Fillable Subrecipient Program Monitoring Report (City of Pasadena, Texas)

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Subrecipient Program Monitoring Report (City of Pasadena, Texas)

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Subrecipient Program Monitoring Report
Community Development Block Grant (CDBG)
24 CFR 570
Subrecipient:
Sub Agreement/Ordinance No.:
Date of monitoring visit:
Program Monitor(s):
Financial Monitor:
Subrecipient Representative:
Subrecipient Representative:
Subrecipient Representative:
Subrecipient Representative:
Subrecipient Representative:
CDBG Subrecipient Monitoring Report
2
CDBG MONITORING VISIT REPORT
DATE
COMPLETE
CD
INITIAL
1. Subrecipient monitoring letter sent - certified mail
2. Receipt of signed certified mail notice
3. Review contract file
4. Interview program representative
5. Onsite review
6. Exit conference
7. Appendix A – included and complete
8. Report letter prepared – certified mail
A. Approval letter**
B. Letter and finding(s) mailed**
9. Subrecipient's response received
10. CD approval of Subrecipient response (close out)
**Lapse time from line 6 to line 8a and 8b should not be longer than 30 working days.
Check one:
□ Desk Review □ Onsite Visit
Contract Term: __________________________________________________________________________________________
Project Title: ____________________________________________________________________________________________
Subrecipient Name: ______________________________________________________________________________________
Address: _______________________________________________________________________________________________
Phone #: ______________________________________________________________________________________________
Approved Date: _______________________________________ Approved Amount: $______________________________
Date of Last Expenditure Report: __________________________
_________________________________________ ____________________
Program Monitor's Signature Date
_________________________________________ ____________________
Management’s Review Signature Date
**CDBG FINANCIAL MONITORING REPORT IS A SEPARATE DOCUMENT: APPENDIX A.
CDBG Subrecipient Monitoring Report
3
YES
NO
CONTRACT BENEFICIARIES/ NATIONAL OBJECTIVE/
ELIGIBILITY
^How many persons are currently being/were served?
^Is this consistent with the contract?
^Do clients meet a National Objective?
If yes, which National Objective.
^Are activities benefiting persons within Low-Mod Income
category?
If yes, please indicate below:
L/M Income Area Benefit
L/M Income Limited Clientele (circle applicable one)
Presumed Benefit §570.208(a)(2)(i)(A)
51% of clientele L/M §570.208(a)(2)(i)(B) and (C)
Nature and Location §570.208(a)(2)(I)(D)
Serving to remove material/architect. barriers for
severely disabled §570.208(a)(2)(ii)
Limited Circumstance §570.208(a)(2)(iv)
L/M Income Housing
L/M Income Jobs
^What eligibility category does the project meet (570.201-6)?
YES
NO
CONTRACT REPORTING REQUIREMENTS
PROGRAMMATIC
^Client Data Reports submitted in a timely manner? (circle
each month submitted ) Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
^Client Summary Reports submitted in a timely manner? (circle
each month submitted) Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
^Duplicate Client Data Report submitted in a timely manner?
(circle each month submitted) Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
^For Economic Development projects, Employee Data Reports
submitted in a timely manner? (circle each month submitted)
Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
CDBG Subrecipient Monitoring Report
4
^Bi-Annual/ Annual Performance Reports submitted in a timely
manner? (circle each submitted) Explain.
1
st
Six Months 2
nd
Six Months Annual Performance
Report
^Were the above submitted reports complete and accurate?
Explain.
Does the Subrecipient maintain these reports onsite for
review?
FINANCIAL (programmatic)
^Request for Payment (and supporting documentation)
submitted in a timely manner? (circle each month submitted)
Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
^Time and Attendance Sheet submitted in a timely manner?
(circle each month submitted) Explain.
Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept
^Were the above submitted reports complete and accurate?
Explain.
Does the Subrecipient maintain these reports onsite for
review?
