Sub Recipient Monitoring
The Governor’s Office of Homeland Security and Emergency Preparedness (GOHSEP) is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of federal program funds.
GOHSEP receives funding on behalf of the State of Louisiana through the Public Assistance (PA), Hazard Mitigation (HM) Grant Programs (Disaster and Non-Disaster Mitigation Assistance) and Preparedness grant programs (EMPG and HSGP: SHSP, UASI, OPSG, etc.) from the Federal Emergency Management Agency, an agency of the U.S. Department of Homeland Security and other federal grant programs.
OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) ("Uniform Guidance"), specifically sections §200.330 and §200.331, requires prime recipients of federal funds to monitor subawards and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award. This Subrecipient Monitoring Program/Procedures applies to all subawards issued under programs made to the GOHSEP, without regard to the primary source of funding.
Why Monitoring?
- Reduce risk of de-obligation in current disasters.
- Assist with compliance deficiencies so future audits and closeouts are a smooth process.
- Prepare for future events.
GOHSEP's Sub Recipient Monitoring (SRM) Section performs two types of monitoring Desk Reviews and Monitoring Visits.
Desk Reviews
A desk review is a monitoring activity implemented for all Subrecipients subject to the 2 CFR Subpart F audit requirements regardless of their risk category (high/moderate/low). Desk reviews are composed of a review of the subrecipient’s single audit reports for their most current fiscal year completed.
The single audit is a requirement to procure an audit for Subrecipients expending more than $ 750,000 per year in federal funds, in total of all grant programs. In addition, if at least $0.01 was spent with GOHSEP grant funds, GOHSEP (as the pass-through agency) is required to obtain the single audit report, review and issue a decision on remediation plans for each finding that impacts the Public Assistance, Hazard Mitigation, and Preparedness grant Programs.
If a subrecipient expends $750,000 or more per fiscal year in federal funds:
- GOHSEP must ensure they are in compliance with 2 CFR 200.330 and 200.331.
- Each subrecipient must provide a copy of the audit report, incompliance 2 CFR 200.330 and 200.331 to the following:
If the audit report is not received in a timely manner, the SRM section will inform the GOHSEP federal pre-award section(s), and the proper course of action will be determined on the subrecipient.
If the documentation indicates instances of non-compliance with federal laws and regulations affecting the subcontract issued by GOHSEP, the SRM Section will contact the subrecipient and inform them that they need to provide evidence of corrective action. The SRM Section will maintain a current listing of all subrecipients from which corrective action is expected and ensure that follow-up occurs on a timely basis. If the subrecipient fails to establish that corrective action has been taken, the SRM Section will inform the appropriate federal pre-award section(s) and the proper course of action will be determined. In noted instances of non-compliance, the SRM Section will maintain documentation of action taken and the results of such action.
Monitoring Visit
GOHSEP, as the grantee or recipient for federal grant programs, is responsible for monitoring awards made to subgrantees to provide reasonable assurance that the award is being administered in compliance with federal grant guidance and terms of the subgrantee agreement. Monitoring visits are one form of monitoring conducted by GOHSEP. If selected to receive a monitoring visit, a subgrantee should plan for a project/program management and financial review. To ensure a successful monitoring visit; a project manager, finance representative (knowledgeable of the agencies policies and procedures) and a property control representative should be present.
Monitoring notification letters are sent approximately 30 days in advance. A list of items (such as financial documents, project files, policies and procedure manuals, overtime policies, etc.) to have present during the monitoring visit will be included in the notification letter. Program or project files should be available during the monitoring visit. The monitoring visit is intended to assess a subrecipient's processes and procedures to achieve the intended outcomes of the grant award. In addition, it is an opportunity to provide technical assistance that may further enhance support to local jurisdictions in their grant administration as well as improve stakeholder relationships.
How is a subrecipient chosen for a monitoring visit?
Subrecipients are chosen for a monitoring visit by an Annual Risk Assessment process, which includes the following indicators.
Risk Indicators:
- Financial+ Operational+ Compliance
- Rated as low, moderate, or high risk to GOHSEP.
What to expect after a Desk Review and/or Monitoring Visit?
