Subgrantee Monitoring and Risk Assessment Principles Leslie O Reilly, VOCA Program Specialist
DIVISION OF VICTIM SERVICES CRIME VICTIM SERVICES COMMISSION Assistance, Services and Aid to Crime Victims
NON TAX DOLLARS Victims of Crime Act (VOCA) Federal Crime Victims Fund Crime Victim Compensation Act Federal Fines and State Assessments Crime Victim Rights Act State Assessments
Crime Victim Compensation Direct assistance to individuals Last Resort for unpaid medical bills, loss of earnings, burial costs, counseling needs Crime Victim Assistance Federal pass through funds Competitive grants to local public or non profit agencies to provide direct services Training of professionals Crime Victim Rights and Assessment Revenue Funds to support Crime Victim Rights Activities Grants to prosecuting attorneys and juvenile courts MI VINE notification Train advocates
VOCA GRANT AWARDS IN MICHIGAN FY 2016 86 Grants to 86 agencies $18,728,777 Allocated FY 2017 128 Grants to 109 agencies $30,204,184 Competitive FY 2018 Allocated $32.4 Million in grants FY 2018 2 RFP s $4.1 Million in grants 5
FY 2019 VOCA GRANT RFP S IN MICHIGAN Services to victims of Elder Abuse Tribal Victim Services Supervised Visitation Children s Advocacy Center Development UP Sexual Assault and SART Sexual Assault Nurse Examiner Campus Sexual Assault Services 6
Future RFPs Human Trafficking Housing Services 7
THINGS THEY ARE A CHANGING 2/2015 MERGER OF TWO STATE DEPARTMENTS STAFF RETIREMENT, RESIGNATION, HIRING, TRANSFERS, NEW STAFF 9/2015 VOCA 2015 AWARD $$$ 1/2016 MOVE OFFICES TO NEW BUILDING 7/2016 NEW VOCA RULES OCFO AUDIT 9/2016 DEPARTMENT GRANTEE MANAGEMENT AND MONITORING POLICY OVC AUDIT CHANGE IN AUDIT MANAGER SINGLE AUDIT SIGNIFICANT TURNOVER IN VICTIM SERVICE LEADERSHIP 8
MDHHS Plan / Outline I. September 2016 II. New Policy III. Risk Assessment Tool IV. Monitoring Activities Menu V. Monitoring Plan Development 9
PROGRAM OFFICES WERE TRAINED Good Business Practice! 2 CFR 200.331 requires: (b) Risk Assessments (d) Minimum Monitoring (e) Other Monitoring Depending Upon Assessed Level of Risk Proposal to comply Learn about policy Learn about required risk assessments / required monitoring Applicable to Grant Awards to Grantees Award provided to a grantee (subrecipient or recipient) for grantee to carry out a project or program to address a public benefit for the greater good. DOES NOT include payments to contractors under procurement contracts Program may have ADDITIONAL monitoring requirements Check Grant Award Notification / Regulations / Policies specific to your program 10
What is 2 CFR 200? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Replaces former: Administrative Requirements (A-102, A-110, A-89) Cost Principles (A-87, A-122, A-21) Audit Requirements (A-133, A-50) Applicable to FEDERAL awards granted AFTER 12/26/2014 Joint Interim Final Rule (12/19/14) (79 FR 75867) Federal Awarding Agencies adopted guidance May have made changes see exceptions at: https://cfo.gov/wp-content/uploads/2014/12/agency-exceptions.pdf 11
OMB Circular A-133 (Prior Requirement).400 (d) (3) Pass-through entity responsibilities Monitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. A-133 Compliance Supplement gave guidance on monitoring. 12
2 CFR 200.331 All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). 13
2 CFR 200.331 All pass-through entities must: (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by 200.521 Management decision. 14
2 CFR 200.331 All pass-through entities must: (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on programrelated matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in 200.425 Audit services. 15
Grantee Monitoring and Management Policy APA 212 Distributed for Comment 8/15/2016 --- Effective 9/1/2016 Significant Definitions: Grant Award federally AND non-federally funded Grantee agency receiving grant award as recipient or subrecipient Recipient agency receiving a grant award that s not federally funded Subrecipient agency receiving a grant award that s federally funded Subaward grant award that s federally funded (term used in 2 CFR 200) 16
Grantee Monitoring and Management Policy APA 212 Policy Section General list for involved parties: Bureau of Purchasing (also administers grants management system) Bureau of Audit Program Offices: Determine Subrecipient/Recipient/Contractor Perform Risk Assessments Annually Develop Monitoring Plan Perform Monitoring Activities 17
Grantee Monitoring and Management Policy APA 212 Procedure Section More specific details related to: Relationship Determinations Grant Award Content Grantee Risk Assessments Grantee Monitoring Plan Grantee Monitoring Highlights of each of the above follow 18
