COC PROGRAM MONITORING REQUIREMENTS

Transcription

1 COC PROGRAM MONITORING REQUIREMENTS HomeBase December 3, 2014

2 Agenda for Today Overview Section 1: Types of Monitoring Section 2: Scope of Monitoring Section 3: Frequent Compliance Issues Section 4: Risk Analysis Section 5: How to Conduct Monitoring Section 6: Utilizing Monitoring Results Wrap Up

3 Upcoming Trainings Friday, December 5 Eligibility Documentation Wednesday, December 10 - Match and Leverage Friday, December 12 - Recordkeeping and HMIS Wednesday, December 17 - To be announced Friday, December 19 - To be announced

4 Overview

5 Background Monitoring is integral to grant management. It is an ongoing process that assesses the quality of a grant recipient s performance over a period of time. Monitoring provides information about grant recipients and the participants that they serve, which is critical for making informed judgments about program effectiveness and management efficiency. It also helps in identifying instances of fraud, waste, and abuse.

6 Section 1: Types of Monitoring

7 General Overview HUD Monitors recipients/subrecipients CONTINUUM OF CARE (CoC) Monitors recipients/subrecipients RECIPIENTS/SUBRECIPIENTS Monitors itself Monitors subrecipients Is monitored by HUD and CoC

8 HUD Monitoring HUD monitors CoCs and recipients to do the following: Ensure that programs and technical areas are carried out efficiently, effectively, and in compliance with applicable laws and regulations (e.g., statute, 24 CFR Part 578, NOFA, Notices, OMB circulars, and other programmatic guidance) Assist CoCs in improving their performance, developing or increasing capacity, and augmenting their management and technical skills Stay abreast of the efficacy of HUD-administered programs and technical areas within the communities these programs serve

9 CoC Monitoring CoCs have a year-round interest in monitoring and evaluating programs within the system to ensure programs are effective and managed efficiently so the community does not lose money due to poor grant management: Monitoring can be conducted as part of a formal, periodic review or as-needed. CoCs can designate an individual or work group to conduct the monitoring process. Some CoCs have developed policies and procedures. To monitor effectively, CoCs should have a system for tracking and monitoring grants; it is recommended that they maintain upto-date and thorough information on the projects.

10 Recipient/Subrecipient Monitoring Grant recipients/subrecipients will be monitored by CoCs and (perhaps) by HUD and should monitor for self-compliance. Recipients are also responsible for monitoring subrecipients: Recipients/subrecipients must comply with ALL terms of the Grant Agreement. Thus, monitoring includes a number of subject areas, including ensuring that housing supported by grant funds is regularly inspected for habitability at least once per year.

11 Section 2: Scope of Monitoring

12 Scope To ensure that, if audited by HUD, your program would pass with flying colors, your agency should regularly monitor itself and its subrecipients and keep records about the findings on the following topics: Eligibility Supportive Services Housing Client Payments Program Policies Use of Program Income & Cash Match Fiscal Management

13 Scope (Eligibility) Documenting Homeless Status Documenting Chronic Homeless Status Documenting Disability To learn more about Eligibility Documentation, please attend the December 5 th Training.

14 Scope (Program Policies) Client Participation in Policy-Making Client Participation in Day-to-Day Operations Rules and Regulations for Clients Client Grievance Procedures Termination of Assistance Staff Rules and Regulations Emergency Safety and Evacuation Procedures Confidentiality and Privacy Restrictions Non-Discrimination and Equal Opportunity Religious Influences Conflict of Interest Anti-Lobbying Discharge Planning Drug-Free Workplace Educational Assurances To learn more about Program Policies, please see the materials from the November 21 st Training.

15 Scope (Fiscal Management) Internal Controls Cash Management Budget Procurement Audits Accounting Controls Match Property Asset Controls

16 Discussion What topics do you monitor?

17 Section 3: Frequent Compliance Issues

18 Eligibility Sample compliance issues could include: Insufficient documentation Inadequate diagnosis of disability (e.g. not credentialed) Failure to include sufficient detail Failure to date/sign documentation Unclear history of chronic homelessness For more information on Eligibility Documentation, please attend the December 5 th Training.

