Monitoring is a tool that federal and state agencies use to reinforce collaboration between awarding agencies (e.g., FEMA or HUD) and their grantees; it is a Government Accountability Office (GAO) standard that provides information that is critical for making informed judgments about program effectiveness and management efficiency.
Whereas an audit involves a systematic independent examination of an organization’s financial records, procedures, controls, and engagements, and is a one-time event, monitoring entails continuous observation, assessment, and tracking of various aspects of an organization’s operations, initiatives, or frameworks. Monitoring can help accomplish several objectives, including ensuring compliance with statutes and regulations, preventing fraud, waste, and abuse, detecting inefficiencies early, and facilitating continuous improvement to policies and procedures and operations, among others.
Monitoring Design
The Federal Uniform Guidance does not prescribe specific frequencies or methodologies for monitoring activities and instead emphasizes tailoring approaches to fit the specific needs of each state, local government agency, or subrecipient. Federal agencies often determine the appropriate frequency, scope, and methodology for monitoring reviews using pre-established checklists.
Federal funding recipients must design their organization and program monitoring strategies while adhering to all applicable Federal, state, and local policies, regulations, and grant-specific requirements. A best practice for a federal funding recipient is to monitor not only their subgrantees and subrecipients, but also contractors and their own operations.
Monitoring Activities &
Types of Events
Monitoring is a multifaceted process spanning multiple steps to ensure effective oversight and compliance, including:
Planning:
Defining the monitoring objectives, scope, and methodology.
Pre-review Activities:
Gathering documentation, reviewing past reports, and assessing preliminary risks.
Fieldwork (if applicable):
On-site visits to observe operations, interview staff, and gather firsthand information.
Reporting:
Documenting findings, summarizing observations, noting issues or non-compliance, and making recommendations for corrective actions.
Determining the appropriate monitoring approach requires a strategic risk assessment and a well-defined monitoring plan. Factors to consider include the overall capacity and availability of the subrecipient or grantee, their experience in managing federal funds, the scale of the grant award, the type of programs to be monitored, and the availability of agency resources.
Monitoring can be conducted either on-site or via a desk review. Desk reviews are performed remotely and are suitable for low- and medium-risk grantees, while on-site reviews are appropriate for higher-risk grantees and may be necessary depending on the type of program or project. Desk reviews offer cost savings but may be limited in scope compared to on-site monitoring, which provides closer access to personnel and records.
Crosscutting Requirements
Some grants face added complexity due to “crosscutting” requirements—overarching mandates that apply universally to all Federal programs within a particular domain. For example, all Community Development Block Grant (CDBG) recipients must meet Federal standards for environmental review, Fair Housing, and Civil Rights. Additionally, grantees may need to comply with the Davis-Bacon Act (DBA), Uniform Relocation Act (URA), and Lead Safe Housing Rule, depending on their projects.
HORNE Monitoring Experience and Successes
The HORNE team excels in managing and executing extensive monitoring operations and guiding organizations through risk assessments and effective monitoring plans. We specialize in establishing robust internal controls to ensure the successful implementation of grant programs. Our team’s agility is strengthened by the diverse expertise within our Technical Advisory Group (TAG) of Government Services.
TAG includes former deputy and assistant directors from HUD’s Office of Disaster Recovery, a former chief of staff from HUD’s Community Planning and Development division, a former HUD federal fiscal monitor, and other experts in HUD disaster recovery.
Our unparalleled insights and experience enable us to deliver strategic solutions that align closely with an organization’s objectives.
Our team includes former grantee leaders who have firsthand experience in the roles your team currently occupies. This unique perspective allows us to anticipate challenges, offer strategic insights, and provide practical solutions tailored to your specific needs and objectives.
We bring together a team of proven implementation experts who have successfully managed complex projects nationwide. Our record of delivering measurable results, optimizing resource allocation, and mitigating risks underscores our unwavering commitment to excellence in service delivery.
Our proficiency in managing government-regulated programs is evident in our oversight of over $110 billion across 18 U.S. states and territories. Notably, we have maintained a flawless record with no audit findings related to monitoring and compliance issues within the realm of CDBG-DR programs.
How Can HORNE Assist Your Organization
With a strong reputation in CDBG-DR program implementation and large-scale project management, we are adept at identifying and mitigating risks such as fraud, waste, and noncompliance. This proactive approach safeguards program integrity and ensures optimal outcomes.
We specialize in maximizing efficiency and effectiveness to support clients in swiftly launching and managing projects. Our services include expert consultation on monitoring strategies, development of compliant policies, real-time reporting solutions, and streamlined vendor management practices. With extensive compliance experience, we offer tailored insights and processes designed for CDBG-DR programs, ensuring smooth operations.
We are dedicated to leveraging our collective expertise to navigate complexities, capitalize on opportunities, and achieve success in every endeavor we undertake.
For further information on monitoring and how HORNE can assist your organization with developing and implementing a monitoring operation, please contact us.
About the Author
Director Steven Rawlinson oversees the monitoring and QA/QC division for HORNE. He has over 18 years of experience with HUD programs, including four years in HUD’s Community and Planning Development (CPD) division. Prior to HUD, Steve served as the Chief Financial Officer for the City of Houston Housing and Community Development Department.