Grantee Monitoring and Management Policy APA 212 Relationship Determinations Program Offices make determinations Grant Agreement V. Procurement Contract Determination Form Grant Award Content Purchasing makes sure subaward content meets requirements of 2 CFR 200.331(a) Program Offices make sure special requirements are incorporated. VOCA GRANT REQUIREMENTS ARE ATTACHMENTS TO THE STANDARD AGREEMENT. 19
Grantee Monitoring and Management Policy APA 212 Grantee Risk Assessments Audit providing tool that includes items to consider from 2 CFR 200 Program Offices ANNUALLY assess each grantee s risk of noncompliance Program Offices categorize grantees in risk categories. Grantee Monitoring Plan Program Offices ANNUALLY develop a monitoring plan based off risk assessment Include minimum required monitoring Include additional monitoring based on level of risk Specifically identify activities in plan 20
Grantee Monitoring and Management Policy APA 212 Grantee Monitoring Audit providing monitoring activities menu and guidance Program Offices perform monitoring and document monitoring Minimally: Review required reports Follow up on deficiencies and ensure corrective action Program specific monitoring Additional monitoring based on risk assessment: Training and technical assistance Desk reviews On-site reviews Arranging agreed-upon-procedures engagements 21
Risk Assessment Tool Grantee Risk Assessments/Monitoring 22
Risk Assessment Tool Overview Just a recommended template Can use your own form as long as it meets the requirements of 331(b) Additional risk factors can be added 13 Columns 9 columns are risk factors that you select the appropriate score 3 columns for entering the identifying information for each of your grant awards 1 column (total risk score) is automatically calculated Avoid altering the formulas! Double-check the math! Written Instructions are available 23
Risk Assessment Tool Identify your Administration Be sure to type in the appropriate name of your Administration and Program. Be sure to specify the correct year 24
Risk Assessment Tool Grantee, Grant Award, Award Amount Each Grant Award will be entered onto one line in the tool You may have multiple entries for the same Grantee if they have multiple awards. Grantee Name Enter the Grantee s full legal name Grant Award Number Enter the unique grant identification number for each award Grant Award Amount Enter the full amount of the grant award 25
Risk Assessment Tool Risk Factors The Risk Assessment tool comes pre-populated with nine common risk factors and scores for each factor have been built into the tool Simply requires the user to click on the appropriate answer for each question. Definitions for each risk factor are included in the Risk Definitions tab of the tool, by Hold and Hover on the risk factor title, or by clicking the hyperlinked risk factor title. If you would like to add additional risk factors add them to your risk assessment tool. 26
Risk Assessment Tool Total Dollar Amount Total dollar amount is intended to help you capture any significant differences in the dollar value of your grants. You set your own criteria for what is Large, Medium, or Small Based on the dollar amounts of your grants. 27
Risk Assessment Tool Previous Grant Experience Grant Programs may have requirements that are unique. Grantees that have less experience with a particular grant program may be of higher risk due to the lack of familiarity with grant specific requirements. 28
Risk Assessment Tool Financial and Compliance Monitoring Grantees not audited or subjected to an MDHHS monitoring review are typically higher risk than those that have. BARQA is working on a report that will help you with identifying if the grantee had a single audit and if your programs were tested as a major program. 29
Risk Assessment Tool Frequent Turnover of Staff Grantees that have a high staff turnover rate may encounter issues with consistency of operations related to your programs and are typically considered a higher risk. If you are aware of higher than normal turnover, you should select Yes If you are not familiar enough or don t know of any issues, select No 30
Risk Assessment Tool Other Issues of Noncompliance Over the course of a grant, you may become aware of other issues a grantee is having that would make them a higher risk. Maintain documentation to support your concern. 31