19 Supportive Services Sample compliance issues could include: Failure to incorporate treatment plan in client file Failure to conduct or document ongoing (re)assessment of progress and/or treatment plan Failure to indicate which services are being provided

20 Housing Sample compliance issues could include: Failure to adequately screen for lead-based paint Failure to regularly inspect habitability of units

21 Client Payments Sample compliance issues could include: Failure to adequately verify client income and/or conduct an annual review Charging excessive rent Charging program fees

22 Program Policies Sample compliance issues could include: Failure to keep adequate records Failure to implement require policies and/or procedures For more information on Program Policies, please see the materials from the November 21 st Training.

23 Use of Program Income & Match Sample compliance issues could include: Insufficient and/or ineligible match Failure to obtain an MOU for in-kind services Failure to track or document match For more information on Cash Match, please attend the December 10 th Training.

24 Fiscal Management Sample compliance issues could include: Charging for ineligible expenses Paying rent above FMR amount Salary costs not tied to eligible expense Insufficient documentation to support drawdown

25 Discussion What are the most common issues you see?

26 Section 4: Risk Analysis

27 What is a Risk Analysis? As you ve seen, the scope of monitoring is extensive; as a result, neither HUD nor the CoCs have the time or energy to monitor every aspect of a grant s operation. HUD utilizes a risk analysis process to identify those grantees and activities that represent the greatest risk vulnerability to fraud, waste, abuse, and mismanagement.

28 Each CoC/Recipient All CoCs and recipients will also engage in risk analysis to determine how to prioritize for monitoring. Each will do that differently Last year in Santa Clara CoC In this presentation will review HUD s process in detail, which may inform CoC and recipient processes

29 Risk Analysis Process HUD s Risk Analysis process consists of two steps: Rating: Assessing and recording risk for each grantee by the Evaluator; and, Reviewing results by Management; and, Ranking: Ranking grantees by risk, from highest to lowest; Determining monitoring exceptions; and, Certifying results.

30 Risk Analysis Process This process leads to monitoring strategies, including identifying: Which grantees will be monitored; The method of monitoring (on-site or remote); Programs and areas to be monitored; Type of monitoring (in-depth or limited) Resources needed; and, Projected timeframes.

31 Risk Analysis for CoC Programs Risk Analysis for CoC Programs assigns numerical values to four factors, including: Grant Management [37 out of 100] Financial Management [25 out of 100] Services & Satisfaction [23 out of 100] Physical Assets (or Rental Assistance) [15 out of 100] Each individual factor is broken into subfactors which are each assigned a Risk Category (High, Medium, or Low) and a corresponding numerical value, the sum of which equals the total for the factor. After adjusting for exceptions, this overall numerical score is used to identify monitoring targets. For worksheet, please see Implementing Risk Analyses for Monitoring Community Planning and Development Grant Programs in FY 2015 and 2016 at pgs [link]

32 Factor 1: Grant Management Definition: Extent to which the program participant has the capacity to carry out HUD competitive programs according to established requirements. Rating Considerations include: Consideration of the knowledge, skills and ability of program staff Grantee s administrative capacity to manage the grant including: n Eligibility of activities and recipients n Lack of progress in implementing a project n Rapid staff and/or board turnover n Major changes in the agency s mission or direction n Lack of experience with Federal grants or project activities n Frequency and level of technical assistance required by the grantee before and during a project. A-133 Audits Office of Inspector General (OIG) Audits Analysis of Impediments to Fair Housing Choice HUD Environmental Review Online System (HEROS)/Request for Release of Funds and Certification Reporting systems such as IDIS, e-snaps, and LOCCS

33 Factor 1: Grant Management Factor 1 Grant Management includes: Grantee/CoC Program Recipient Reporting Grantee/CoC Program Recipient Staff Capacity Multiple HUD Programs and Multiple Grants under One HUD Program Grantee/CoC Program Recipient Findings and Sanctions (Monitoring and OIG) Grantee/CoC Program Recipient Cross-Cutting Requirement Compliance

34 Subfactor 1A: Grantee/CoC Program Recipient Reporting SUBFACTOR 1A Risk is based on the grantee/coc Program recipient meeting report deadlines with the main consideration being on the completeness and accuracy of information contained in the Annual Performance Report (APR) for homeless grant programs, as well as grantee responsiveness in the last three years. CRITERIA [Risk Category, Risk Score] Untimely, incomplete, or inaccurate reports; OR the grantee/coc Program recipient is unresponsive to HUD requests via , telephone, or correspondence. [High Risk, 5 Points] Timely, complete, and accurate reports AND the grantee/ CoC Program recipient is responsive to HUD requests. [Low, 0]

