managing vets competitive grants

MANAGING VETSMANAGING VETSCOMPETITIVE GRANTSCOMPETITIVE GRANTS

VETERANS’ EMPLOYMENTVETERANS’ EMPLOYMENT ANDAND

TRAINING SERVICETRAINING SERVICE HVRP & VWIP GRANTSHVRP & VWIP GRANTS

ASPECTS OF HVRP/VWIP ASPECTS OF HVRP/VWIP GRANTSGRANTS• SolicitationSolicitation

• ApplicationApplication

• Notice of AwardNotice of Award

• Grant Law & Grant Law & RegulationsRegulations

• Oversight Oversight ResponsibilitiesResponsibilities Quarterly Desk Quarterly Desk

ReviewReview Annual On-Site Annual On-Site

ReviewReview Technical Technical

AssistanceAssistance

GRANT LAW & GRANT LAW & REGULATIONS REGULATIONS

SOLICITATION

OVERSIGHT

REPORTING REQUIREMENTS

NOTICE OF AWARD

APPLICATION

SOLICITATION OF GRANT SOLICITATION OF GRANT APPLICATIONAPPLICATION

• Participant EligibilityParticipant Eligibility

• Program Concept and EmphasisProgram Concept and Emphasis

• Scope of Program DesignScope of Program Design

• Results-Oriented ModelResults-Oriented Model

• Required ContentRequired Content

• Proposal ContentProposal Content

• Cost Proposal NarrativeCost Proposal Narrative

PARTICIPANT ELIGIBILITYPARTICIPANT ELIGIBILITY

• Individuals must be homeless Individuals must be homeless veteransveterans

• Persons who lack a fixed regular Persons who lack a fixed regular nighttime residencenighttime residence

• Those in public or private temporary Those in public or private temporary sheltersshelters

• Private place not designed as Private place not designed as sleeping accommodations for human sleeping accommodations for human beings (42 USC 11302(a))beings (42 USC 11302(a))

• Persons who served on active duty & Persons who served on active duty & discharge other than dishonorable discharge other than dishonorable (38 USC 101(2))(38 USC 101(2))

PROGRAM CONCEPT AND PROGRAM CONCEPT AND EMPHASISEMPHASIS

• To provide services to assist in To provide services to assist in reintegrating homeless veterans reintegrating homeless veterans into meaningful employment within into meaningful employment within the labor forcethe labor force

• To stimulate the development of To stimulate the development of effective service delivery systems to effective service delivery systems to address complex problems facing address complex problems facing homeless veteranshomeless veterans

SCOPE OF PROGRAM SCOPE OF PROGRAM DESIGNDESIGN

• Core servicesCore services

• Coordination with veterans’ services Coordination with veterans’ services programs & othersprograms & others

• Referrals to necessary treatment & Referrals to necessary treatment & rehabilitative servicesrehabilitative services

• Referral to housing assistanceReferral to housing assistance

• Employment and training servicesEmployment and training services

RESULTS-ORIENTED MODELRESULTS-ORIENTED MODEL

• Applicant must design a program that Applicant must design a program that is responsive to the local needs of is responsive to the local needs of homeless veteranshomeless veterans

• Carry out the objective to successfully Carry out the objective to successfully reintegrate homeless veterans into reintegrate homeless veterans into the workforcethe workforce

• Discuss steps/processes to be taken to Discuss steps/processes to be taken to achieve successful reintegration of achieve successful reintegration of clientsclients

REQUIRED CONTENTREQUIRED CONTENT• SEVEN CORE PROGRAM SEVEN CORE PROGRAM

ACTIVITIES ACTIVITIES (employment focused)(employment focused)

OutreachOutreach

Pre-enrollment assessmentsPre-enrollment assessments

EDP’s for all clientsEDP’s for all clients

Case ManagementCase Management

Job Placement & Retention Follow-up Job Placement & Retention Follow-up at 90 & 180 Daysat 90 & 180 Days

• Utilization of DVOP/LVER staffUtilization of DVOP/LVER staff Utilization of linkages with other Utilization of linkages with other

programs & services which provide programs & services which provide support to homeless veteranssupport to homeless veterans

PROPOSAL CONTENT, PROPOSAL CONTENT, (Part one (Part one

technical)technical)

• Narrative proposalNarrative proposal• Outreach componentOutreach component• Employment focusedEmployment focused• Need for programNeed for program• Approach or strategy to increase Approach or strategy to increase

employment & retentionemployment & retention• LinkagesLinkages• Supportive servicesSupportive services• CapabilityCapability

PROPOSAL CONTENT, PROPOSAL CONTENT, (Part two (Part two

cost)cost)

• Standard Forms, SF-424 & SF-424A, Standard Forms, SF-424 & SF-424A, (Budget Information Sheet)(Budget Information Sheet)

• Detailed cost breakout of each line Detailed cost breakout of each line item on SF-424Aitem on SF-424A

