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Grant Administration - Monitoring & Auditing

Monitoring

The GLO ensures program compliance based on a risk analysis. In addition to the day-to-day oversight activities and review of information submitted, GLO staff schedule topic-specific reviews both via desk review and in the field. The result of these reviews is a written report detailing the specifics of the review and any needed improvements or corrective action necessary by the grantee or subrecipient.

Throughout the life of any CDBG-DR grant, the GLO will conduct monitoring efforts on subrecipients, Contractors and itself to ensure compliance with federal regulations, prevent fraud, waste, and abuse, and identify places of improvement. Each subrecipient should also implement monitoring plans for any CDBG-DR funds administered at a local level.

Monitoring review activities are conducted to meet the following objectives:

  • Review performance - A subrecipient’s or service provider’s performance will be monitored to ensure that activities have been performed and beneficiaries are served in accordance with a contract’s Performance Statement and that funds have been expended as identified in the budget.
  • Review contract records for compliance - A subrecipient’s or service provider’s performance will be monitored to ensure compliance with GLO-CDR requirements, as outlined in the contract and other applicable state and federal rules, regulations, policies, and related statutes.
  • Prevent fraud and abuse - A subrecipient’s or service provider’s systems and other policies and procedures used to administer GLO-CDR funds will be monitored to ensure that adequate protections against fraud and misuse of funds are in place.
  • Identify any necessary corrective actions - A review could result in prescribed corrective measures to be carried out by the subrecipient or service provider.
  • Identify technical assistance needs - A review may reveal a need for areas requiring additional technical assistance from grant management.

Recurrent unsatisfactory performance and delays in submitting responses to monitoring reports may affect a subrecipient’s or service provider’s eligibility to apply for future CDBG-DR funding.

Program files will be open for inspection to GLO or any of its duly authorized representatives, or funding source representatives. In addition to monitoring which may be performed by the GLO-CDR, HUD, HUD-OIG and other entities may, at their discretion, perform monitoring or audits over entities receiving CDBG-DR funding. Additional information related to monitoring performed by HUD and HUD OIG can be found at the following locations:

For additional HUD resources regarding monitoring activities visit:

Auditing

GLO audit requirements are mandated by 2 CFR 200 Subpart F – Audit Requirements. GLO holds each subrecipient responsible for all funds expended.

Single Audit

As defined in 2 CFR 200 Subpart F, any non-federal entity expending $750,000 or more in Federal Awards must have a single audit conducted in accordance with 2 CFR 200.514 unless it elects to have a program-specific audit.

Note: A subrecipient expending less than $750,000 a year in federal awards is exempt from the Single Audit requirements for that year. However, records must be available for review or audit by appropriate officials of the Federal agency, and the pass-through entity.

Program-Specific Audit Election

Applicable to subrecipients when Federal awards are expended under only one Federal program, and a financial statement audit is not required by the program’s statutes, regulations, or terms or conditions of the Federal award.

It is the responsibility of each subrecipient to ensure that a Single Audit or Program Specific Audit, if required, is submitted to the Federal Audit Clearinghouse (FAC) database as detailed in 2 CFR 200.512. The FAC is operated on behalf of the Office of Management and Budget and can be accessed through the following website: https://harvester.census.gov/facweb/

Housing Quality Assurance Overview

Throughout the construction process, CDR Quality Assurance staff will monitor the various inspections done by the Subrecipients to ensure that they are being done on time, they are being done thoroughly and all necessary documentation is in order. In addition, the Construction Quality Assurance Team will use the results of the inspections to track builder performance and to make recommendations as to quality and process improvement. Each project will require an inspection(s) during the lifecycle of the project. The required inspections are dependent on the activity type (ex: Reconstruction, Rehabilitation, etc.), which are outlined in the Housing Guidelines. Further details regarding the inspections are included in the specific activity types in title H. Housing Project Activity Types of the Housing Guidelines.


Instances of fraud, waste, and abuse should be referred to the HUD OIG Fraud Hotline (phone: 1–800–347– 3735 or email: hotline@hudoig.gov).