MONITORING 201: What To Expect In A Program (Participant) And Financial Review

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MONITORING 201 What To Expect In A Program
(Participant) And Financial Review
Webinar Date September 15, 2015
200PM EST U.S. Department of
Labor Employment and Training Administration
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Learning Objectives

• Purpose
• Why and How We Monitor
• Enhanced Desk Review vs. Onsite Review
• Core Monitoring Guide
• Program (Participant) Objectives
• Financial Objectives included in the Financial
  Supplement
• Monitoring Report and Resolution Process
• Common Findings
• Suggestions for Avoiding Findings
• Review Participant Files

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Presenters

• Moderator Program (Participant) Files
• Maisha Meminger, Division of Youth Services,
  National Office USDOL
• Program Monitoring Review Content
• Elina Mnatsakanova, Federal Project Officer,
  Region 6 USDOL
• Fiscal Monitoring Review Content
• Debbie Galloway, Senior Fiscal Analyst, Office of
  Grants Management, National Office USDOL

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Purpose of Monitoring

• U.S. DOL ETA conducts monitoring to
• Ensure compliance with
• Federal financial and administrative
  requirements, statutes, and regulations
• Grant Agreement terms and conditions
• Solicitation for Grant Applications (SGA)
• Identify technical assistance needs and best
  practices.

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Monitoring Methods

• On-Site Monitoring Review
• Scheduled at least 30 days in advance
• Conducted on-site in 2 5 days
• Enhanced Desk Monitoring Review (EDMR)
• Scheduled at least 30 days in advance
• Conducted virtually in 2 5 days

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On-Site Monitoring Reviews

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Core Monitoring Guide

• Generic tool, includes five core activities
• Design and Governance
• Program and Grant Management Systems
• Financial Management Systems
• Service Delivery
• Performance Accountability
• Financial Supplement
• Focuses on core activities 2 3 and includes
  additional objectives (2.11, 2.12 and 3.9)

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Scheduling The Review

• Establish the dates of the review
• Issue formal review confirmation letter
• Sent at least 30 days prior to visit to grants
  authorized representative (cc. grants program
  manager or POC)
• Includes US DOL ETA Core Monitoring Guide and
  Review Planning Tool
• Confirm staff availability
• Identify records, policies and files needed for
  review

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Review Planning Tool

• Developed to supplement Core Monitoring Guide
• Lists documents to be reviewed
• Identifies key staff and partners to be
  interviewed.
• Used to develop review Agenda

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Entrance Conference

• Reviewer(s) and grantee staff
• Duration 30 minutes
• Discuss the review process and next steps
• Finalize the agenda
• Q A
• Select a sample of participant files for review
• Optional a list of participants is requested
  prior to visit

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Core Activity 1 Design and Governance

• Objectives
• 1.1 Strategic Planning
• 1.2 Service Design
• 1.3 Program Integration

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Core Activity 1 Design and Governance

• How are you operating your program?
• Is your program structured as described in the
  grant agreement scope of work?
• Is your program fully integrated and aligned with
  other community resources?
• Have you strategically developed partnerships in
  your community to support your program?
• Are the required partners on-board with your
  grant program?

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Core Activity 2 Program and Grant Management
Systems

• 2.1 Administrative Controls
• 2.2 Personnel
• 2.3 Civil Rights
• 2.4 Sustainability
• 2.5 Match Requirements
• 2.6 Equipment
• 2.7 Procurement
• 2.8 Audit and Audit Resolution
• 2.9 Reporting Systems
• 2.11 Facilities and other Capital Assets
• 2.12 Intangible Property

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2.1 Administrative Controls

• Policies and Procedures for core management
  functions and program operations (fiscal and
  program)
• Monitoring Tools and Procedures and documentation
  of monitoring sub-recipients
• Record retention and access policy

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2.2 Personnel

• Personnel policies, including hiring process and
  procedures
• Grantee Organizational Chart
• Project Organizational Chart

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2.3 Civil Rights

• Access to and within buildings
• EEO notices in appropriate languages
• EEO notices in participant files
• Job announcements in appropriate languages
• ETA monitoring is a limited review of civil
  rights and issues related to individuals with
  disabilities
• Grievance and complaint procedures
• Incident reporting

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2.4 Sustainability

• If required, there is a viable plan for
  sustaining grant activities for those grants
  whose funds are scheduled to expire Statement of
  Work (SOW).
• The organization has identified resources that
  will support project activities after the grant
  expires.
• A plan is in place for continuation of services
  to participants who have not completed the
  program by the end of the grant period.

