Sub-Recipient Grant Management and Monitoring Policy

Transcription

1 Sub-Recipient Grant Management and Mnitring Plicy May 2010 Warning: CONTROLLED/UNCLASSIFIED/ This infrmatin is t be cntrlled, stred, handled, transmitted, distributed and dispsed f in accrdance with DHS plicy relating t FOUO infrmatin and is nt t be released t the public, the media, r ther persnnel wh d nt have a valid need-t-knw withut prir apprval f an authrized DHS fficial. This infrmatin is nt fr public disclsure under I.C / 5 U.S.C. 552

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3 TABLE OF CONTENTS I. PURPOSE... 3 II. OVERVIEW... 3 III. OFFICE-BASED MONITORING... 4 A. File Review... 4 Fiscal and Cmpliance Mnitring... 4 Prgrammatic Mnitring... 5 B. Cntact Sub-recipient fr Mre Infrmatin... 5 IV. ON-SITE MONITORING... 6 Fiscal and Cmpliance Mnitring... 6 Prgrammatic Mnitring... 7 V. GRANTS MANAGEMENT CONTACT INFORMATION... 7 REFERENCES Grant Accunting Systems, Federal Grants Management Handbk, tab 420 pp.1-92 Cmmn Rule fr Unifrm Administrative Requirements fr Grants and Cperative Agreements t State and Lcal Gvernments OMB Circular A-87, Cst Principles fr State, Lcal and Indian Tribal Gvernments OMB Circular A-102, Grants and Cperative Agreements with State and Lcal Gvernments OMB Circular A-133, Audits f States, Lcal Gvernments and Nn-Prfit Organizatins 2

4 I. Purpse The Indiana Department f Hmeland Security (IDHS), as the federal grantee, is respnsible fr mnitring sub-recipients and ascertaining that all fiscal, cmpliance and prgrammatic respnsibilities are fulfilled. This includes mnitring sub-recipient reprting, recrdkeeping and internal peratin and accunting cntrl systems. Grant management ensures that the grant prgram is perating efficiently, its internal cntrl prgram is perating successfully, and any deficiencies detected in the grant prgram are crrected in a timely manner. IDHS grant prgrams subject t these general mnitring effrts include, but are nt limited t: BZPP Buffer Zne Prtectin Prgram CCP * Citizen Crps Prgram EMPG * Emergency Management Planning Grant prgram HMEP Hazardus Materials Emergency Preparedness grant prgram HSGP GPD Hmeland Security Grant Prgram * See HSGP/GPD-specific grants ntes thrughut this dcument. LEPC Lcal Emergency Planning Cmmittee grant prgram MMRS Metrplitan Medical Respnse System grant prgram HSGP/GPD Specific: IDHS is the State Administrative Agency (SAA) and primary recipient f hmeland security grant funds. IDHS is tasked with mnitring the prgress f sub-recipient prjects in accrdance with the State Hmeland Security Strategy (SHSS) t gauge statewide prgress tward strategy implementatin, required fr up-line reprting t the U.S. Department f Hmeland Security (DHS), Grant Prgrams Directrate (GPD). Sub-recipient mnitring is als critical t determine whether grant funds awarded fr planning, peratins, equipment, training, exercise, and administrative prjects are expended in accrdance with Office f Justice Prgrams (OJP), Office f the Cmptrller (OC) fiscal guidelines, GPD prgrammatic guidelines, and subgrant awards. Overall, IDHS will assess hw GPD resurces awarded t sub-recipients enhance Chemical, Bilgical, Radilgical, Nuclear, r Explsive (CBRNE) preventin, respnse, and recvery capabilities, and supprt the gals and bjectives in the SHSS. State sub-recipient mnitring will prvide GPD with a cmprehensive picture f hw CBRNE terrrism preventin, respnse, and recvery capabilities are increasing natinwide and will allw GPD t ensure it is prviding resurces and supprt in an efficient and effective manner. II. Overview The IDHS Grants Management Sectin administers sub-recipient grants and mnitrs their activities frm award t clseut. The Prgram specific Prject Manager prvides day-t-day versight, recnciles and apprves prgrammatic subgrantee expenditures, reviews reimbursement requests, and prvides general supprt and assistance relating t prject implementatin. The Prject Manager authrizes reimbursement fr expenditures. The Grants Management Sectin audits quarterly Narrative and Financial Prgress Reprts, the Request fr Reimbursement and supprting dcumentatin fr cmpliance, then frwards fr payment. Accunting persnnel within the IDHS Fiscal Branch prcesses reimbursement and issues a warrant fr payment t the subgrantee. The Prject Manager may maintain a subgrantee wrking file that may include in-prgress prject crrespndence and actins, quarterly reprts that require additinal supprting dcumentatin, cpies f s and a telephne cmmunicatin lg, additinal cntact infrmatin, and incidental and anecdtal prject infrmatin, etc. relevant t the prject and award. The IDHS Grants Cmpliance Officer is respnsible fr sub-recipient mnitring thrugh tw means: ffice-based mnitring and n-site mnitring. Mnitring assists IDHS in identifying areas f need fr subgrantee supprt and prvides feedback n ways t imprve its services. Bth frms f mnitring require written dcumentatin. HSGP/GPD Specific: Mnitring GPD grants encmpasses tw main areas: 1) fiscal and cmpliance mnitring f planning, prcurement and cntracts, exercise, administrative, and training funds, and 3

