U.S. Department of Housing and Urban Development

1. U.S. Department of Housing and Urban Development

2. Continuum of CareProgram MonitoringMark SorboProgram Manager, Detroit Field OfficeMargaret MomonSenior Financial Analyst, Detroit Field Office2019 Building Michigan Communities Conference05/01/2019

3. Overview • Regulations • HUD Monitoring Activities • Annual Risk Analysis • Monitoring Visit • eLOCCS Payment Requests • Annual Performance Report (APR) • Other HUD Monitoring • Roles and Responsibilities • Grantee Monitoring Activities • Program Evaluation • Financial Management and Control • Sub-Recipient/Contractor Monitoring • Continuum Lead Agency Monitoring Activities • Continuum Lead Responsibilities • Continuum Member Responsibilities • Monitoring Resources • Questions

4. Regulations

5. Regulations • 24 CFR part 578 • Continuum of Care Program Interim Rule • 2 CFR part 200 • Uniform Administrative Requirements, Cost Principles, and Audit Requirements • Applicable for Grants Awarded through FY2015 Program Competition and later • Regulations Contain Requirements on Monitoring for Compliance in Various Program Areas: • Uniform Administrative Requirements • Audit Requirements • Subrecipient Monitoring • Continuum Lead Agency Monitoring • Some additional regulations related to lead-based paint compliance when housing clients in pre-1978 properties

6. HUD Monitoring Activities

7. HUD Monitoring Activities • Timeline of HUD Monitoring Activities • Typical Date Ranges Included

8. HUD Monitoring Activities • Annual Risk Analysis • Completed every year by CPD Representative • One analysis per organization • Can be for multiple grants/programs • Grantee staff may be asked to provide program documents • Results in overall risk score used internally at HUD-CPD for comparison across programs and grant recipients • Results used as factor in selection of monitoring visits

9. HUD Monitoring Activities • Program Monitoring Overview • Work Plan Development • Monitoring Notification Letter • On-Site or Remote Monitoring • Typically between 2-5 days in length • Usually completed by CPD Representatives and Fiscal Analysts • Coordination prior to monitoring start date

10. HUD Monitoring Activities • Pre-Monitoring Visit Activities • Locate Key Program Documents • Prepare Meeting Space and Location for File Review • Possibly Schedule Client and Community Site Visits (On-Site Visit Only) • Coordinate Program Staff Schedules for Meetings and Interviews • Maintain Contact With HUD Monitoring Staff

11. HUD Monitoring Activities • Monitoring Visit Activities • Entrance Meeting • Staff Involved • Topics Covered • Program Overview • Sample document review • Project File and Documentation Review • Policies and Procedures • Client Eligibility • Financial Management • Annual Audit Review • Client and Community Site Visits (On-Site Visit Only) • Client Interviews • Program Staff Interviews • Daily Debriefings • Exit Meeting

12. HUD Monitoring Activities • Monitoring Exhibits • Selected based on comprehensive knowledge of grant program areas • Risk Analysis, Work Plan Development, Program Knowledge, Client Complaints, Financial History, Required Monitoring Components • Common Exhibits Used in CoC Program Monitoring • 29-1: Review of Homeless and At-Risk Determination/Recordkeeping Requirements • 29-3: Overall Grant Management • 29-4: Subrecipient Grant Management • 29-11: Match Requirements • 29-12: Financial Management and Cost Allowability • 24-2: Lead-Based Paint Compliance • 34-1: Financial Management and Audits

13. HUD Monitoring Activities • Monitoring Report • Timeline (60 Day Goal) • Cover Letter • Summary Information • Program Areas Reviewed • Monitoring Results • Finding • Concern • Recommendation • Comment

14. HUD Monitoring Activities • Monitoring Report Follow-Up • Report Response (From Grantee) • Typically 30-60 Days (see report for specific window) • Resolving Findings • Review Corrective Actions Identified in Report • Coordinate with CPD Staff • Ongoing Process • Timeline and Outcomes Tracked by CPD Staff • Report Updates from HUD • Official Notice of Finding Update or Closure

15. HUD Monitoring Activities • electronic Line Of Credit Control System (eLOCCS) Payment Requests • Required and Periodic Reviews by CPD Staff • Infrequent Requests • Budget Line Item Issues • Requests in Grant Closeout Period • Typically 3-5 Days for Review • Supporting Documentation • eLOCCS Data Reviewed During Monitoring Visits

16. HUD Monitoring Activities • Annual Performance Report (APR) Review • Due by Grantee 90 Days After Grant End Date • Reviewed by CPD Staff • Typically 45-60 Days for Review • Submitted through SAGE System • HUD Uses the APR to track progress and performance • Information populated from eSNAPS, eLOCCS, and HMIS • APR Data may be used in Risk Analysis and Monitoring Visit

17. HUD Monitoring Activities • HUD Field Office Responsibilities • Complete Annual Risk Analysis • Prepare Monitoring Work Plans • Schedule and Complete Monitoring Visits • Prepare and Issue Monitoring Report • Review eLOCCS Payment Requests • Review Annual Performance Reports • Review Annual Single Audits (if applicable) • Ongoing Monitoring and Evaluation of Grant Recipient • HUD Field Office Staff Roles • CPD Representatives / Fiscal Analysts • Program Managers • Director

