Fiduciary Responsibilities for Monitoring Sub-Grantees

Fiduciary Responsibilities in Monitor Sub-Grantees

• MSDHA website have updated information available– Monitoring packets available for assistance

• Key Parts– Fiduciary responsibilities

– Monitoring of HARAs

– Monitoring of sub grantees

Part 1Common Fiduciary problems

– No required reimbursement schedule established

• Sub grantees should be submitting reimbursement requests to their fiduciary regularly

– Either monthly or quarterly

– Not inspecting HMIS data regularly

• There should be no missing DOB on your HMIS client served reports

Common Fiduciary problems

– Monitoring of HARAs and sub grantees should have been done

• Written letters should have been sent to each agency monitored

– Please send a copy of those letter to your HA specialist

– Better review of sub grantee audit reports is needed

• Some of your sub grantees have findings

– Look for finding involving cash handling, financial reporting, and accounting procedures

» Have your accountants assist in reviewing financial statements

Common Fiduciary problems

– Make sure your vendors and sub grantees are not listed on the debarment/suspension list

• Go to https://www.sam.gov/portal/public/SAM/ to see their status

Common Fiduciary problems

– Improper accounting

• Your financial assistance types should be separated

– Prevention and Rehousing financial assistance should not be merged together

» Case managers should be identifying costs that are submitted

» Accountants should be tracking the different types of assistance

Common Fiduciary problems

– For budgeting and planning proposes, it is recommended that you break down both

• Prevention- Utilities, arrearages, security deposits and leasing assistance

• Rehousing- Utilities, security deposits, and leasing assistance

Part 2Monitoring of HARAs

– Common problems

• General releases of information are not allowed

– HMIS ROI required

» Agency can have additional ones

• Missing 214

– IDs are required with the 214

» There is not a substitute for the 214

» IDs can be uploaded to HMIS

Monitoring of HARAs

• ESG forms 2 & 3

– The literally homeless qualify for category #1 of form #2.

– All other categories fall under Prevention.

• Household incomes

– All adult members must have their income documented

» Non-working adults fill out form #8

• Verification of Income

– Pay stubs/award letter are the best

Monitoring of HARAs

– Housing documents

• Missing leases

• No housing inspections

– Habitability standards is required

• Proper lead based forms needed

– There are 3 different ones

» #19 is required for all households

Monitoring of Sub Grantees

– Common problems

• Timely billing

– Late submission for reimbursement is not a good sign

» Fiduciaries should look into why an agency that is not turning in billings in a timely manner

Monitoring of Sub Grantees

– No set guidelines for case management• Possible requirements

– Detailed case notes

– HMIS entry

– Regular meetings

– Setting clear goals

– Referrals to HARA or other eligible programs

Monitoring of Sub Grantees

– Oversight

• Billing detail

– Review the time sheets for hours worked

» Look for excessive hours

» Look to see how many programs hours are billed to

» Check case notes to see how often case workers met with clients

» Look to see how many programs the case manager works on

Monitoring of Sub Grantees

– Monitoring

• Look at overall costs and staff capacity

• Look at the case workers workload

• Look at exit outcomes

• Review operational expenses

Questions

• If you have any questions about the content of this webinar, please contact Scott Clark at: clarks15@michigan.gov