COST PROPOSAL COST PROPOSAL NARRATIVENARRATIVE

• Breakout of personnel costs by Breakout of personnel costs by positionposition

• Explanation & breakout of any Explanation & breakout of any extraordinary fringe benefits extraordinary fringe benefits (35% Or (35% Or More Of Wages)More Of Wages)

• Explanation of purpose & Explanation of purpose & composition of & method to derive composition of & method to derive costs of:costs of: Travel, equipment, supplies, sub-Travel, equipment, supplies, sub-

awards/contracts, and other costsawards/contracts, and other costs

APPLICATIONAPPLICATION

• Must be submitted timelyMust be submitted timely

• Must be responsive to the SGAMust be responsive to the SGA

• Program concept and emphasisProgram concept and emphasis

• Scope of program designScope of program design

• Budget informationBudget information

NOTICE OF AWARDNOTICE OF AWARD

• Agreement periodAgreement period

• Funding amountFunding amount

• Special provisionsSpecial provisions

• General provisionsGeneral provisions

• Copy of recipient’s applicationCopy of recipient’s application

• Recipient’s approved budgetRecipient’s approved budget

• Quarterly technical performance Quarterly technical performance goals goals

SPECIAL PROVISIONSSPECIAL PROVISIONS• ScopeScope

• Payments/interest earnedPayments/interest earned

• Reporting requirementsReporting requirements

• Grant administrationGrant administration

• TravelTravel

• Printing & duplicatingPrinting & duplicating

• Sub-grantsSub-grants

• Salary paymentsSalary payments

• Limits on administrative costsLimits on administrative costs

• Indirect chargesIndirect charges

GENERAL PROVISIONSGENERAL PROVISIONS• Administrative provisionsAdministrative provisions

• Modifications to grantModifications to grant

• Allowable costsAllowable costs

• Interest earned & program interestInterest earned & program interest

• Property acquisition & managementProperty acquisition & management

• Grant close-out proceduresGrant close-out procedures

• Suspension & termination proceduresSuspension & termination procedures

• Encumbrance of grant fundsEncumbrance of grant funds

• Site visitsSite visits

• Order of precedenceOrder of precedence

GRANT LAW AND GRANT LAW AND REGULATIONSREGULATIONS

• DOL 29 CFR Subtitle A, Parts 95-99DOL 29 CFR Subtitle A, Parts 95-99

• Uniform Administrative Requirements Uniform Administrative Requirements OMB Circulars:OMB Circulars: A-102 State & Local GovernmentsA-102 State & Local Governments A-110 Non-ProfitsA-110 Non-Profits

• Cost Principals OMB Circulars:Cost Principals OMB Circulars: A-87 State & Local Governments A-87 State & Local Governments A-122 Non-profitsA-122 Non-profits A-21 Educational InstitutionsA-21 Educational Institutions

• Grant ProvisionsGrant Provisions

OVERSIGHT OVERSIGHT RESPONSIBILITIESRESPONSIBILITIES• Develop working relationship with Develop working relationship with

grantee; provide assistancegrantee; provide assistance

• Monitor quarterly reportsMonitor quarterly reports

• Analyze reportsAnalyze reports

• Complete quarterly desk review with Complete quarterly desk review with comments on your analysiscomments on your analysis

• Conduct annual on-site reviewConduct annual on-site review

• Address concerns/deficiencies with Address concerns/deficiencies with granteegrantee

• Keep your Regional Administrator Keep your Regional Administrator appraised on any potential problemsappraised on any potential problems

Grant MonitoringGrant Monitoring

• DOL/VETS emphasizes thorough DOL/VETS emphasizes thorough monitoring of grantees. monitoring of grantees.

• One of the key roles of the state One of the key roles of the state level DVET in the administration of level DVET in the administration of grants is the monitoring and grants is the monitoring and provision of technical assistance to provision of technical assistance to grantees. grantees.

• The “program start date” is the The “program start date” is the date on which a grantee can legally date on which a grantee can legally begin to spend Federal grant funds.begin to spend Federal grant funds.

Grant Monitoring - Grant Monitoring - ccontinuedontinued

• On a basic level, monitoring ensures On a basic level, monitoring ensures that grantees comply with the Grant that grantees comply with the Grant Agreement and all laws, regulations, Agreement and all laws, regulations, and policies concerning grants in and policies concerning grants in general, and VETS grants in particular.general, and VETS grants in particular.

• Monitoring should be seen as a largely Monitoring should be seen as a largely positive activity.positive activity.

• VETS uses two methods for obtaining VETS uses two methods for obtaining information about grant performance - information about grant performance - desk reviews desk reviews and and on-site visitson-site visits..