18. HUD Monitoring Activities • HUD HQ Responsibilities • Review NOFA Applications and Award Funds • Determine Annual Monitoring Goals and Objectives • Revise Monitoring Exhibits (as needed) • Provide Policy and Technical Assistance to HUD Field Office Staff (as needed) • Program and Organizational Oversight • HUD HQ Roles • HUD Office of Field Management • HUD Office of Special Needs Assistance Programs (HUD-SNAP) • HUD Office of Inspector General (HUD-OIG)

19. Grantee Monitoring Activities

20. Grantee Monitoring Activities • We expect grantees to regularly and thoroughly monitor and evaluate their activities throughout the entire grant period • Policies and Procedures • Program and Staff Activities • Sub-Grantee Activities • Program Costs and Expenses • The proposed approach for this monitoring and the evidence that it is occurring should be documented

21. Grantee Monitoring Activities • Types of Grantee Self-Monitoring Activities

22. Grantee Monitoring Activities • Program Evaluation • Policies and Procedures • Must be documented and available for review • Should be reviewed and updated regularly • Typically referenced and involved in HUD Monitoring and Resolution • Should include complaint resolution, client termination, and sub-recipient monitoring policies • Annual Performance Report • Submitted for each CoC Grant and reviewed by CPD Staff • Should be used to measure achievement based on stated objectives

23. Grantee Monitoring Activities • Financial Management and Control • Budget Review and Reconciliation • Financial staff should monitor budget regularly to ensure budget categories are aligned with expected program area costs and in compliance with 2 CFR 200. • Budget revisions should be submitted to HUD in a timely manner • Applicant Match must be tracked and documented • Annual Single Audit • Required for all recipients that expend $750,000 or more in Federal Funding in a fiscal year • Due within 9 Months of end of organization fiscal year • Must be submitted to Federal Clearinghouse • Included in other HUD Monitoring activities

24. Grantee Monitoring Activities • Financial Management and Internal Controls • 2 CFR 200: Uniform Administrative Guidance, Cost Principles & Audit Requirements • Subpart A – Acronyms • Subpart B – (Pre- and Post) Financial Management • Subpart C – Procurement Activities • Subpart D: Cost Principles • Subpart E: Audits Requirement

25. Grantee Monitoring Activities • Sub-Recipient and/or Contractor Monitoring • HUD Responsibilities • Primary Grant Recipient (Grantee) • Grantee Responsibilities • Frequency: At Least Annually • Policies: Risk Analysis, Monitoring Plan, Corrective Actions • Key Documents: Procurement, Contracts, Agreements, Financial Records, Audits, HUD Monitoring Exhibits • Reports: Monitoring Results, Quarterly Financial and Performance Summary, Annual Audits (if applicable)

26. Continuum Monitoring Activities

27. Continuum Monitoring Activities • 24 CFR Part 578 (CoC Program Interim Rule) • Formalizes the composition and responsibilities of the CoC and establishes minimum requirements for its operation and management. • Establishes seven responsibilities that must be carried out by the CoC. All responsibilities must be thoroughly documented in the CoC’s governance charter. • (5) …develop, follow, and update annually a governance charter, which will include all procedures and policies needed to comply with subpart B of this part and with HMIS requirements as prescribed by HUD… • (6) …monitor recipient and subrecipient performance, evaluate outcomes, and take action against poor performers. • (7) Evaluate outcomes of projects…and report to HUD. • (9) …establish and consistently follow written standards for providing Continuum of Care assistance...

28. Continuum Monitoring Activities • Continuum Lead Responsibilities • Policies and Procedures • Grievance Policy (internal and external) • Flexible Design • Use of Positions or Titles when Possible • To prevent future gaps due to staff turnover • Transparency and Fair Treatment • Documentation Requirements • Coordinated Entry, Complaint/Request Intake, Processing, and Resolution • Communication Protocols • Response Timeliness • Between Continuum Members

29. Continuum Monitoring Activities • Continuum Member Responsibilities • To Clients • Clear line of communication • Appropriate staff responsible for client interactions • Timeliness of response(s) • Protection of personal information • To Continuum • Follow local continuum policies in place • Communicate client needs as required • To HUD • Respond to information requests in timely manner • Provide updates as requested or when issue is resolved

30. Monitoring Resources

31. Monitoring Resources • HUD Exchange www.hudexchange.info • CoC Grant Administration Guide: https://www.hudexchange.info/resources/documents/CoCProgramGrantsAdministrationUserGuide.pdf • CoC Program Monitoring: https://www.hudexchange.info/programs/cpd-monitoring/#coc • CPD Monitoring Handbook (6509.2) and Exhibits: https://www.hud.gov/program_offices/administration/hudclips/handbooks/cpd/6509.2 • HUD-CPD Detroit Field Office Staff • CPD Representatives • Fiscal Analysts • Program Managers • Director

32. Questions Mark Sorbo 313-234-7334 Mark.F.Sorbo@hud.gov Margaret Momon 313-234-7331 Margaret.A.Momon@hud.gov