risk analysis so how do we choose who gets monitored? hq gives each field office a monitoring goal...
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Risk Analysis
So how do we choose who gets monitored?
HQ gives each Field Office a monitoring goal they must meet.
Each year HUD reviews all of its grantees and scores them on certain risk factors to determine who will be monitored in that year.
Risk AnalysisFactors that are reviewed
1.) Financial
2.) Physical
3.) Management
4.) Satisfaction
5.) Services
Monitoring Work Plan Field Office creates a Work Plan based
on the Risk Analysis
Monitoring reviews are tentatively scheduled for the year
Most reviews are done on-site, however sometimes remote reviews are conducted.
Monitoring Exhibits
The HUD monitoring manual includes six possible checklists that can be used to review S+C grants.
Project ProgressS+C HousingS+C ClientsS+C Match DocumentationS+C Subrecipient ManagementS+C Overall Grant Management
Other Federal Requirements Lead Based Paint
Visual assessmentsLead Pamphlet
Civil Rights/Fair HousingAffirmative marketingCollection of demographic dataAccessibility
File Sampling
Normally, HUD staff will
Request a list of all participants from a certain time period
Select a sample of files from that list to review
However, HUD can expand the file sample if needed.
Staff Interviews In addition to file reviews, HUD staff will
also likely interview staff to discuss the program.
Each program is different but common staff interviewed include:Executive DirectorProgram DirectorHousing SpecialistFinancial Officer/AccountantCase Manager
Areas of emphasis
Client eligibility and Service provision Unit Inspection and Rent Calculation Draw Review Program Administration and Due
Process
Client Eligibility and Services Eligibility
Homeless documentationDisability documentation
Services AppropriateOngoing needs assessmentAdequate match amount provided
Unit Inspection and Rent Calculation Unit Inspection
HQS inspection done
Rental Calculation and documentation
Contract Rent - Tenant Contribution = S+C Subsidy
Contract rent is based on rent reasonablenessTenant contribution is based on income
Draw reviews
Sometimes HUD staff will select a few draws from LOCCS for review
We would be looking for Adequate source documentation
for the draw amountSound overall financial
management
Program Administration Written procedures or program
guidelinesIncluding participant termination due
process policies
Grantee-Sponsor communication and division of duties
Administration costs and documentation
After the visit Exit Conference
Discuss the results of the review and likely outcome
Monitoring LetterHUD has 45 days after the exit conference to
send out a letter that details the results of the review and any findings and correction actions
Monitoring ResponseNormally HUD requests a response to the
monitoring letter within 30 days (if there are findings to resolve)
Findings vs Concerns
FindingDeficiency based on a statutory, regulatory
or program requirement for which sanctions or other corrective actions are authorized. Grantee MUST respond to findings.
ConcernPotential deficiency or performance issue
that could lead to future finding. Sanctions or corrective actions are not authorized for concerns.
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