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2.5 Match Requirements

• Youth Career Connect grantees have a 25 percent
  match requirement.
• Written procedures on
• Match leveraged resources requirements
• Allowable match
• Methods for tracking
• Developed
• Issued to all parties affected
• Records are available to document and track match

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2.6 Equipment

• DOLs definition for Equipment is any item with a
  per unit acquisition cost of 5,000 or more, and
  a useful life of more than one year.
• Requires Prior approval from DOL Grant Officer
• Costs are properly allocated
• Inventories conducted every two years
• Inventories are properly tracked
• Use is limited to grant
• Program income fees charged, if applicable

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2.7 Procurement

• Open and fair competition
• Written procurement procedures for goods and
  services
• Basis for contractor selection
• Justification for sole source
• All Federal certifications and required clauses
• Cost and/or price analysis

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2.8 Audit and Audit Resolution

• Audit of own organization
• Audit of sub-recipients
• Audit tracking system
• Written status report of questioned costs and
  findings as a result of the latest Single Audit
  performed of grantees organization.
• Resolution

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2.9 Reporting Systems

• The organization maintains data collection and
  reporting systems to fulfill external reporting
  requirements, both financial and programmatic

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Core Activity 3 Financial Management Systems

• 3.1 Budget Controls
• 3.2 Cash Management
• 3.3 Program Income
• 3.4 Cost Allocation
• 3.5 Allowable Costs
• 3.6 Internal Controls
• 3.7 Financial Reporting
• 3.9 Cost Classification

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Basics Financial Management Systems

• Must adhere to 7 separate standards
• Financial Reporting
• Accounting Records
• Internal Controls
• Budget Controls
• Allowable Costs
• Source Documentation
• Cash Management

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Basics Financial Grant Management
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Financial Management RequirementsEffective for
YCC grants and for all grants awarded on or
before December 26, 2014
Grant Recipients Before December 26, 2014 Admin Requirements Audit Requirements Cost Principles
Governmental Organizations 29 CFR Part 97 29 CFR Part 96 2 CFR 225
Non-Profit Organizations 29 CFR Part 95 29 CFR Part 96 2 CFR 230
Institutions of Higher Education 29 CFR Part 95 29 CFR Part 96 2 CFR 220
Commercial For-Profit Organizations 29 CFR Part 95 29 CFR Part 96 48 CFR 31.2
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Financial Management RequirementsGrant funds
received after December 26, 2014 must follow he
Uniform Guidance
Grant Recipients After December 26, 2015 Admin Requirements Audit Requirements Cost Principles
Governmental Organizations 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Indian Tribes 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Non-Profit Organizations 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Institutions of Higher Education 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Commercial For-Profit Organizations 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Foreign Public Entities and Foreign Organizations 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900 2 CFR Part 200 and 2 CFR Part 2900
Please see the Federal Register dated December 19, 2014 outlining the one-year grace period for the implementation of the procurement standards Please see the Federal Register dated December 19, 2014 outlining the one-year grace period for the implementation of the procurement standards Please see the Federal Register dated December 19, 2014 outlining the one-year grace period for the implementation of the procurement standards Please see the Federal Register dated December 19, 2014 outlining the one-year grace period for the implementation of the procurement standards
2 CFR 2900.2 expands the applicability of the
Uniform Guidance to these entities. Uniform
Guidance Resources - http//doleta.gov/grants/pdf/
quick_reference_sheet.pdf
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Basics Accounting Records and Source
Documentation

• Accounting Records
• Must demonstrate the ability to maintain records
  that adequately identify the source and
  application of funds for approved financial
  activities aligned with the SOW.
• The General Ledger is the official books where
  all transactions are posted and this information
  is transferred to ETAs Quarterly Financial
  Status Report.
• Source Documentation
• Accounting records and payments must be supported
  by documentation such as actual invoices,
  canceled checks, time and attendance records,
  reimbursement to employers for OJT, eligibility
  for stipends, justification for needs-related
  payments.

