The NDOT Subrecipient Risk Assessment Questionnaire FFY19

Transcription

1 The NDOT Subrecipient Risk Assessment Questionnaire FFY19 The purpose of this assessment is to evaluate the technical and financial risk of the Section 5310, 5311, 5311(f), and 5339 applicants. Limited program experience, protocols, and internal controls will increase an applicant s degree of risk, but will not necessarily preclude the applicant from becoming a subrecipient. The applicant s degree of risk may require additional conditions to be incorporated into the grant award pursuant to 2 CFR Patterns or trends in technical and financial risks will influence the NDOT s training as well as the NDOT s monitoring plan. Appropriate technical support will be provided by the NDOT to build subrecipient capacity and lower risks. Process: A. The questionnaire (including the agency and/or grant-specific questions) is distributed to the applicant by the NDOT prior to awarding grant funds. B. The applicant returns the completed questionnaire to the NDOT. The NDOT will score the questionnaire based on the responses provided by the applicant. C. The calculated responses equate to a risk profile for each of the 5 risk categories D. The NDOT will align the risk profile to the applicable specific condition(s) for medium and high-risk applicants in each of the 5 risk categories. E. The NDOT will communicate the applicable specific condition(s). A separate programmatic risk assessment is required for each grant program. Responses should be program-specific. Program Associated with this Risk Assessment: (5310, 5311, 5311(f), 5339) Applicant Completing the Risk Assessment: Individual Completing the Risk Assessment: Contact Information for Individual Completing the Risk Assessment: (Phone and ) Page 1 of 13

2 In response to the requirements of 2 CFR , the NDOT is required to review the programmatic risk posed by applicants. Five risk categories are assessed through this questionnaire: Quality of management systems and ability to meet the management standards 2. History of performance 3. Reports and findings from audits performed under Subpart F-Audit Requirements of this part or the reports and findings of any other available audit 4. The applicant's ability to effectively implement statutory, regulatory, or other requirements imposed on awardees 5. Grants management policy and other compliance requirements Quality of management systems and ability to meet the management standards 1.1. Do you have written policies and procedures that guide program delivery on the topics of? a. Quality assurance b. Outcome tracking and reporting mechanisms c. Relevant documentation of services/goods delivered d. Staff performance management policies and procedures e. Personnel policies and procedures that include conflict of interest statements f. Complaint/grievance resolution policies and procedures g. Governing body policies and procedures that include conflict of interest statements Safeguarding funds, property, and other assets against loss from unauthorized use or disposition Management of grant term extensions, if applicable h. i Do you have internal controls that govern program delivery on the topics of? a. Quality assurance reporting b. Appropriate supervision of staff (for transit staff) c. Unit costs analysis and management 1.3. Does the organization have written standards of conduct covering real or perceived conflict of interest related to actions of employees engaged in the selection, award, or administration of contracts supported by grant awards? 1.4. How many years of experience does the project leader have managing the scope of services required under this program? More than five years One to five years Less than one year Page 2 of 13

3 1.5. Does the organization have a time and effort system that? a. Records all time worked, including time not charged to awards? b. Is signed-off by the employee and a supervisor? c. Includes an approved methodology? Question is not applicable because services are contracted with a third-party provider and rates are based on a set rate or a per unit of service. Go to Question Does the organization have controls for invoicing the grants based on the program cost reimbursement? 1.7. Does the organization apply the same standard for match requirements as it does for expenses? 1.8 To what extent are you able to produce periodic grant status reports to inform the NDOT and stakeholders about program outcomes? Reports are an established part of grant management procedures We re developing reports as part of grant management procedures We do not currently have established reports as part of grants management 2. History of grant performance 2.1. How many years of experience does your organization have with federal grants of comparable scope and/or capacity? More than five years One to five years Less than one year No experience Go to Question 3.3 Page 3 of 13

4 2.2. If your organization has experience with federal grants of comparable scope and/or capacity, provide a brief description of similar project goals and outcomes; specify the applicable year. Page 4 of 13

5 2.3. During your last two fiscal years, how frequently has your organization submitted project performance reports to the NDOT on time? Always Reported late up to three times Reported late four or more times 2.4. Have there been any significant changes in your organization in the last fiscal year related to: a. Leadership change(s) b. Significant program / grant initiative(s) c. Structural changes d. Service changes e. Fiscal changes f. Statutory or regulatory requirements g. Other If other, please explain here: 2.5. Provide a brief explanation for all responses in Question 2.4, (a) through (f). Page 5 of 13