QUARTERLY DESK REVIEWQUARTERLY DESK REVIEW• Profile of the grantProfile of the grant

• Program performance reviewProgram performance review

• Past performancePast performance

• Financial reviewFinancial review

• AnalysisAnalysis

• Summary of the desk reviewSummary of the desk review Program StrengthsProgram Strengths Program WeaknessProgram Weakness Potential Problematic AreasPotential Problematic Areas

Desk ReviewDesk Review

• A review of this information can A review of this information can therefore:therefore:· Identify potential or existing · Identify potential or existing problem areas;problem areas;· Provide background information · Provide background information concerning program design, concerning program design, operational procedures and operational procedures and previous monitoring activities; andprevious monitoring activities; and· Identify the priorities/activities to · Identify the priorities/activities to be reviewed during the on-site visit.be reviewed during the on-site visit.

Desk Review - Desk Review - continued continued

• Each program year quarter, the Each program year quarter, the GOTR’s desk review will include an GOTR’s desk review will include an assessment of the Quarterly Technical assessment of the Quarterly Technical Performance Report including the Performance Report including the grantee’s expenditures;grantee’s expenditures;

• The GOTR reviews the Financial The GOTR reviews the Financial Status Report (SF-269) and compares Status Report (SF-269) and compares it with the quarterly HHS 272, andit with the quarterly HHS 272, and

• review of other pertinent narrative review of other pertinent narrative data, such as previous monitoring data, such as previous monitoring reports and Corrective Action Plans. reports and Corrective Action Plans.

Reporting and GrantReporting and GrantMonitoring - Grantee Monitoring - Grantee Reporting RequirementsReporting Requirements

• Throughout the grant period and Throughout the grant period and following the end of the grant period, following the end of the grant period, grantees are required to submit grantees are required to submit reports on both the programmatic and reports on both the programmatic and financial status of the grant program;financial status of the grant program;

• Reporting instructions are covered in Reporting instructions are covered in the grant Special Provisions. the grant Special Provisions.

Reporting and GrantReporting and GrantMonitoring - Grantee Reporting Monitoring - Grantee Reporting RequirementsRequirements• Technical Performance Reports Technical Performance Reports – The – The

grantee must submit a Quarterly Technical grantee must submit a Quarterly Technical Performance Report 30 days after the end of Performance Report 30 days after the end of each Federal fiscal quarter as per the most each Federal fiscal quarter as per the most recent guidance;recent guidance;

• This report must contain the following:This report must contain the following:1. A comparison of actual accomplishments to 1. A comparison of actual accomplishments to established goals for the reportingestablished goals for the reportingperiod, and any findings related to monitoring period, and any findings related to monitoring efforts; andefforts; and2. An explanation for variances of plus or minus 2. An explanation for variances of plus or minus 15 percent of planned program and/or 15 percent of planned program and/or expenditure goals. The explanation must also expenditure goals. The explanation must also include a corrective action plan and timetable.include a corrective action plan and timetable.

Reporting and GrantReporting and GrantMonitoring - Grantee Reporting Monitoring - Grantee Reporting Requirements (continued)Requirements (continued)

• It should explain, in some detail, what is It should explain, in some detail, what is happening in the program and why. If some happening in the program and why. If some aspects of the program are doing much aspects of the program are doing much better than expected, the grantee should better than expected, the grantee should explain why; explain why;

• If other aspects are not on target, the If other aspects are not on target, the grantee should both offer an explanation grantee should both offer an explanation and describe what is being done to improve and describe what is being done to improve performance in those areas;performance in those areas;

• If the grantee foresees the need to change If the grantee foresees the need to change the program schedule or anticipates the program schedule or anticipates problems, this report should address this problems, this report should address this explicitly.explicitly.

Reporting and GrantReporting and GrantMonitoring - Grantee Reporting Monitoring - Grantee Reporting RequirementsRequirements (continued)(continued)

• Financial Reports Financial Reports – The grantee must – The grantee must report outlays, program income, and report outlays, program income, and other financial information on a quarterly other financial information on a quarterly basis no later than 30 days after the basis no later than 30 days after the ending date of each Federal fiscal quarter ending date of each Federal fiscal quarter during the grant period (i.e., October 30, during the grant period (i.e., October 30, January 30, April 30 and July 30); January 30, April 30 and July 30);

• The financial report is a standard form The financial report is a standard form (SF-269A, Financial Status Report, Short (SF-269A, Financial Status Report, Short Form) available on the Internet atForm) available on the Internet at

http://www.whitehouse.gov/omb/grants/sfhttp://www.whitehouse.gov/omb/grants/sf269a.pdf269a.pdf

http://www.whitehouse.gov/omb/grants/sf269a.pdf

http://www.whitehouse.gov/omb/grants/sf269a.pdf


• Request for Payment Request for Payment – In addition to – In addition to these performance status reports, the these performance status reports, the grantee is required to submit a request for grantee is required to submit a request for payment in order to process grant payment in order to process grant payments, on a quarterly basis. (This form is payments, on a quarterly basis. (This form is HHS-PMS 272, and is explained at the Post-HHS-PMS 272, and is explained at the Post-Award Conference.)Award Conference.)