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3.1 Budget Controls

• Budget Control
• Process implemented to compare planned versus
  actual expenditures to prevent line item overruns
• Compare monthly or quarterly
• Compare approved budget to expense reports
• Need for budget modification?

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3.1 Budget Controls

• Budget Control
• Comparison of budget or planned expenses to
  actual on a reasonable frequency
• Flexibility is allowed within the grant budget
  (except wages, salaries and fringe benefits, and
  indirect cost rates), provided no single line
  item is increased or decreased by more than 20
• Changes in excess of 20 require prior written
  approval from the Grant Officer. Failure to
  obtain such prior approval may result in cost
  disallowance.
• For grants awarded after 12/26/2014, the prior
  approval process will change due to the
  implementation of the Uniform Guidance.

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3.2 Cash Management

• Forecasting cash needs
• Advances
• Petty cash petty check
• Credit cards / purchasing cards
• Sub payments advances
• Authorized to
• Request and receipt
• Log in cash receipts
• Deposits
• Liquidation of advances

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3.3 Program Income

• Revenue in excess of expenses is program income
• Except for commercial organizations
• Requirements
• To further grant activities
• Separate account codes
• Expended prior to requesting additional cash
• Reported on the accrual basis of accounting

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3.4 Cost Allocation

• Federally approved indirect cost rate
• Federally approved cost allocation plan
• Other cost allocation plans approved by a State
  or other Federal agency

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3.5 Allowable Costs

• Transaction testing
• Payroll
• Space
• Operations and maintenance
• Administrative costs
• Travel
• Sub-contracts
• Sub-agreements
• Inter-agency agreements
• All Cost Must Be Allowable, Allocable, Necessary,
  And Reasonable

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3.6 Internal Controls

• Separation of duties
• Transactions properly authorized
• Assets are safeguarded
• Budgetary controls exist
• IT systems are secure

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3.7 Financial Reporting

• Reports are submitted to DOL are accurate and
  timely
• No less frequently than quarterly
• Grantee and grantees sub-recipients are
  reporting on the accrual basis of accounting
• Sub-recipient reporting instructions are issued
• For all data elements
• Require reports to be on the accrual basis of
  accounting

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3.7 Financial Reporting

• Track program vs. administrative costs
• Stay within administrative cost cap limit
• Apply an approved indirect cost rate correctly
• Charging all indirect costs as admin?
• If not charging all indirect costs as admin, what
  portion of indirect cost pool are properly
  chargeable to program?

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3.7 Financial Reporting

• Grant expenditures must be reported on an accrual
  basis

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3.9 Cost Classification

• Administrative Cost Definition
• Definition at 20 CFR 667.220
• Function based
• Not related to direct program services
• Can be both direct and indirect
• Examples
• Accounting, budgeting, financial and cash
  management
• Procurement and purchasing
• Personnel and property management
• Payroll, audit and general legal services
• Oversight and monitoring of administrative
  activities
• Developing information systems and procedures
  related to administrative functions

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Core Activity 4 Service / Product Delivery

• 4.1 Operating Systems
• 4.2 Participant Files
• 4.3 High-Growth Jobs
• 4.4 Integrated Services
• 4.5 Business Relationships

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Core Activity 4 Service / Product Delivery

• List of Materials to be Reviewed
• Outreach and recruitment materials
• Eligibility procedures and documentation
• Copy of project plan and contractual agreements
• Latest participant data from PTS MIS System
• Training Curriculum, course descriptions, and
  products developed with grant funds
• Supportive Services policy and documentation
• Program Services Flow-Chart
• Non-Financial MOUs with partners identified in
  grant agreement

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Core Activity 5 Performance Accountability

• 5.1 Service Goals
• 5.2 Performance Outcomes
• 5.3 Sub-recipient Performance
• 5.4 Performance Data

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Core Activity 5 Performance Accountability

• Project implementation plan
• Spending targets
• Performance data reports from PTS MIS system
• Sub-recipient contracts, performance, and
  financial reports