YES
NO
CONFORMANCE TO SUBRECIPIENT AGREEMENT
^Is the full scope of services listed in the Agreement being
undertaken? List any deviation.
^Compare actual accomplishments at the point of monitoring
with planned accomplishments. Is the project achieving the
expected levels of performance (number of persons served,
number of units rehabbed, etc.) and reaching the intended
client group? Explain any problem the subrecipient may be
experiencing. Acknowledge major accomplishments.
^Is the work being performed in a timely manner (i.e., meeting
the schedule as shown in the Agreement)? Explain.
^Compare actual expenditures versus planned expenditures.
Do they match? Note any discrepancies or possible deviations.
^Are requests for payment consistent with the level of work
accomplished? Explain.
CDBG Subrecipient Monitoring Report
5
Is program income properly accounted for and recorded?
Explain.
Does the project conform to any special terms and conditions
included in the Subrecipient Agreement? Explain.
YES
NO
ADMINISTRATIVE REQUIREMENTS
Does Subrecipient maintain personnel records for all persons
paid with CDBG funds provided by COP CD? (Review 1099,
W-2 and timesheet/payroll reports)
Does Subrecipient have documentation stating it is an Equal
Opportunity or Affirmative Action Employer? Note
documentation reviewed.
Is appropriate EEO and/or Fair Housing signage in place easily
visible by employees and visitors?
Does the Subrecipient accept all otherwise eligible clients
regardless of race, ethnicity, age, gender, disability? Explain.
Is documentation maintained ensuring compliance with faith-
based organization, requirements? (if applicable) Note
documentation reviewed and any discrepancies.
Have any personnel employed in the administration of the
CDBG-funded program been used for political activities,
sectarian or religious activities, lobbying, political patronage,
and nepotism activities? If yes, explain.
Is Subrecipient operating program in compliance with OSHA
requirements, if applicable? Note documentation reviewed.
Does the Subrecipient have a Section 3 policy? (Applicable to
construction projects) Review policy against HUD Section 3
clause.
Is Subrecipient adhering to the “Section 3 Clause” of the HUD
Act of 1968? (if applicable) Note any documentation reviewed
and any deficiencies.
Is documentation maintained for Conflict of Interest, if
applicable? Note documentation reviewed or if N/A.
Does Subrecipient have a copy of contract to reference?
CDBG Subrecipient Monitoring Report
6
YES
NO
PROGRAM MANAGEMENT AND RECORDKEEPING
Does the Subrecipient maintain an application file? Note
documents included in file.
Does the Subrecipient maintain a project file? Note documents
included in file.
Does the Subrecipient maintain client files? Note documents
included in file.
Does the Subrecipient maintain property files? (if applicable)
Note documents included in file.
Are files orderly, comprehensive, secured for confidentiality
where necessary, and up-to-date? Note any areas of
deficiency.
Do the client files and subrecipient reporting records have the
necessary documentation (supporting the National Objective
being met, eligibility, and program costs) and do they agree?
Note any deficiencies.
Does the Subrecipient have a program procedure manual?
Are there administrative policies and procedures in place? Note
any deficiencies.
Are there financial policies and procedures in place? Note any
deficiencies.
Are there programmatic and client policies and procedures in
place? Note any deficiencies.
Is there a file retention policy?
If so, is it being adhered to? Explain.
Does the record retention policy coincide with COP CD
requirement of 5 years? Note length of time in policy.
Retain copies of pertinent documents for COP CD file
Specific Records to Verify are being Maintained
Are records maintained describing each activity undertaken?
CDBG Subrecipient Monitoring Report
7
Do records maintained demonstrate each activity undertaken
meets a national objective?
Are records maintained documenting participant income? (if
applicable)
Are records maintained documenting compliance with the fair
housing and equal opportunity components of the CDBG
Program? (if applicable)
Are real property inventory records, which clearly identify
properties purchased, improved, or sold, maintained? (if
applicable)
Are copies of monthly programmatic and financial reports
submitted to COP CD retained?
See Contract Reporting Requirements above.