• Ninety (90) Day Report Package Ninety (90) Day Report Package – No – No later than 120 days after the grant later than 120 days after the grant expiration date, the grantee must submit a expiration date, the grantee must submit a final report containing the following:final report containing the following:


• Financial Status Report SF-269;Financial Status Report SF-269;

• Technical Performance Report Technical Performance Report including updated 90 and 180 day including updated 90 and 180 day after exit quarter retention in after exit quarter retention in employment data for all participants employment data for all participants that entered employment during the that entered employment during the active grant performance period.active grant performance period.


• One Hundred Eighty (180) Day Report One Hundred Eighty (180) Day Report – – No later than 210 days after the grant No later than 210 days after the grant performance period ends, the grantee must performance period ends, the grantee must submit a follow-up report containing the submit a follow-up report containing the following:following:

• 1. Financial Status Report (SF-269A);1. Financial Status Report (SF-269A);

• 2. Technical Performance Report with 2. Technical Performance Report with updated data (as in the 90 day report);updated data (as in the 90 day report);


• Two Hundred Seventy (270) Day Final Report Two Hundred Seventy (270) Day Final Report no later than 300 days after the active grant no later than 300 days after the active grant performance period the grantee must submit:performance period the grantee must submit:

• Final Longitudinal Report;Final Longitudinal Report;• Final Financial Status Report (if not already Final Financial Status Report (if not already

submitted)submitted)• Updated Technical Performance ReportUpdated Technical Performance Report• See Section IV of the Grant Special Provisions See Section IV of the Grant Special Provisions

for details on reporting requirements. for details on reporting requirements.


Issues Affecting Performance ReportingIssues Affecting Performance Reporting• Two aspects of performance reporting have Two aspects of performance reporting have

often created challenges (or difficulties) for often created challenges (or difficulties) for both the grantee and VETS staff monitoring both the grantee and VETS staff monitoring the grantee in the past. These two issues the grantee in the past. These two issues include properly projecting goals and the include properly projecting goals and the period covered by the first quarterly report.period covered by the first quarterly report.

• Projected Goals: Projected Goals: are not accurately stated are not accurately stated either in the grant application or the Grant either in the grant application or the Grant Agreement. Agreement.

• Period Covered by the First Quarterly Period Covered by the First Quarterly Report: Report: A second issue concerns the period A second issue concerns the period covered by the first quarterly report. covered by the first quarterly report.

Quarterly Desk ReviewQuarterly Desk Review

• The Desk Review must contain a written The Desk Review must contain a written summary of the progress and problems (if summary of the progress and problems (if any) of the grant program;any) of the grant program;

• The summary is typically no more than The summary is typically no more than one or two pages unless the GOTR has one or two pages unless the GOTR has concerns about grantee progress or concerns about grantee progress or performance. In that case, the Summary performance. In that case, the Summary includes:includes:

• A description of the problem or potential A description of the problem or potential problem;problem;

Quarterly Desk Review Quarterly Desk Review continuedcontinued

• A summary of any actions taken to rectify A summary of any actions taken to rectify the issue (such as provision of technical the issue (such as provision of technical assistance, discussions with the grantee, assistance, discussions with the grantee, or a request for a Corrective Action Plan or a request for a Corrective Action Plan (CAP)8 along with the date(s) such (CAP)8 along with the date(s) such action(s) was taken;action(s) was taken;

• An indication of whether or not a CAP will An indication of whether or not a CAP will be required of the grantee;be required of the grantee;

• An assessment of whether or not a Grant An assessment of whether or not a Grant Modification might be necessary; andModification might be necessary; and

• Any additional information required to Any additional information required to explain and/or document fully the explain and/or document fully the situation.situation.

Quarterly Desk Review Quarterly Desk Review continuedcontinued

• The quarterly review of grantee information is The quarterly review of grantee information is important, both to ensure that the grantee important, both to ensure that the grantee remains in compliance and to help identify remains in compliance and to help identify potential problems early;potential problems early;

• Equally as important, the desk review is used Equally as important, the desk review is used to prepare for the on-site evaluation and to prepare for the on-site evaluation and should beshould beconducted before an on-site visit is scheduled;conducted before an on-site visit is scheduled;

• The Quarterly Desk Review is submitted The Quarterly Desk Review is submitted according to current reporting policy.according to current reporting policy.

Monitoring VisitsMonitoring Visits• Monitoring visits allow the GOTR to Monitoring visits allow the GOTR to

assess in person the operations of assess in person the operations of a grantee program;a grantee program;

• The purpose of the visit is to The purpose of the visit is to provide for a more in-depth review provide for a more in-depth review of the grant operation and to help of the grant operation and to help address issues or concerns that address issues or concerns that have surfaced as a result of the have surfaced as a result of the quarterly review of performance quarterly review of performance reports;reports;

Monitoring Visits - Monitoring Visits - continuedcontinued• Two factors determine the length and Two factors determine the length and

the depth of the monitoring visit – the the depth of the monitoring visit – the purpose for the visit and the size and purpose for the visit and the size and complexity of the grant;complexity of the grant;

• Regular evaluation visits are Regular evaluation visits are completed in the third program completed in the third program quarter of the program year and are quarter of the program year and are intended to review the operation of intended to review the operation of the entire grant program;the entire grant program;

• A special monitoring visit is typically A special monitoring visit is typically completed to investigate one completed to investigate one particular aspect of a grant program;particular aspect of a grant program;

Monitoring Visits - Monitoring Visits - continuedcontinued

• The on-site monitoring process The on-site monitoring process is comprised of five steps:is comprised of five steps:· Desk review and on-site · Desk review and on-site review preparation;review preparation;· On-site review;· On-site review;· Documentation of Findings · Documentation of Findings (Report);(Report);· Corrective Action (if · Corrective Action (if necessary); andnecessary); and· Follow-up.· Follow-up.