35 Subfactor 1B: Grantee/CoC Program Staff Capacity SUBFACTOR 1B Risk is based on current staff capacity of the grantee/coc Program recipient in regards to its ability to ensure programmatic compliance with the regulations and fulfill al of its obligations as a grantee/ CoC Program recipient (includes financial staff that may be separate from administrative). CRITERIA [Risk Category, Risk Score] During the last three program years, key staff of the grantee has demonstrated an inability to administer the competitive programs as evidenced through the following: Serious or numerous violations of regulations; Recurring monitoring findings or failure to timely resolve open findings; Poor performance that is ongoing, that the grantee has failed to improve within a reasonable time period; One or more vacancies of key staff have existed for more than six months; More than 50% of staff are not recipients of technical assistance The CoC Program recipient was designated as a Unified Funding Agency; Staff hired with the most recently completed program year or prior years has not demonstrated a basic understanding of HUD requirements; or, Two or more valid complaints from the CoC Board or membership, clients, funders, project sponsors/subrecipients, or other employees about staff capacity have been received by HUD. [High Risk, 12 Points] The grantee/coc Program recipient has experienced the following: A moderate to high turnover of staff; At least 40% of the current staff are not recipients of technical assistance; One or more vacancies of key program staff have existed for the past 3-6 months; or, Key program staff has been hired in the past two program years but lack necessary experience and have not received program training. [Medium, 8] The grantee/coc Program recipient experienced any of the following: No program deficiencies have been identified as evidenced through violations or findings or poor performance; and, Any key staff vacancies have existed for less than three months; and, Any key staff in the past program year are recipients of technical assistance. [Low, 0]

36 Subfactor 1C: Multiple HUD Programs and Multiple Grants under One HUD Program SUBFACTOR 1C Grantee/CoC Program recipient information regarding the number of project sponsors, subrecipients, and funding sources is found in the grantee s Annual Performance Report (APR). CRITERIA [Risk Category, Risk Score] The grantee/coc Program recipient carries out more than two HUD programs using multiple project sponsors/subrecipients, or partners, which involve more than one funding source from HUD. [High Risk, 5 Points] The grantee/coc Program recipient carries out only one HUD program but has more than two grants, which involve one or more project sponsors/subrecipients. [Medium, 3] The grantee/coc Program recipient carries out only one HUD program with one grant, which involves no project sponsors/subrecipients, or partners and only one HUD funding source. [Low, 0]

37 Subfactor 1D: Grantee/CoC Program Recipient Findings and Sanctions (Monitoring and OIG) SUBFACTOR 1D Risk is based on the monitoring of the grantee/coc Program recipient s program by HUD to ensure compliance with program requirements within the last three program years and includes the following: the grantee/coc Program recipient s past performance in regards to the number of open and unresolved findings or monetary sanctions that have been imposed, and any OIG audits the grantee/coc Program recipient has had, or if the grantee/coc Program recipient has been monitored in the last three years. CRITERIA [Risk Category, Risk Score] Within the last three program years, the grantee/coc Program recipient has received findings that are still open and unresolved; OR monetary sanctions have been imposed on the grantee/coc Program recipient; OR HUD has not conducted an on-site monitoring of the competitive program within the last three years. [High Risk, 12 Points] Within the last three program years, the grantee/coc Program recipient has received one finding that is still open and unresolved AND HUD has conducted an on-site monitoring within the last three years. [Medium, 8] The grantee/coc Program recipient has no open monitoring findings AND HUD has conducted an on-site monitoring within the last three years. [Low, 0]

38 Subfactor 1E: Grantee/CoC Program Recipient Cross-Cutting Requirement Compliance SUBFACTOR 1E Risk is based on whether the grantee/coc Program recipient has received a monitoring finding within the last three program years regarding any of the cross-cutting programmatic requirements (Relocation, Environmental, Davis- Bacon, FHEO, etc.). CRITERIA [Risk Category, Risk Score] In the last three program years, the grantee/coc Program recipient has received one more findings on any of the cross-cutting programmatic requirements. [High Risk, 3 Points] The grantee/coc Program recipient has not received monitoring findings on any of the cross-cutting programmatic requirements within the last three years. [Low, 0]

39 Factor 2: Financial Management Definition: Extent to which the grantee/coc Program recipient accounts for and manages financial resources in accordance with approved financial management standards and the amount of potential monetary exposure to the Department. The grantee/coc Program recipient upholds generally accepted conflict of interest policies. Rating Considerations include Financial management under applications Approved or amended grant/coc Program recipient agreements Audit management systems Assessment of grantee/coc Program recipient's drawdown history (i.e., IDIS/LOCCS/PAS) Submission of required documents Timeliness standards and expenditure rates as they relate to financial management and history of financial activities Headquarters (HQ) reporting systems Grantee performance reports, and Any on-site or remote monitoring information available.