Risk Assessment Tool Financial Management Problems or Issues Grantees at risk of insolvency, with known financial management issues, frequent tardiness in submitting expenditure reports, etc. are considered a higher risk than those without these issues. May be identified through an independent audit or through your own monitoring activities. 32
Risk Assessment Tool Significant Findings or Questioned Costs If the grantee did have findings and/or questioned costs related to your grants, they should be considered a higher risk than those that did not. If a grantee did not have an audit performed select No. 33
Risk Assessment Tool Recurring or Unresolved Issues Grantees that are unable to correct known issues in a timely manner should be considered a higher risk than those that are able to implement corrective actions. If you are aware of previously identified issues that have not been corrected over the course of a full audit or review cycle, select Yes. 34
Risk Assessment Tool Programmatic Noncompliance Grantees who have been found in noncompliance with the programmatic requirements of their grant in the past should be considered a higher risk than those that have not. 35
Risk Assessment Tool Total Risk Score Automatically calculated based on your answers to the nine risk factors. Not intended to be an absolute score. Provides a guideline for completing your Annual Monitoring Plan. Do not enter any information into this column. This is the number that you will copy to the Monitoring Plan. 36
Monitoring What is Monitoring? Anything that provides assurance that the Grantee is in compliance with the provisions of their Grant Award. Programmatic AND Fiscal Anything that answers the questions: Did we get what we paid for? Did the Grantee do what they were supposed to do? 37
Monitoring Activities Menu Menu of 9 Monitoring Activities May be Other Monitoring Activities Not on the List Must perform items 1 3 Choose Other Activities Based on Assessed Level of Risk Guidance on Each Document, Document, Document! 38
Monitoring Plan Template will be available www.navaa.org Grantee Risk Assessments/Monitoring 39
Monitoring Plan Not required to use this tool. May already have a tool that meets the requirements. However You are required to: Annually, develop a monitoring plan based on the results of the risk assessment. The monitoring plan will include the minimum required monitoring elements for each grantee and other additional monitoring for grantees based on the level of identified risk. The activities to be performed for each grantee will be specifically identified in the monitoring plan. Just a Plan, subject to change and should be updated throughout the year. Allows you to allocate your resources effectively based on the results of your risk assessment. 40
Monitoring Plan Overview 15 Columns 3 columns for identifying the grant award, grantee, and associated risk score from your risk assessment. 4 columns for planning fiscal monitoring activities. 4 columns for planning programmatic monitoring activities. 2 columns for pre-award monitoring. 2 columns for technical assistance. There are no formulas, everything is to be entered manually. Written instructions are available. 41
Monitoring Plan Identify your Administration Be sure to type in the appropriate name of your Administration and Program Be sure to specify the correct year 42
Monitoring Plan Grant Award, Grantee, Risk Score Enter each of your grant awards onto one line and include the corresponding risk score from your risk assessment. You may choose to sort by risk score, highest score to lowest. 43
Monitoring Plan Resources Before continuing with the Monitoring Plan, you will need to determine the amount of resources that you will be able to dedicate to monitoring over the course of the calendar year. Typically done using number of hours. No minimum required number of hours. Allocation of your hours should be based on: 1. Any Federal, State, Departmental mandated monitoring activities specific to your programs. (Remember items 1-3 of the monitoring menu are required!) 2. Your Risk Assessment results. 44
Monitoring Plan Physical Location of Monitoring Activities If you are going to perform the monitoring activities at the grantee s place of business, often referred to as onsite monitoring, then the monitoring activities should be placed in the At the Grantee s Office column. If you are going to perform the monitoring activities at your MDHHS place of business, often referred to as Desk Monitoring, then the monitoring activities should be placed in the Not at the Grantee s Office column. This is important to differentiate as you complete the plan because the 45 two different types most often consume different levels of resources.