• The GOTR will consider the following The GOTR will consider the following questions about the grantee:questions about the grantee:· Which grantee program components · Which grantee program components contain potential challenges?contain potential challenges?· Who should be interviewed to identify · Who should be interviewed to identify and understand any concerns?and understand any concerns?

(financial, programmatic, or administrative (financial, programmatic, or administrative staff, clients/customers, staff from staff, clients/customers, staff from partner organizations, clients, etc.)partner organizations, clients, etc.)


· · What records should be examined What records should be examined and what information gathered?and what information gathered?· What activities should be observed?· What activities should be observed?· What needs to be documented, · What needs to be documented, recorded and reported? Are the recorded and reported? Are the grantee’sgrantee’s records complete?records complete?· What questions need to be asked or · What questions need to be asked or data collected in order to provide data collected in order to provide appropriate technical assistance to this appropriate technical assistance to this grantee?grantee?

MonitoringMonitoringVisitsVisits - - continuedcontinued• On-site visits are expected to take one to On-site visits are expected to take one to

two days and will typically begin with an two days and will typically begin with an “entrance interview” to explain the purpose “entrance interview” to explain the purpose of the visit, and will end with an “exit of the visit, and will end with an “exit interview” to review any initial findings from interview” to review any initial findings from the visit;the visit;

• The GOTR may provide the grantee with an The GOTR may provide the grantee with an agenda for the on-site visit ahead of time. A agenda for the on-site visit ahead of time. A typical agenda, as well as checklists for typical agenda, as well as checklists for review of financial and other grant program review of financial and other grant program information;information;

• The GOTR will develop a written The GOTR will develop a written monitoring monitoring instrument instrument to use to collect information to use to collect information about the grantee while on-site.about the grantee while on-site.

Monitoring Visits - Monitoring Visits - continuedcontinued• Typical components of the monitoring Typical components of the monitoring

instrument include:instrument include:· Review of project financial and non-· Review of project financial and non-financial records;financial records;· Review of the administrative and · Review of the administrative and management structure and system;management structure and system;· Review of the flow of participants · Review of the flow of participants through the program, if applicable;through the program, if applicable;· Documentation of visits to work · Documentation of visits to work sites and training institutions, if sites and training institutions, if applicable.applicable.


• Using the monitoring instrument, the Using the monitoring instrument, the GOTR’s collection of grantee information GOTR’s collection of grantee information is usually accomplished through three is usually accomplished through three methods. These include: review of methods. These include: review of participant records; staff and/or client participant records; staff and/or client interviews; and general observation.interviews; and general observation.

• Review of participant records is used to:Review of participant records is used to:· Validate quantitative data previously · Validate quantitative data previously submitted in quarterly reports;submitted in quarterly reports;· Validate eligibility of participants;· Validate eligibility of participants;


· · Validate that activities proposed Validate that activities proposed are being carried out as planned;are being carried out as planned;

· Ensure the grantee is complying · Ensure the grantee is complying with all record-keeping with all record-keeping requirements;requirements;

· Identify and provide a focus for on-· Identify and provide a focus for on-site interviews and observations; site interviews and observations; andand

· Monitor grant program costs.· Monitor grant program costs.

Monitoring Visits - Monitoring Visits - continuedcontinued• Candidates for in-person interviews include:Candidates for in-person interviews include:

· Program staff, including administrative program · Program staff, including administrative program staff, such as program managers, trainers, staff, such as program managers, trainers, counselors, job developers, etc.;counselors, job developers, etc.;· Clients/customers of the program;· Clients/customers of the program;· Chief elected official of the geographic area in · Chief elected official of the geographic area in which the program is operating (for example, which the program is operating (for example, governor, mayor, or county executive);governor, mayor, or county executive);· Community members affected by the program; · Community members affected by the program; andand· Leaders and members of appropriate interest · Leaders and members of appropriate interest groups, particularly local veterans’ organizations, groups, particularly local veterans’ organizations, which may be linked to the project in the program which may be linked to the project in the program narrative, or whose services may be claimed as a narrative, or whose services may be claimed as a match.match.