YES
NO
INSURANCE
^Has the subrecipient submitted a current copy of its Certificate
of Insurance?
^Is the City named as an additional insured?
YES
NO
EQUIPMENT AND REAL PROPERTY
^Has the Subrecipient acquired or improved any property it
owns in whole or in part with CDBG funds in excess of
$25,000?
If yes, review for 570.503(b)(7). Note any issues.
^Has Subrecipient purchased equipment with CDBG funds in
excess of $1,000?
If yes, does Subrecipient maintain the records required by
84.34?
Has the Subrecipient disposed of equipment or property in the
last 5 years that was purchased with CDBG funds?
If yes, were proceeds for the sale reported as program
income?
^Did the City approve expenditures of program income?
Was the program income returned to the City?
CDBG Subrecipient Monitoring Report
8
YES
NO
OTHER MONITORING AREAS
CONFIDENTIALITY
Are systems in place that ensure the confidentiality of persons
provided services for family violence treatment prevention,
homeless services, etc? Explain.
TERMINATION OF PROGRAM ASSISTANCE
Is there a formal process in place that recognizes the rights of
individuals receiving assistance to due process of law when
terminating assistance? Explain.
GRIEVANCE PROCEDURE
Does the Subrecipient maintain a formal complaint procedure
as required by the agreement?
Is this procedure in writing and does is comply with the COP
CD Grievance Procedure requirements? Note any deficiencies.
Are participants made aware of this procedure? Is it posted or
is provided upon entry into the program? Specify.
SECTION 504
Has the Subrecipient completed a Section 504 self-assessment
(disability access)? Note discrepancies between what is known
about the facility(ies) and what is noted in assessment.
Does the facility where assistance/services are provided meet
accessibility requirements of 24 CFR 8.21(c)(2)? Note
deficiencies.
LABOR STANDARDS
Were required labor standards requirements and guidance
included in applicable subrecipient contracts?
Were labor standards properly enforced? Review a sample of
Davis Bacon payrolls, HUD-11 interview forms, Other
Deductions forms, etc., to ensure adequate review was
performed and any required restitution was paid. Note any
discrepancies.
GRANTOR RECOGNITION
Does the subrecipient maintain a “recognition file” as required
by the subrecipient contract? Note documentation contained in
file.
CDBG Subrecipient Monitoring Report
9
Do program brochures/marketing materials recognize City Of
Pasadena as a funding source? Explain.
CONFLICT OF INTEREST
^Does the Subrecipient have a conflict of interest disclosure
form filed with City of Pasadena?
Does there appear to be any apparent or real conflict of interest
that has not been disclosed by the subrecipient?
PROGRAM CHANGES
^Have any significant changes been made to the program? (i.e.
staff changes, budget revisions, scope of services)
Were changes approved by COP CD?
Does Subrecipient maintain documentation of COP CD
approval of applicable amendments/revisions to Subrecipient
Agreement? (if applicable) Note documentation reviewed.
**** Final Confirmation of Documentation
Does supporting documentation exist in all files reviewed for
each of the above questions? If not, please note.
CDBG Subrecipient Monitoring Report
10
PROGRAMMATIC MONITORING SUMMARY: (Is the subrecipient meeting the terms of the Subrecipient
Agreement and HUD regulations? Discuss both positive conclusions and any weaknesses identified.)
FINDINGS OR CONCERNS: (Note areas that require follow-up action.)
CORRECTIVE ACTIONS: (List the required actions, a schedule for implementing corrective actions or making
improvements and schedule for any needed technical assistance or training.)
_________________________ ________________
Program Monitor’s Signature Date(s) Reviewed
^ Indicates items that can be reviewed as a desk audit prior to performing an onsite monitoring. If desk
audit reveals that further testing is necessary, determine what issues have arisen to cause any
discrepancies. Items should be verified onsite.
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Subrecipient Program Monitoring Report (City of Pasadena, Texas)

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Completed 25 February 2021

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