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Exit Conference

• Conducted by the reviewer(s)
• Reviewer provides an overview of the issues
  identified during the review.
• Notes positive practices
• Discusses next steps issuance of the monitoring
  report and subsequent Corrective Action Plans
  (CAP)
• Q A

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Monitoring Report

• Issued within 45 days after the Exit Conference
• Consists of a cover letter, executive summary,
  and actual report
• Details findings (violations of compliance
  requirements) and required corrective actions
• Notes areas of concern
• Describes promising practices
• Requires a Corrective Action Plan (CAP) within 30
  days of receipt.

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Findings Resolution Process

• Grantee submits a Corrective Action Plan
• Discusses actions that will be taken to resolve
  findings
• Provides a timeline for all required changes
• Findings closed, based on CAP
• Additional CAPs may be required
• All findings must be resolved by the end of the
  grant

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Suggestions for Reducing Findings

• Knowledge and understanding of the
• Grant Agreement
• Solicitation for Grants Application (SGA)
• Federal statutes and regulations
• Maintain Documentation
• Financial activities (e.g. expenditures,
  procurement actions, etc.)
• Program or Performance Outcomes
• Policies and procedures for all grant activities
• Questions? Call your FPO

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Questions?
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YCC Participant (Program) Files
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Objectives

• Review Key FAQs
• Participant Files Tip
• Suggested YCC Participant File Documents
• Resources

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The Resource Guide

• Contains
• Participant Files FAQs
• Participant Files Tips
• Suggested YCC Participant File Documents
• Participant File Resources
• Emphasizes that each program has proof of
  services and activities took place for each YCC
  participant unique to the YCC program the proof
  is organized and uniform and programs have
  up-to-date notes on each student

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What are the components of a participant file?

• YCC grant programs are responsible for providing
  information on each YCC student regarding
• eligibility for the YCC program
• Equal Opportunity Documents
• any applicable assessments for the YCC program
• education and support received through (or in
  conjunction with) YCC
• Individual Development Plan (IDP)
• employment and work-experience received through
  (or in conjunction with) YCC
• placement after exit
• case notes.

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Are participant files an important a part of the
YCC program and monitoring?

• YES
• Under the U.S. Department of Labor, Employment
  and Training Administration, Core Monitoring
  Guide, Participant Files indicate
• The grantee is serving the eligible/target
  population identified in the grant
• The grantee develops an individual service plan
  (i.e. the Individual Development Plan)
  identifying and meeting the specific needs to
  each individual participant
• Supportive services are being provided as needed
  to overcome client barriers to participation and
  completion of the individual service plan and
• Participants are receiving training as needed and
  progressing toward achieving their employment
  goals.

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Is the participant file a different file from the
students school file/record?
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Can the PTS act as a Students Participant File?

• The PTS is a data collection tool which allows
  grantees to track specific data elements, by
  participant, and report against program
  performance measures.
• Individual participant files enhance the PTS by
  housing documentation as proof of services and
  activities provided

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Do participant files have to be hard copies?

• This depends on design of the YCC programs
  guidelines.
• Items in a participant file can be electronic, in
  a physical folder or a hybrid of both.

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How will participant files be used during a
monitoring visit?

• FPOs will pull or request participants files
  randomly to determine whether objectives are
  being met.
• If the files are solely electronic, the FPO must
  have access to those files.
• They will also interview personnel who manage the
  participant files.
• The more comprehensive your files are, including
  documentation, signatures, case notes, receipts,
  logs, time sheets, etc. the better.

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Participant File Tips
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File Maintenance

• Strongly suggested each YCC program
• Create a written description of the standards for
  participant files
• Establish an internal quality assurance system
• Create a checklist of what documentation is be in
  each file
• Create guidelines for
• Recording case notes
• Organizing participant files
• Updating documents regularly
• Ensuring information in file matches PTS
• Ensuring file protection
• Make sure to adhere to Family Educational
  Rights and Privacy Act (FERPA) regulations

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Suggested YCC Participant File Documents
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Note..