• Staff and client interviews can provide useful Staff and client interviews can provide useful information about a program that cannot be information about a program that cannot be obtained in any other way. The purpose of obtained in any other way. The purpose of interviewing is to:interviewing is to:· Verify and expand upon information obtained · Verify and expand upon information obtained from the desk review and other on-site review from the desk review and other on-site review activities;activities;· Obtain qualitative information on activities;· Obtain qualitative information on activities;· Identify causes of problems, deficiencies or of · Identify causes of problems, deficiencies or of exceptional performance; andexceptional performance; and· Identify management or administration issues · Identify management or administration issues requiring more in-depth review.requiring more in-depth review.


• Observation is also a technique for Observation is also a technique for gathering information about the gathering information about the operation of a grantee’s program;operation of a grantee’s program;

• Through observation, the GOTR may Through observation, the GOTR may formulate objective opinions about the formulate objective opinions about the adequacy of buildings, furnishings, adequacy of buildings, furnishings, equipment, signs, and other posted equipment, signs, and other posted information during the on-site visit;information during the on-site visit;

• Such impressions will be included as Such impressions will be included as part of the written report and might part of the written report and might also be shared during the exit interview also be shared during the exit interview with the grant manager.with the grant manager.

How Grantees Should How Grantees Should Prepare for Monitoring Prepare for Monitoring Visits?Visits?

• To help the grantee prepare for a To help the grantee prepare for a monitoring visit, the GOTR monitoring visit, the GOTR communicates with the grantee communicates with the grantee both in writing and by telephone both in writing and by telephone about the purpose of the about the purpose of the upcoming visit, the types of upcoming visit, the types of information the GOTR will review, information the GOTR will review, and the methods to be used and the methods to be used during the visit.during the visit.

How Grantees Should How Grantees Should Prepare for Monitoring Prepare for Monitoring Visits?Visits? - continuedcontinued• The GOTR should in advance The GOTR should in advance

provide the grantee a copy of the provide the grantee a copy of the monitoring instrument that will be monitoring instrument that will be used; used;

• With this, the grantee can prepare With this, the grantee can prepare staff and others who may be asked staff and others who may be asked for an interview, and can ensure for an interview, and can ensure that program records are up to date that program records are up to date and organized in such a way that and organized in such a way that will allow access by the GOTR.will allow access by the GOTR.

On-Site ReviewOn-Site Review

• On-site monitoring visits are On-site monitoring visits are typically conducted in the second typically conducted in the second quarter of the grant period; quarter of the grant period;

• Whether completing a desk or an Whether completing a desk or an

on-site review, VETS staff use three on-site review, VETS staff use three review processes in monitoring:review processes in monitoring:

On-Site Review - On-Site Review - continuedcontinued

• Plan Versus Actual Plan Versus Actual Monitoring (PVA): Monitoring (PVA): This is This is a review and analysis of a review and analysis of current program information current program information to determine the extent to to determine the extent to which grantees are which grantees are achieving goals established achieving goals established in the Grant Agreement.in the Grant Agreement.


• Managerial Monitoring: Managerial Monitoring: This This review of the quality of the program review of the quality of the program and the provided to veterans and the provided to veterans involves troubleshooting to involves troubleshooting to determine the cause of identified determine the cause of identified problems. This review involves problems. This review involves assessing the organizational assessing the organizational capacity of the grantee in carrying capacity of the grantee in carrying out the proposed program.out the proposed program.


• Data Validity Data Validity Monitoring: Monitoring: This This review is a systematic review is a systematic monitoring method to monitoring method to substantiate the substantiate the reliability of program reliability of program and financial and financial information reported by information reported by grantees.grantees.

ANNUAL ON-SITE REVIEWANNUAL ON-SITE REVIEW

• Entrance conferenceEntrance conference

• Program reviewProgram review Interview staff responsible for programInterview staff responsible for program Review and document a sample of Review and document a sample of

participants filesparticipants files Review program files Review program files Placement reviewPlacement review

• Exit conferenceExit conference

• Follow-up Letter/reportFollow-up Letter/report

Monitoring FindingsMonitoring Findings

• GOTR must prepare a written report on GOTR must prepare a written report on the results of the on-site monitoring the results of the on-site monitoring visit;visit;

• issues covered in the report will be issues covered in the report will be those that had been identified during those that had been identified during the desk review but remain unresolved; the desk review but remain unresolved; supplemented by any new issues that supplemented by any new issues that came to the attention of the GOTR as a came to the attention of the GOTR as a result of the on-site record review, result of the on-site record review, interviews, or observations.interviews, or observations.

Monitoring Findings - Monitoring Findings - continuedcontinued

• The monitoring instrument will generally The monitoring instrument will generally serve as the guide to the issues covered serve as the guide to the issues covered in the monitoring report;in the monitoring report;

• The findings and recommendations, The findings and recommendations, particularly those involving corrective particularly those involving corrective action, must be objective, accurate and action, must be objective, accurate and related to the goals and objectives of related to the goals and objectives of the particular grant; the particular grant;

• The monitoring instrument and written The monitoring instrument and written report must be submitted as per current report must be submitted as per current grant reporting requirements. grant reporting requirements.


