When a grantee passes federal funding to a subrecipient who follows through with a project or program, a true partnership is created. Both the grantee and the subrecipient are responsible for proper performance and compliance with the grant activities. Therefore, it’s necessary for the grantee to oversee the performance and compliance of its subrecipients. Grantees do this through subrecipient monitoring as well as through their administration of the programs. The subrecipient monitoring piece of oversight has several layers and starts first and foremost with a strong monitoring plan.
Risk assessment is the initial step in developing a strong monitoring plan. A risk-based approach to subrecipient monitoring for assessing program and project performance has proven to be effective and is now required by the Uniform Guidance for federally-funded projects. The risk assessment provides a framework for prioritizing and scheduling monitoring activities based on the subrecipient’s potential for non-compliance or improper performance. Primary components of the risk assessment should include the subrecipient’s previous experience, audit results, entity personnel, management systems, and results from federal agency monitoring.
On a practical level, elements of a strong subrecipient monitoring plan should also include direct coordination with the subrecipient or contractor, the methodology to be used in the review/assessment, direct reporting of results to appropriate stakeholders, and guidelines for addressing issues noted in the monitoring results such as providing technical assistance or developing corrective action plans. Standardization with monitoring processes provides higher efficiency and ensures a consistent level of oversight. However, monitoring plans must also be flexible enough to allow them to be tailored for the unique compliance and performance requirements for each program or project.
The purpose of the monitoring plan is to provide structure and integrity to this process of grant oversight and support. The monitoring plan maps out the steps to be taken by monitoring staff to review and assess individual programs and projects for proper performance and compliance. An effective monitoring plan is essential to providing grantees with a means to identify weaknesses and issues that could lead to non-compliance or insufficient performance of a federally-funded program.
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