40 Factor 2: Financial Management Factor 2 Financial Management includes: Staff Capacity for Financial Compliance Timely Expenditures Grantee A-133 Audits

41 Subfactor 2A: Staff Capacity for Financial Compliance SUBFACTOR 2A Assessment of risk for this factor is based upon financial management compliance with the competitive program regulations, financial management monitoring CRITERIA [Risk Category, Risk Score] The CoC Program recipient was designated as a Unified Funding Agency in the most recent program year; OR during the last three program years, as evidenced through information available (e.g., audits, LOCCS, citizen correspondence, previous HUD monitorings, grantee correspondence with CPD), financial management staff has demonstrated a lack of knowledge or skill sets needed to administer the financial management responsibilities for the competitive program evaluated AND has had one or more violations of Part 84, Part 85, A-87, or A-110. [High Risk, 10 Points] During the last three program years, as evidenced as described above, financial management staff has demonstrated a lack of knowledge or skill sets needed to administer the financial management responsibilities for the competitive program evaluated AND has not had any violations of Part 84, Part 85, A-87, or A-110. [Medium, 5] During the last three program years, financial management staff has not demonstrated a lack of knowledge or skill sets AND no financial management deficiencies have been identified as evidenced through violations or findings. [Low, 0]

42 Subfactor 2B: Timely Expenditures SUBFACTOR 2B The terms and conditions for timely expenditures for the competitive program(s) being assessed can be referenced by the programs grant/recipient agreement and/or operating instructions for that program. Timely expenditure of funds means funds are spent in proportion to the timeliness standards found in the NOFA for the year the grant was funded, the grant agreement, or in the program regulations. Timeliness requirements for the CoC Program are located at 24 CFR CRITERIA [Risk Category, Risk Score] A grantee/coc Program recipient s performance has been untimely in the expenditure of funds in accordance with the grant/coc Program recipient agreement for that program; OR a prior problem of this nature has not been resolved. [High Risk, 10 Points] A grantee/coc Program recipient is performing adequately under a HUD requirement to correct an identified problem; OR the matter is minor in nature and is likely to be corrected per HUD instruction. [Medium, 6] A grantee/coc Program recipient s performance is satisfactory AND any prior problem was corrected AND no problems currently exist. [Low, 0]

43 Subfactor 2C: Grantee A-133 Audits SUBFACTOR 2C Assessment is based on the timely submission of the A-133 program audits for recipients of federal funds that expend in excess of $500,000 on an annual basis, but special emphasis is placed on whether or not the grantee/coc Program recipient has received a finding or has received recommendations in a management letter based on its current accounting practices. Audits are due within 9 months from the end of the grantee/ CoC Program recipient s program year. CRITERIA [Risk Category, Risk Score] During the last three program years, the grantee/coc Program recipient has not been timely in its submission of the required A-133 audits; OR has received a finding and/or has received a recommendation in a management letter based on its current accounting practices. [High Risk, 5 Points] None of the criteria above applies. [Low, 0]

44 Factor 3: Services & Satisfaction Definition: Extent to which HUD grantees/coc Program recipients effectively and efficiently deliver services to intended beneficiaries/clientele and clients or beneficiaries express satisfaction with the delivery of program services. Rating Considerations include: Planned program support and how it addresses the intended range of housing/service needs n n n Specialized efforts for sub-populations Difficulty in serving the proposed number of participants Difficulty in moving homeless program participants to permanent Consider n Freedom of Information Act (FOIA) requests n n n n n n n n n Approved grant amendment requests Annual performance plans Release of funds requests Local-, HQ-, or grantee/recipient-generated automated reports or spreadsheets Correspondence or other communication to HUD Any recent problems, such as citizen complaints, newspaper articles, internet postings, Congressional inquiries, and other forms of correspondence Response/failure to submit reports or respond to inquiries Loss of community support Functional issues related to carrying out and impacting on overall program activities, which include: environmental and wage requirements, flood insurance protection compliance, relocation and acquisition policies.