• The GOTR must also inform the grantee The GOTR must also inform the grantee in writing of the findings and in writing of the findings and recommendations no later than ten recommendations no later than ten days after the on-site visit. Generally, days after the on-site visit. Generally, there are three types of findings reports there are three types of findings reports as a result of an on-site monitoring visit. as a result of an on-site monitoring visit. These include:These include:

• Grantee is meeting or exceeding Grantee is meeting or exceeding goals and has no problems or goals and has no problems or potential problems; potential problems;


• Grantee has some potential Grantee has some potential challenges - challenges - In this case, the GOTR In this case, the GOTR has determined no current concerns, has determined no current concerns, but has identified areas where but has identified areas where challenges may arise in the future. challenges may arise in the future. The GOTR should identify these The GOTR should identify these challenges, and collaborate with challenges, and collaborate with grantee on a course of action to grantee on a course of action to address these concerns;address these concerns;

• Grantee has challenges that Grantee has challenges that require a Corrective Action Plan require a Corrective Action Plan (CAP).(CAP).


• Typically, a follow-up meeting or Typically, a follow-up meeting or communication between the grantee and communication between the grantee and GOTR so the GOTR can outline any GOTR so the GOTR can outline any concerns, indicate areas where the grantee concerns, indicate areas where the grantee is not in compliance with the Grant is not in compliance with the Grant Agreement, and offer to provide technical Agreement, and offer to provide technical assistance to bring the grant back into assistance to bring the grant back into compliance;compliance;

• The GOTR also indicates that a CAP is The GOTR also indicates that a CAP is required and establishes a time frame by required and establishes a time frame by which the CAP is to be submitted to the which the CAP is to be submitted to the GOTR.GOTR.

TECHNICAL ASSISTANCETECHNICAL ASSISTANCE

• Be prepared to provide assistance Be prepared to provide assistance as requestedas requested

• Do not hesitate to provide Do not hesitate to provide assistance as you feel it is assistance as you feel it is warrantedwarranted

• Utilize your resourcesUtilize your resources

Technical Assistance and Technical Assistance and Corrective ActionsCorrective Actions

• DOL/VETS wants to do everything feasible DOL/VETS wants to do everything feasible to ensure the success of all grantees in to ensure the success of all grantees in carrying out their proposed programs;carrying out their proposed programs;

• In many cases, only minor problems are In many cases, only minor problems are found as a result of the monitoring found as a result of the monitoring process;process;

• In some cases, however, potential In some cases, however, potential challenges, or current problems challenges, or current problems significant enough to warrant a Corrective significant enough to warrant a Corrective Action Plan (CAP) are identified.Action Plan (CAP) are identified.

Technical Assistance and Technical Assistance and Corrective Actions - Corrective Actions - continuedcontinued• If If minor problems minor problems are found, a CAP is are found, a CAP is

not required. However, even minor not required. However, even minor problems must be addressed;problems must be addressed;

• If If potential challenges potential challenges are found as are found as a result of the monitoring process, the a result of the monitoring process, the GOTR will work with the grantee to GOTR will work with the grantee to ensure that these challenges do not ensure that these challenges do not become major compliance issues.become major compliance issues.

Technical Assistance and Technical Assistance and Corrective Actions - Corrective Actions - continuedcontinued• If If significant problems significant problems are found are found

either in the desk review or as a result either in the desk review or as a result of the on-site visit, a CAP is required. A of the on-site visit, a CAP is required. A difference of more than 15 percent from difference of more than 15 percent from program goals or expenditures would program goals or expenditures would necessitate a CAP;necessitate a CAP;

• Development of the CAP is the Development of the CAP is the grantee’s responsibility, with assistance grantee’s responsibility, with assistance and direction provided by the GOTR.and direction provided by the GOTR.

Technical Assistance and Technical Assistance and Corrective Actions - Corrective Actions - continuedcontinued• A CAP is required if the GOTR finds the A CAP is required if the GOTR finds the

grantee is not in compliance with the Grant grantee is not in compliance with the Grant Agreement. The CAP should contain three Agreement. The CAP should contain three basic elements:basic elements:· A description of the problem(s) being · A description of the problem(s) being addressed;addressed;· A detailed, step-by-step plan to correct · A detailed, step-by-step plan to correct the problem(s); andthe problem(s); and· A schedule for implementing the plan.· A schedule for implementing the plan.

• On the basis of the schedule contained in On the basis of the schedule contained in the CAP, the GOTR contacts the grantee to the CAP, the GOTR contacts the grantee to ensure that the proposed actions have been ensure that the proposed actions have been taken.taken.

Sanctions And Penalties Sanctions And Penalties

• The Special Provisions of the Grant The Special Provisions of the Grant Agreement specify three sanctions Agreement specify three sanctions that may be taken when a grantee is that may be taken when a grantee is not performing in compliance with the not performing in compliance with the terms and conditions of the grant:terms and conditions of the grant:

• Withholding of Funds;Withholding of Funds;• Suspension; andSuspension; and• Termination.Termination.