5 cmpliance with regulatins; and 2) prgrammatic mnitring f subgrantee prgress and peratins, including equipment deplyment, fr prject implementatin and executin. Fr reference, IDHS cnducts sub-recipient fiscal, cmpliance and prgrammatic mnitring based upn the fllwing: OMB Circular A-110 OMB Circular A-87 OMB Circular A-21 OMB Circular A-122 OMB Circular A-133 Cmmn Rule fr Unifrm Administrative Requirements fr Grants and Cperative Agreements t State and Lcal Gvernments Certificatins and Assurances Grant Prgram Guidance Applicable Cde f Federal Regulatins US DOJ/OJP Office f the Cmptrller Financial Guide US DHS/GPD State and Lcal Gvernment Crdinatin & Preparedness, Office f Grant Operatins Federal Grants Management Handbk, Thmpsn Publishing Grup Sub-recipient Obligating Award Dcument III. Office-Based Mnitring Fr each active grant prgram, the Grants Cmpliance Officer cnducts ffice-based mnitring reviews fr ne third f all subgrantees per fiscal year. Office-based mnitring will ccur befre n-site visits are scheduled. Open, multi-year subgrants under the same prgram shuld be reviewed and mnitred at the same time. The Grants Cmpliance Officer perfrms a cmprehensive review f the subgrantee master grant file t ensure that all dcumentatin is cmplete and current; cnferring with the Prject Manager regarding any file irregularities r prblems the subgrantee r the Prject Manager is experiencing, and ensuring that any apparent prblems are addressed. The Grants Cmpliance Officer then cntacts the subgrantee by phne and/r t cnfirm these findings and recncile discrepancies. In unisn the Grants Cmpliance Officer, Prject Manager and the subgrantee agree t a brief written plan and timeline t reslve any prblems. A. File Review The Grants Cmpliance Officer reviews the subgrantee s master grant file t perfrm fiscal, cmpliance and prgrammatic mnitring. The Grants Cmpliance Officer verifies cmpliance with the certificatins and assurances listed in the sub-grant agreement. The review assesses the status f quarterly Narrative Prgress Reprts and Financial Prgress Reprts, the rate f expenditure f funds, evaluatin f prgress implementatin and timelines, and cnfirmatin f these findings with the Prject Manager. Fiscal and Cmpliance Mnitring The fllwing are required dcuments in the sub-recipient fficial master grant file: Cmplete applicatin with riginal signatures, date-stamped when received Sub-grant agreement with riginal signatures, special cnditins, certificatins and assurances, prject narrative and budget detail, and cpy f IDHS award letter Quarterly Narrative Prgress Reprts with supprting dcumentatin; must be current 4