Monitoring Plan Actions Actions indicate the types of monitoring activities that you plan on performing for each grant award. Use the Monitoring Activities Menu and enter the corresponding number for each monitoring activity you plan on performing for that grantee (remember 1-3 are required!) 46
Monitoring Plan Hours Hours should indicate the total number of hours you think it will take to complete all of the monitoring actions you indicated. Again, just a plan and your best projection based on your past experience. If possible, if any hours are left over after completing your mandatory monitoring activities, the remaining hours should be allocated based on your risk assessment scores with higher risk grant awards receiving more monitoring than those with lower scores. 47
Monitoring Plan Monitoring Categories Fiscal Monitoring Any set of activities designed to determine compliance with fiscal requirements. Programmatic Monitoring Activities designed to determine compliance with program requirements Pre-Award Monitoring Functions involved with the development and awarding of a grant to a grantee. Technical Assistance Assistance provided to grantee to assist in compliance with grant requirements. 48
SUBRECIPIENT QUESTIONNAIRE REQUIRED BY DEPARTMENT COMPLETED ANNUALLY ATTESTED TO CURRENT STATUS 49
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SPECIAL CONDITIONS ATTACHMENT G VOCA Crime Victim Assistance Grant Program PERFORMANCE / PROGRESS REPORT REQUIREMENTS FY 10/1/2017 9/30/2018 The purpose of this attachment is to impose additional special conditions on this Agreement. The Executive Director will continue reporting on a bi-weekly basis, beginning October 6, 2017, to the MDHHS team the status of the investigation and include chronological updates until the resolution of this matter. Provide updates on: Summary of issues Summary of impact to awards (amount of impact by funding source) Forensic Audit Insurance Claim Criminal Case 52
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Statement of Independence 54
TOOLS WILL BE AVAILABLE ON THE NAVAA WEBSITE POLICIES AND PROCEDURES RISK ASSESSMENT TOOL RISK ASSESSMENT TOOL INSTRUCTION SUBRECIPIENT QUESTIONNAIRE MONITORING PLAN MONITORING PLAN INSTRUCTIONS VOCA ON SITE PROGRAMMATIC CHECKLIST DE MINIMUS CALCULATION WORKSHEET AUDIT PROGRAM FOR ON SITE AUDITORS AVAILABLE UPON REQUEST 55
DV/SA PEER REVIEW program and compliance with programmatic www.michigan.gov/domesticviolence Standards review site visits are a unique blend of technical assistance, support and monitoring. The overall goal is to meet the highest standards of excellence in addressing the issues of violence against women, especially as related to providing support and assistance for survivors and strong nonprofit administration. Other goals are to build community between agency leaders and ensure consistency in response across the state. It is a peer review process that relies on teams comprised of individuals currently working in sexual assault and domestic violence service agencies and those from the field with direct and related experience, The standards peer review process, including writing the standards and instituting site visits, was identified and implemented by leaders within the Michigan domestic and sexual violence movements. 56
CONTACTS Leslie O Reilly VOCA Program Specialist Crime Victim Services Commission Grand Tower, Suite 1113 235 S. Grand Avenue P.O. Box 30037 Lansing, MI 48909 1-517-241-5249 oreillyl@michigan.gov www.michigan.gov/crimevictims 57
Questions? 58