Sanctions And Penalties - Sanctions And Penalties - continuedcontinued

• Withholding of FundsWithholding of Funds

• If a grantee has expended funds in a If a grantee has expended funds in a manner which is not permissible, or if manner which is not permissible, or if the grantee’s financial report (SF-269) the grantee’s financial report (SF-269) does not justify the expenses does not justify the expenses requested on the SF-270 (or the requested on the SF-270 (or the amount of money drawn down by amount of money drawn down by Letter-of-Credit), the Grant Officer has Letter-of-Credit), the Grant Officer has the authority to withhold payment. the authority to withhold payment.

Sanctions And Penalties Sanctions And Penalties - - continuedcontinued

Suspension of a Grant ProgramSuspension of a Grant Program• Suspension of a grant temporarily Suspension of a grant temporarily

suspends Federal assistance under the suspends Federal assistance under the grant pending corrective action by the grant pending corrective action by the grantee or pending a decision to grantee or pending a decision to terminate the grant;terminate the grant;

• When a grant is reinstated, the Grant When a grant is reinstated, the Grant Officer (GO) will allow all necessary and Officer (GO) will allow all necessary and proper costs that the grantee could not proper costs that the grantee could not reasonably avoid during the period of reasonably avoid during the period of suspension, provided that they meet the suspension, provided that they meet the provisions of the grant and any provisions of the grant and any applicable Federal Cost Principles.applicable Federal Cost Principles.


Grant TerminationGrant Termination• The termination of a grant means the The termination of a grant means the

cancellation of assistance under the grant, cancellation of assistance under the grant, in whole or in part, at any time prior to the in whole or in part, at any time prior to the end of the grant period; end of the grant period;

• If a grant is terminated, the Grant Officer If a grant is terminated, the Grant Officer will promptly notify the grantee and the will promptly notify the grantee and the GOTR, RAVET, and OASVET in writing; GOTR, RAVET, and OASVET in writing;

• In addition to termination for cause, a grant In addition to termination for cause, a grant may also be terminated for convenience; may also be terminated for convenience;

• A grant may also be terminated “in part” – a A grant may also be terminated “in part” – a partial termination – when some portion(s) partial termination – when some portion(s) of a program is terminated, but others of a program is terminated, but others continue. continue.


Imposition of SanctionsImposition of Sanctions

• Sanctions imposed on a grantee will Sanctions imposed on a grantee will depend upon the seriousness of the depend upon the seriousness of the situation, the terms of the Grant situation, the terms of the Grant Agreement, and the willingness and Agreement, and the willingness and ability of the grantee to rectify the ability of the grantee to rectify the situation; situation;

• Only the Grant Officer has the authority Only the Grant Officer has the authority to impose sanctions on VETS grantees.to impose sanctions on VETS grantees.

Grant Close - outGrant Close - out

• All VETS grants must be formally closed-out All VETS grants must be formally closed-out by the grantee, the GOTR and the Grant by the grantee, the GOTR and the Grant Officer;Officer;

• The Office of Cost Determination is currently The Office of Cost Determination is currently responsible for the distribution of close out responsible for the distribution of close out packages to grantees and the administrative packages to grantees and the administrative tasks of closing the grant;tasks of closing the grant;

• “ “Close out” means the official end of the Close out” means the official end of the grant period, the expenditure of all grant grant period, the expenditure of all grant monies, and the accomplishment of grant monies, and the accomplishment of grant project goals;project goals;

• Procedures for close out are outlined in the Procedures for close out are outlined in the General Provisions of the Grant Agreement;General Provisions of the Grant Agreement;

• Grant close out typically occurs within 6 to 12 Grant close out typically occurs within 6 to 12 months after the grant expires.months after the grant expires.

WEBLINKSWEBLINKS• http://www.dol.gov/vetshttp://www.dol.gov/vets

- Contract/Grant Award Info- Contract/Grant Award Info

VETS Guide to Grants, SGA’s & VETS Guide to Grants, SGA’s & enclosuresenclosures

• http://whitehouse.gov/omb/circulars/index.hthttp://whitehouse.gov/omb/circulars/index.htmlml

- Office of Management and Budget - Office of Management and Budget CircularsCirculars

• http://www.access.gpo.gov/nara/cfr/waisidx_0http://www.access.gpo.gov/nara/cfr/waisidx_03/29cfrv1_03.html3/29cfrv1_03.html

-- Code of Federal Regulations governing DOL Code of Federal Regulations governing DOL grantsgrants

http://www.dol.gov/vets

http://whitehouse.gov/omb/circulars/index.html

http://whitehouse.gov/omb/circulars/index.html

http://www.access.gpo.gov/nara/cfr/waisidx_03/29cfrv1_03.html

http://www.access.gpo.gov/nara/cfr/waisidx_03/29cfrv1_03.html

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• QuestionsQuestions

• CommentsComments

• SuggestionsSuggestions

managing vets competitive grants

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