6 Quarterly Financial Prgress Reprts with supprting dcumentatin; must be current SPECIAL NOTE: Since subgrantees maintain financial recrds in a variety f different frmats based n their accunting systems and sftware prgrams, they are nt required t present the infrmatin t IDHS thrugh a single standardized frmat, nr change their frmal accunting systems t cmply with federal requirements. Hwever, IDHS may require the subgrantee t mdify its existing system t develp subsystems t accunt fr grant funds, and t reprt csts in accrdance with the grant agreement. Paid Requests fr Reimbursement with riginal signatures, filed and attached t crrespnding quarterly Financial Prgress Reprts Award Amendment(s) with riginal signatures Paper and/r electrnic cpies f any substantial deliverables (e.g. Pwer Pint presentatin, training curse, prgram plans, brchures, utreach materials, etc.) Crrespndence, especially any previus mnitring dcumentatin, if applicable. Expediting the return f the signed Sub-Grant Agreement and/r Amendment is particularly imprtant when invlving increases, decreases r reallcatin f prject budget amunts, because the award/amendment is nt effective until IDHS receives the riginal signed dcument. N reimbursements will be paid ut t a subgrantee fr thse affected items with an utstanding, unsigned sub-grant agreement r amendment. Of significant cncern t IDHS is if the subgrantee is experiencing any prblems resulting in a slw expenditure f funds. A lack f any expenditure(s) may indicate prject inactivity and will be discussed with the subgrantee. The Grants Cmpliance Officer will ask the subgrantee t further explain and justify reasns fr delayed prcurement activities. If the subgrantee has expended significant funds, the Grants Cmpliance Officer will inquire abut hw expenditures have enhanced its peratins and respnse capabilities. In particular, if special cnditins are in place that withhld funds t the subgrantee, the Grants Cmpliance Officer and Prject Manager will determine what the subgrantee must d t satisfy and remve them. Prgrammatic Mnitring The Grants Cmpliance Officer reviews the subgrantee s master grant file t determine the subgrantee s achievements and ptential prblems faced in implementing the prject. The Grants Cmpliance Officer will cnfer with the Prject Manager during prgrammatic file review. The prject narrative is examined fr the fllwing infrmatin: Gals, bjectives, and implementatin steps planned vs. actual, Requirements and activities, Timelines, planned vs. actual, Evaluatin plans, and Perfrmance measures. HSGP/GPD Specific: The Grants Cmpliance Officer reviews the incidence f exercise and training activities in accrdance with the prject timeline as defined in the grant award, with relevant gals and bjectives in the SHSS and the Hmeland Security Exercise and Evaluatin Prgram (HSEEP). B. Cntact Sub-recipient fr Mre Infrmatin The Grants Cmpliance Officer cntacts the subgrantee and schedules a time t cnduct a phne interview with the subgrantee Prject Manager(s), grant fiscal manager/crdinatr and ther apprpriate individuals in relatin t all active subgrants awarded by IDHS that are currently being reviewed and mnitred. The Grants Cmpliance Officer will ask if the subgrantee has cnducted any frmal prcurements and/r entered int any 3 rd -party cntracts. If s, IDHS will need a narrative summary f the prcurement prcess and a cpy f the cntract. In additin, the Grants Cmpliance Officer may need t reference the jurisdictin s all-hazards Emergency Operatins Plan (EOP) fr crdinatin and alignment with grant activities. Finally the Grants Cmpliance 5

