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Subrecipient Monitoring: Federal Policies and Sensible Practices

Audio Conference, November 28, 2006Presented by:

Robert M. LloydConsultant on Public Management

and Government Relations

Telephone: (202) 775-0066(864) 235-8680

email: consultlloyd@aol.com

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Do You Have Monitoring “Angst”

To avoid it, let’s review the actual federal requirements

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A Working Definition of Subrecipient Monitoring

Continuous collection of relevant information about a subrecipient organization and its performance

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OMB’s Compliance Supplement For A-133 Audits

Subrecipient Monitoring - 1 of 14 areas for compliance testing– What the supplement says about the real requirements– What it doesn’t say– Part 6 - On internal control– How do you get into trouble here?

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Start Fresh and Organize the Process

“Step Back” Phase Pre-Award Phase Post-Award Phase After-The-Subgrant Phase

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“Step-Back” Phase

Agreement Review– Subrecipient v. Vendor?– Federal fund identification– Federal requirement identification– Shed excess weight– Organize the document– Provide citations

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“Step-Back” Phase (cont.)

Submission Requirements for Applications– Create a useful file– Ask relevant questions

Checklist Review– Build in flexibility for the awarding agency? – Are there other ways to gather information?– Connect to the subgrant agreement

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Pre-Award Techniques

Assess the Applicant Organization– Responsibility– Financial stability– Systems– Prior award activity

Assess the Program or Project– What’s “monitorable”– Performance indicators

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Pre-Award Techniques (cont.)

Tailor the Agreement– Special “high risk” conditions– One size need not fit all

Organize Your Subgrant “Universe”– Size of your award– Size of the federal award portfolio– Extent of your past experience

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Post-Award Techniques

“Kick-Off” so they can catch the ball Use A-133 audits (obtain, review, follow-up) Use limited scope audits (A-133, ___.230(b)) Review financial and performance reports Document routine contacts

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Post-Award Techniques (cont.)

Obtain and use third party information Follow-up on significant developments Conduct meaningful site visits Provide feedback and technical assistance Document, document, document

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Dealing With Your Auditors

Look at their audit program Understand their field work on subrecipient

monitoring What if there are findings?

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This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney-client relationship with the presenter(s). You should not take any action based upon any information in

this presentation without first consulting legal counsel familiar with your particular circumstances.