This policy is designed to establish the techniques and procedures to properly prepare, comply, and cooperate with any inspections, reviews, investigations, or audits deemed necessary. Grants awarded by the federal government are subject to on-site monitoring and/or audits. This policy applies to all employees, officers, and contractors doing business with the GBPLD.
Pre-Monitoring
In preparation for the reviews, the Director of Grants will perform the following pre-monitoring tasks:
- Become thoroughly familiar with the program;
- Develop a clear understanding of the governing statutes, regulations, and official guidance.
- Review and analyze reports, available data, and financial information, from previous monitoring reports and issues;
- Determine the programs/areas/functions to be reviewed;
- Determine the data or information to be submitted prior to monitoring (if any);
- Prepare the staff members who will need to be consulted during the monitoring; and
- Finalize the schedule for conducting the monitoring tasks and the anticipated time frames.
On-Site Monitoring
On-site reviews involve monitoring overall program administration and can include examining information and materials provided to the awarding agency by GBPLD to track performance and identify potential problem areas. The monitoring event is designed to assess and document compliance with the requirements based on:
- File reviews to determine the accuracy of the information, using both automated and manual data and reports submitted by GBPLD; and
- Interviews with staff to clarify and determine the accuracy of the information.
The documents reviewed include activity status reports, if applicable, monthly review of the project schedule, monthly project updates, and financial information to assess performance and look for indicators of performance or compliance problems. In addition, GBPLD may submit progress reports that include the activity showing the progress, accomplishments, barriers, and spending patterns against planned activities and accomplishments.
Post-Monitoring
At the end of the review, the monitoring agency will provide GBPLD with a formal written notification of the results of the monitoring review. The letter will outline any concerns, findings, recognize successes, and the deadline for a written response to correct actions. An important and fundamental principle of the monitoring process is the documentation of deficiencies when there is evidence that a statute, regulation, or requirement has been violated but it retains discretion in identifying appropriate corrective action(s) to resolve deficiencies. An equally fundamental principle is that GBPLD has a process to respond to and resolve deficiencies.
Identified monitoring deficiencies require corrective action. The corrective action responsibility rests both with the awarding agency and GBPLD. GBPLD has a responsibility to determine, or assist the awarding agency in determining, the reason a requirement was violated or provide evidence of compliance.
A key piece of effective monitoring is the ability to identify the root cause(s) of any identified deficiencies, or whether the problem is an isolated occurrence or systemic. Such knowledge leads to the development of optimal corrective actions. In some cases, GBPLD may need to determine appropriate action if compliance is not possible.
Board Approved 5/14/2024