7 Officer will ask the subgrantee if it is experiencing any financial r prgrammatic grant management prblems itself r with IDHS, r has identified a need fr technical assistance and supprt frm IDHS. At the cnclusin f the Office-based Mnitring review the Grants Cmpliance Officer sends an electrnic mem t the subgrantee Prject Manager, cpied t authrized fficials listed n the award and the IDHS Prject Manager, fllwed with a hard cpy by fax r mail. A hard cpy will be placed in the subgrantee s master grant file. IV. On-Site Mnitring IDHS will cnduct n-site mnitring visits fr tw separate sub-recipients each fiscal year. If the subrecipient has received subgrants under several prgrams, all prgram grants are reviewed and mnitred at the same time and the apprpriate IDHS Prject Managers will be asked t participate. On-site mnitring builds upn the subgrantee master grant file review and cnversatins undertaken as part f ffice-based mnitring. Thirty (30) days in advance f the prpsed visit, the Grants Cmpliance Officer cntacts the subgrantee t schedule the upcming n-site visit, briefing the subgrantee n what activities and discussins will take place. The subgrantee will be prvided with a read-ahead packet, including a cver letter, draft meeting agenda and prpsed list f questins, t ensure n-site time is fcused n discussing issues instead f lcating dcumentatin. The cver letter will be cpied t authrizing fficials listed n the award and t apprpriate IDHS Prject Managers. Althugh IDHS staff and the subgrantee determine the structure f the n-site visit, the Grants Cmpliance Officer clearly distinguishes the review f fiscal and grant cmpliance issues frm prgrammatic discussins. Fiscal and cmpliance issues are generally discussed with the subgrantee Prject Manager and Chief Financial Officer and/r fiscal crdinatr. Prgrammatic issues are discussed with the subgrantee Prject Manager, lcal authrizing fficials, and ther recipient agencies r respnse representatives. If multiple grant prgrams and years are being mnitred, the subgrantee shall ensure that the crrespnding respnsible parties are available t participate in meetings during the site visit. The subgrantee shuld expect IDHS t spend a minimum f ne business day n-site. HSGP/GPD Specific: Infrmatin t explain and justify reasns fr delayed prcurement activities is essential fr timely prject implementatin in supprt f first respnders. On the ther hand, if the subgrantee has expended significant funds, the subgrantee will be queried abut hw expenditures have enhanced its respnse capabilities, in particular with regard t the Natinal Incident Management Systems (NIMS), the Natinal Respnse Plan (NRP) and Hmeland Security Presidential Directive 8 (HSPD-8). IDHS staff may request t visit ne r mre f the lcal departments, rganizatins r cntractrs in rder t directly discuss hmeland security issues and mnitr equipment with first respnder recipient agencies, fcusing n the supprt f r benefits received as a direct result f GPD/IDHS funding, and hw thse resurces have enhanced their CBRNE terrrism preventin, respnse, and recvery capabilities. In additin, the subgrantee will be queried as t hw the prject is supprting the SHSS and HSEEP, whether purchased equipment has been deplyed and if additinal training is needed n specialized equipment prir t its use. Fiscal and Cmpliance Mnitring In advance f the n-site visit, the Grants Cmpliance Officer cnducts a cmprehensive dcument review, asking the subgrantee t prvide a recent summary f expenditures, bligatins and pending bligatins (i.e., purchase rders, prcurements r cntracts in prcess), as well as grant budgets and financial reprts, single audit reprts and findings, crrective actin plans, and an rganizatin chart, and ntes any apparent prblems in preparatin fr the n-site visit. Dcumentatin review includes cnfirmatin f certificatins and assurances, supprting dcumentatin fr expenditures, use f management and administrative (M&A) funds, special cnditins and previus mnitring dcumentatin. Delinquent quarterly Financial Prgress Reprts must be submitted prir t the n-site visit. 6

8 On-site, the Grants Cmpliance Officer reviews applicable grantee spending plans, accunting systems and cntrls, recrds retentin systems, 3 rd -party cntracting, prcurement activities, and equipment maintenance and prperty management systems. Prgrammatic Mnitring A majr prtin f the meeting invlves discussins abut prject implementatin such as milestnes, timeline, rate f funds expenditure, prject peratins, perfrmance measures and evaluatin, etc. This will include develpment r update f the subgrantee s all-hazards EOP, peratins systems, and crdinatin with prject-affiliated departments, rganizatins, and cntractrs. Delinquent quarterly Narrative Prgress Reprts must be submitted prir t the n-site visit. At the end f the n-site visit, IDHS staff cnducts an exit interview with subgrantee fficials t discuss findings frm the meetings and t clarify any crrective actin items fr the subgrantee r IDHS staff t pursue after the visit. IDHS staff asks fr feedback t identify areas f self-imprvement by which it can better supprt, assist, r enable subgrantee prject success. The exit interview highlights what will be included in the pst-visit letter t the subgrantee, cpied t authrizing fficials listed n the award and the apprpriate IDHS Prject Managers, summarizing cntents f the reprt that will be placed in the subgrantee s master grant file. If any utstanding financial, cmpliance and prgrammatic issues are identified, the subgrantee is required t submit a Crrective Actin Plan within 30 days f receipt f the reprt, identifying what steps the subgrantee is taking t reslve them. V. Grants Management Cntact Infrmatin IDHS grant pint f cntacts (POCs) can be fund n the IDHS website at: Rachel Meyer - (317) General Management and Oversight Niki Theeuwes - (317) Grant Writing and General Custmer Service Dlly Watkins (317) Reimbursement Cncerns and Agreement Prcessing Cindy Riley (317) HMEP and Mnitring cncerns Beth Clark- (317) PSIC, CSEPP and IECGP cncerns Vicki Biddle (317) Quarterly Reprts and General Clerical 7