45 Factor 3: Services & Satisfaction Factor 3 Services & Satisfaction includes: Grantee/CoC Program Recipient Citizen Complaints or Negative Media Exposure Grantee/CoC Program Recipient Responsiveness Program Progress Based on Reports Meeting Program Objectives

46 Subfactor 3A: Grantee/CoC Program Recipient Citizen Complaints or Negative Media Exposure SUBFACTOR 3A Risk is based on citizen complaints received or negative media exposure to its program CRITERIA [Risk Category, Risk Score] Citizen complaints have been received during the last three program years through such sources as program participants, citizen letters, phone calls, hot line complaints, newspaper articles, internet postings, s, etc., AND the grantee/coc Program recipient was found to be in violation of the competitive program regulations. [High Risk, 4 Points] Citizen complaints have been received during the last three program years through such sources as program participants, citizen letters, phone calls, hot line complaints, newspaper articles, internet postings, s, etc., and the grantee/coc Program recipient was found not to be in violation of the competitive program requirements; OR no citizen complaints have been received during the most recently completed program year as described above. [Low, 0]

47 Subfactor 3B: Grantee/CoC Program Recipient Responsiveness SUBFACTOR 3B Risk is based upon grantee s timely response to citizen complaints received. CRITERIA [Risk Category, Risk Score] Grantee/CoC Program recipient has failed to respond or be responsive to complaints and/or citizen inquiries forwarded through HUD during the last three program years. [High Risk, 3 Points] Grantee/CoC Program recipient has responded to complaints and/or citizen inquiries; OR has not received any complaints forwarded through HUD within prescribed timeframes. [Low, 0]

48 Subfactor 3C: Program Progress Based on Reports SUBFACTOR 3C Risk is based upon grantee/coc Program recipient program capacity and meeting its program goals confirmed in the Annual Performance Report (APR). CRITERIA [Risk Category, Risk Score] At time of assessment, the grantee/coc Program recipient is operating at less than 80% of program capacity. [High Risk, 8 Points] At time of assessment, the grantee/coc Program recipient is operating between 91-99% of capacity. [Medium, 5] Grantee/CoC Program recipient is operating at 100% of capacity. [Low, 0]

49 Subfactor 3D: Meeting Program Objectives SUBFACTOR 3D Risk is based upon grantee compliance with programmatic rules, policies, and procedures. CRITERIA [Risk Category, Risk Score] Proposed activities to be carried out by grantee/coc Program recipient or subrecipients have not been on schedule during the most recently completed program year; OR activities that are being carried out do not address the intended HIV/AIDS beneficiaries, homeless population, subpopulations or needs of this program. [High Risk, 8 Points] Proposed activities to be carried out by grantee/coc Program recipient or subrecipients are on schedule for the most recently competed program year; however, in the three most recent program years, the grantee/coc Program recipient has not been on schedule at least once AND the grantee/coc Program recipient has submitted a revised timetable to come into compliance. [Medium, 5] Proposed activities to be carried out by grantee/coc Program recipient or subrecipients have been carried out with no known problems, have been on schedule and address the beneficiaries, sub-populations or needs of this competitive program for the three most recent program years or since grant execution, if less than three program years. [Low, 0]

50 Factor 4: Physical Assets (Leasing and Rental Assistance) Definition: Extent to which HUD-funded physical assets are developed, maintained and operated according to established standards. Rating Considerations includes: HUD s inspection of records and reports Observation of the grantee/coc Program recipient s proper use of established forms and procedures Information received through public comments, A-133 or other audits and other sources of information. Consider: Any existing or previously identified problems with the physical assets Whether HUD funds are used for acquisition, construction or rehabilitation activities The number of sites at which HUD-funded physical assets are located and the activities supported by the physical asset The extent of any previous on-site monitoring.

