC website. When entering information into the website, contractors are to be identified by their federal identification number. Each monitoring
5 CPM of 5 CONTRACT administration is responsible to update the monitoring tracking system. All activities that impact the status of the monitoring findings should be entered into the system. This includes the specific findings, questioned costs, and the contractor s corrective action plan. RESPONSIBLE ADMINISTRATION FOR CONTRACT For a list of responsible administration for contract monitoring, please visit the OMIC website at: Pages/default.aspx
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