6 2.6. Does the organization utilize a contractor or have a pass-through agreement to manage, administer, or complete the grant project? If no, go to Question What responsibilities does the contractor or pass through organization perform? (mark all that apply) a. On street transportation service delivery b. Turn key transportation operations c. Scheduling and dispatching functions d. Accounting functions e. Performance/Data reporting f. Drug and alcohol program administration g. Financial reporting h. Other If other, please explain here: What percentage of grant funds does the organization pass onto a contractor or pass through organization? None 2.9. Less than 10% More than 20% Does your organization have an implemented policy for contractor or pass through organization monitoring? If yes, does it include (mark all that apply): on-site review % review of prior monitoring desk / quantitative review Do you notify the NDOT to obtain approval or guidance when? a. The scope of the program changes b. A change to the fare structure is planned c. Key personnel change d. The project director disengages for more than 3 months or reduces 25% or more of time devoted to the project A major event has occurred (accident, loss of local funds, employee strike, etc.) e Does your organization have performance measurements that tie to financial data? Page 6 of 13

7 3. Reports and findings from audits performed under Subpart F Audit Requirements of this part or the reports and findings of any other available audit 3.1. During the last two fiscal years, has your organization been out of compliance with programmatic terms and conditions of awards? Organization has not been audited; go to Question 3.6 No occurrences of non-compliance; go to Question 3.6 One to three occurrences of non-compliance Four or more occurrences of non-compliance 3.2. If your organization had at least one occurrence of non-compliance with programmatic terms and conditions, summarize each occurrence. Page 7 of 13

8 3.3. Have corrective actions been implemented within the specified timeframe? 3.4. Please explain for any corrective actions that were not implemented within the timeframe specified and for any corrective actions that remain open. Page 8 of 13

9 3.5. Have there been conflict of interest-related findings within the last two fiscal years? If yes, specify the conflict of interest-related finding and your response to the finding Has your organization been subject to conditional approvals due to program issues? If yes, specify the terms of the special condition and whether the special condition is still applicable. 4. The applicant's ability to effectively implement statutory, regulatory, or other requirements imposed on subrecipients To what extent does your organization have policies to ensure programmatic expenses are reasonable, necessary, and allowable? Policies are implemented and followed Policies are not fully implemented The organization does not currently have these types of policies 4.2. To what extent does your organization have policies to ensure programmatic activities are allowable? Policies are implemented and followed Policies are not fully implemented The organization does not currently have these types of policies Page 9 of 13

10 4.3. Is your organization able to comply with all federal and state statutory requirements of this program? If no, please explain: 4.4. Has the organization been out of compliance with any statutory, regulatory or other requirements of grant funding within the last two fiscal years? If yes, please explain: 4.5. Has the organization adequately resolved all findings resulting from the NDOT subrecipient monitoring review? If no, please explain: Page 10 of 13

11 5. Grants management policy and other compliance requirements 5.1. Does the organization have an FTA compliant Board adopted Title VI plan? If yes, provide date of plan adoption or most recent plan revision Does the organization have a preventative maintenance plan for equipment and real property secured with FTA funds? If yes, provide date of plan adoption or most recent plan revision. 5.3 Does the organization have an FTA compliant drug and alcohol program for safety sensitive transit employees? If yes, provide date of policy adoption or most recent policy revision. T APPLICABLE If not applicable, please explain. Page 11 of 13

12 5.4 Does the organization have a vehicle and equipment replacement plan? If yes, provide date of plan adoption or most recent plan revision. T APPLICABLE If not applicable, please explain. 5.5 Does the organization have a transportation plan? If yes, provide date of plan adoption or most recent plan revision. T APPLICABLE If not applicable, please explain. 5.6 Does the organization have the capacity for compliance with matching requirements and earmarking requirements related to program delivery? Page 12 of 13

13 5.7 Does the organization have the policies and procedures to ensure procurement of goods and services for the program that meet federal and state requirements? If yes, provide date of procurement policy adoption or most recent plan revision. If not applicable, please explain. End of Federal Fiscal Year 2019 Subrecipient Risk Assessment Questinonaire Certification Section My signature below certifies the responses provided are true and accurate and that all known occurrences of non-compliance with programmatic requirements has been disclosed. Authorized Signature Title of Authorized Signer Date Page 13 of 13