51 Factor 4: Physical Assets (Leasing and Rental Assistance) Factor 4 Physical Assets (Leasing and Rental Assistance) includes: Existing or Previous Physical Asset Problems Multiple Sites for Physical Assets Acquisition, Construction, Rehabilitation of Physical Assets, Leasing, or Rental Assistance

52 Subfactor 4A: Existing or Previous Physical Asset Problems SUBFACTOR 4A Risk for this subfactor is based upon the design, development, maintenance, and operation of HUDfunded physical assets, and leasing, or rental assistance programs, if applicable. CRITERIA [Risk Category, Risk Score] A problem or finding has been identified in the development, design, maintenance, or operation of a HUD-funded physical asset or other physical site-related activity; OR the physical asset has not been monitored within the most recent three program years; OR a problem has been identified in the housing units funded with leasing or rental assistance, or a site-related activity that has not been resolved as of the date of this review. [High Risk, 5 Points] An identified problem or finding with the development, design, maintenance or operation of the physical asset or leasing and/ or rental assistance program is currently subject to corrective action pursuant to a HUD-approved schedule or plan; and is on schedule. [Medium, 3] The development, design, maintenance and operation of the physical asset leasing and/or rental assistance program are satisfactory; OR any previously identified problem has been corrected AND no known problems exist. [Low, 0]

53 Subfactor 4B: Multiple Sites for Physical Assets SUBFACTOR 4B Risk is based upon the number of sites where physical assets, leasing, or rental assistance are located. CRITERIA [Risk Category, Risk Score] HUD funds are used for the acquisition, development, maintenance, or operations of physical assets, leasing, or rental assistance at two or more facility sites; OR for grants or programs with more than 12 scattered units funded through leasing or rental assistance. [High Risk, 5 Points] HUD funds are used for the acquisition, development, or maintenance or operation of physical assets, leasing, or rental assistance at 1 facility site or fewer than12 units of scattered sites with rental assistance. [Medium, 4] HUD funds are used exclusively to support activities not related to leasing or rental assistance or the acquisition, development, maintenance or operation of a physical asset such as any of the following: supportive services, counseling, training, organizational capacity building, etc. [Low, 0]

54 Subfactor 4C: Acquisition, Construction, Rehabilitation of Physical Assets, Leasing, or Rental Assistance SUBFACTOR 4C Assessment of this subfactor is based upon grantee/coc Program recipient s use of program funds for acquisition, construction, and rehabilitation, leasing, or rental assistance. CRITERIA [Risk Category, Risk Score] Funds are used for the acquisition, construction, rehabilitation, leasing, or rental assistance of 24 or more units of a physical asset; OR funds are used at an existing property for housing or residential programs and the grantee/recipient has not followed the requirements for disposition. [High Risk, 5 Points] Funds are used for the acquisition, construction, rehabilitation, leasing, or rental assistance of fewer than 12 units; OR are used at an existing property for housing, supportive services; OR funds are used at an existing property for housing or residential programs and the grantee/recipient has not followed the requirements for disposition. [Medium, 3] No funds are used for the acquisition, construction, or rehabilitation, leasing, or rental assistance of a physical asset; OR are used at an existing property for housing or residential programs. [Low, 0]

55 HUD Exceptions Exceptions include: The Office of Inspector General (OIG) is currently conducting an audit of the high-risk grantee or high-risk program(s). High-risk grantee or high-risk program(s) were monitored within the last two years and all findings and concerns have been addressed and closed. Grantee will be provided technical assistance or training in the current Fiscal Year. Discretionary Monitoring. Other

56 Implications of HUD Risk Assessment For CoCs and recipients, consider HUD risk assessment tells us: HUD priorities Likely candidates for monitoring Likely issues for monitoring And for our own risk assessment may direct: Our priorities Who we monitor What we monitor Even if not QUITE this formalized!

57 Discussion How do you do risk analysis now? Does the HUD process impact your risk assessment?

58 Section 5: How to Conduct Monitoring

59 Monitoring Processes Once a recipient or CoC has determined who will be monitored on what topics at what level, then the recipient or CoC will determine the process for monitoring: Who will monitor How often On site/remote What data sources will be used Outcomes of monitoring

60 Monitoring Data Sources for Desk Review HUD Annual Performance Report (APR) to evaluate CoC projects Integrated Disbursement and Information System (IDIS) and Consolidated Annual Performance and Evaluation Report (CAPER) data to evaluate ESG projects Periodic review of HMIS data Information provided by the projects Financial and draw down information Other locally available information