• Note this is a sample list of SUGGESTED items
  only and not all of these documents are
  requirements for the YCC program

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Each folder should have

• Parental Permission if under 18
• Equal Opportunity Documentation
• A completed and updated IDP
• Emergency Contact information
• Photo Waiver
• Release of Information (Waivers) for Employers
  and Educational Institutions
• Eligibility documents
• Assessments
• Records of participation in activities
• Supportive services
• Documentation of credentials and diplomas
  achieved
• Documentation of other outcomes attained (such as
  employment)
• Case notes

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Monitoring Participant File Resources
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RESOURCES

• Is Your House in Order? YouthBuild Video Series
  (2014) contains 11 videos to help assist grantees
  in preparation for DOL grant compliance and
  monitoring reviews, https//www.youtube.com/playli
  st?listPLX8R1qzt_6MBNXfTij_r9s19b5ydl2hCk
• First Step A student Practitioners Resource
  Guide to Supportive Services (2012) provides
  youth practitioners with the information needed
  to connect young adults to those supportive
  services their employing organizations may not
  offer. The Guide provides quick and easy access
  to programs and services at the state or local
  level. http//wdr.doleta.gov/directives/attach/TEN
  /TEN_31_12_Att.pdf
• Improving Demand-Driven Services and Performance
  Toolkit for Effective Front-Line Services for
  Youth (2007) assists programs with improving case
  management, recruitment, intake, follow-up
  services, and developing Individual Service
  Strategies. Chapter Six, Documentation
  Record-Keeping and Case Notes presents a summary
  of some guidelines for recording case notes,
  organizing case files, and establishing an
  internal quality assurance system to facilitate
  maintaining high standards for documentation in
  case fileshttp//www.doleta.gov/youth_services/pdf
  /TOOLKIT202007-Manual.pdf

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RESOURCES

• U.S. Department of Labor, Employment and Training
  Administration, Core Monitoring Guide (2005)
  provides a consistent framework and starting
  point for all on-site grant monitoring
  responsibilities by ETA. ETA has been moving
  forward in a coordinated effort to improve the
  consistency of oversight while relying on and
  providing opportunities for Federal Project
  Officers (FPOs) to bring their professional
  judgments and experience to the process. Core
  Activity 4 Service/Product Delivery- Objective
  4.2 Participant Files provides a summary of
  indicators for review of participant files and
  case notes, http//www.doleta.gov/regions/reg02/do
  cuments/OSID20Conference/Resource20-20Core-Moni
  toring-Guide.pdf
• U.S. DOL Core Monitoring Guide Financial
  Supplement
• http//www.doleta.gov/regions/reg06/Documents/Conf
  erenceFiles2010/DOLNorthwestWorkforce20Developmen
  tForum/WA20State20-20Tool20Kit.pdf

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RESOURCES

• Youth CareerConnect Community of Practice
  (temporary location) This site contains resource
  information for the YCC program including guides,
  handouts, recorded webinars, videos, research
  documents, and data, https//etagrantees.workforce
  3one.org/page/resources/1001422629124768152
• Youth Career Connect SGA
• http//www.doleta.gov/ycc/pdf/Youth_Career_Connect
  _SGA_13-01.pdf
• Youth.gov Map My Community allows users to
  search for federally-funded, youth related
  resources. The interactive mapping tool on this
  page to locate federally supported youth programs
  in your community. Search by full address or ZIP
  code and click Find Programs. If programs are
  found the location is marked on the map,
  http//youth.gov/map-my-community.
• YouthBuild Counseling and Case Management
  Handbook (2010) focuses on how to offer the
  personal supports students need to overcome
  obstacles to achieving their goals, how to assist
  them in linking with the resources they need, and
  to document outcomes associated with the delivery
  of these services and opportunities to YouthBuild
  participants. The second part of the manual
  focuses on Case Management in Practice,
  http//youthbuild.workforcegps.org//media/Workfor
  ceGPS/youthbuild/Files/Program20Handbooks/Counsel
  ing_Case_Management_0610.pdf

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CONTACT US

• U.S. Department of Labor
• Employment and Training Administration
• 200 Constitution Avenue, NW, Room N-4456
• Washington, DC 20210
• Email ycc_at_dol.gov

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