61 Annual Performance Report (APR) The Annual Performance Report (APR) is a HUD reporting tool used to track program progress and accomplishments, as well as inform HUD s competitive process for homeless assistance funding With high quality data, the APR can be an effective management tool for homeless housing and serve providers to evaluate a number of issues (such as demographics, program design, and service needs)

62 Utilizing the APR for Monitoring The APR is used by the CoC to report annual progress to HUD on all CoC-funded projects Because the APR utilizes the same report format for all CoC projects, it allows for fair comparisons and reliable information APR data can be used to assess: Annual outcomes Population served Reliability and responsiveness Increases in client income and access to mainstream benefts Cost effectiveness

63 Homeless Management Information System (HMIS) The Homeless Management Information System (HMIS) is a community-wide data collection software system that captures client level information over time on the characteristics and serve needs of people experiencing homelessness. It provides significant opportunities to improve access to and delivery of services while strengthening community planning, program monitoring, and resource allocation.

64 Utilizing HMIS for Monitoring HMIS can be used to align housing and services with community needs and plans by: Determining what you want to know (i.e., select the data points that best match the measurements you are trying to identify) Working backward to recover that information CoCs and individual projects can choose to collect additional data beyond HUD requirements Note that, for HMIS to be an effective tool: Information must be entered routinely and accurately Agencies must have direct access to their data

65 Other Desk Review Tools Other tools that communities use to engage in monitoring include: Self-Sufficiency Index LOCCS Review of agency policies Review of monitoring reports of other funding sources

66 Monitoring Data Sources for On-Site Review Agency financial files Agency client files Agency policies and procedures Site visits Focus groups with consumers Interviews with program staff

67 Monitoring Outcomes Monitors may determine that a project is performing well, adequately, or underperforming. If deficiencies are found through the monitoring or evaluating process, the CoC/recipient should up a process to ameliorate findings. Monitors report findings to CoC board/coc/recipient management after each monitoring round. Monitors send letter to project describing findings and asking for response. Monitors takes action against poor performers, according to situation, which may mean: Providing technical assistance, training, or provider-level peer mentoring Increasing project oversight Reallocating the resources to another project or recipient Monitors work with project to address issues with HUD.

68 Monitoring Outcomes In all cases, monitoring should result in reports that are presented to the monitored entity and included in agency files.

69 Discussion How do you monitor now? What resources do you use?

70 Section 6: Utilizing Monitoring Results

71 How Can I Use Monitoring Results? Once you ve settled on a system for conducting monitoring reviews, there are a number of ways that those results can be utilized, including: Better alignment of your program with outstanding needs and priorities Better allocation of resources As part of the CoC Program Competition Address issues identified through self-monitoring, CoC monitoring, or HUD monitoring

72 Alignment with Needs & Priorities Monitoring results should answer: Are we meeting our grant requirements? Are we on track to achieve our outcome targets? If either answer is no, the next question is what to do about it: Redesign programs? Extra resources? Reallocate existing resources?

73 Results of HUD Monitoring As a result of HUD 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 Technical assistance was provided or is needed There were findings that require corrective actions

74 So, HUD s Found an Issue Where deficiencies are identified, the result could be a finding or a concern. Where an identified deficiency results in a finding, the finding will include the condition, criteria, cause, effect, and required corrective action. Monitoring concerns brought to program participant s attention should include the condition, cause, and effect; the HUD reviewer will suggest or recommend actions that the program can take to address a concern based upon sound management principles or other guidelines, but corrective actions are not required for concerns. Monitoring concerns should be addressed completely and expeditiously; unresolved findings may result in grant funds being returned to HUD and affect the agency s success in garnering future Homeless Assistance Grants (new or renewal).

75 So, You ve Found an Issue If you find issues in the course of your monitoring your own activities, you should address them as soon as possible. Develop a plan to correct the issue. Implement the plan. Be honest with HUD and/or your CoC. Ask HUD or your CoC for technical assistance if you need it Keep in mind that resolving the issue may require additional staff training and/or amending your grant with HUD.

76 Wrap Up

77 Summary For each of these requirements you need to: Know what needs to be happen Create process to make it happen Make it happen Ensure it happened Report it happened Other thoughts?

78 Questions?

79 See you soon! Friday, December 5- Eligibility Documentation Wednesday, December 10 - Match and Leverage Friday, December 12 - Recordkeeping and HMIS Wednesday, December 17 - To be announced Friday, December 19 - To be announced