Federal Assistance Manual Chapter 5-50

CHAPTER 5-50 MONITORING AND ADMINISTRATION

• 5-50-00 Purpose
  
• 5-50-10 Applicability
  
• 5-50-20 OSM Policy
  
• 5-50-30 Responsibilities
  
• 5-50-40 Monitoring Duties
  
• 5-50-50 Technical Assistance

5-50-00 PURPOSE

This chapter provides policies and procedures to ensure that grant monitoring duties are clearly assigned, certain monitoring actions are performed and documented, and appropriate follow-up action is taken.

5-50-10 APPLICABILITY

This chapter is applicable to all grants and cooperative agreements awarded by OSM.

5-50-20 OSM POLICY

1. OSM begins its monitoring responsibilities upon receipt of a grant or cooperative agreement application. When reviewing an application, OSM is determining if the applicant can accomplish the proposed goals in the manner proposed and within a specific time frame. Once the grant or cooperative agreement is issued, the goals, the manner of performance and time period are fixed for monitoring purposes.

2. Greater reliance is placed on the recipient to monitor the performance under grant/cooperative agreement supported activities to assure that adequate progress is being made towards achieving the goals of the grant or cooperative agreement. The monitoring shall be made for each program, function or activity of each grant as is set forth in the approved grant application or State plan. Recipients are expected to constantly monitor the performance of all grant activities and functions to assure that time schedules are met, that proposed work units are accomplished and the other performance goals are achieved.

5-50-30 RESPONSIBILITIES

1. The recipient shall retain primary responsibility for performance under a grant or cooperative agreement. It is the responsibility of the recipient to assure that all work conducted under the grant, including its subgrants or other agreements, is performed in keeping with the terms, conditions and scope of the approved grant.

2. The OSM RCC/FO shall monitor all active grants and cooperative agreements.

5-50-40 MONITORING DUTIES

1. The RCC/FO shall perform the following actions:
   1. Develop one or more forms to document the results of grant monitoring actions. Each form shall contain spaces to record at least the information listed on the sample form at Exhibit X5-50-1 (referred to as a Monitoring Statement). All Monitoring Statements shall be distributed to the grant file and may be distributed to other personnel and offices as appropriate.

   2. Track the submission of financial, performance and other reports required from a recipient by the due date.

   3. Review and approve financial and performance reports.

   4. Review the business and other nonprogrammatic concerns of (a) audit reports, (b) site visits, (c) the report portions of continuation applications, (d) correspondence from recipients or third parties in which information on grant performance is provided, and (e) memoranda or telephone conversations with recipients or third parties in which information on grant performance is provided.

2. The following areas should be examined to analyze the recipient's performance:
   1. Statements made by the recipient in the grant or cooperative agreement application regarding grant requirements, activities and program objectives.

   2. Previous experience with the recipient in the OSM program or other Federal programs.

   3. GAO or DOI-OIG audit reports and reports on recipient-sponsored OMB Circular A-128 audits.

   4. Analysis of the recipient's financial statements performed by the cognizant agency as part of the indirect cost rate negotiation process.

   5. The recipient's implementation of State or Federal management systems/procedures and internal controls.

3. The following factors may indicate that the grantee may be high-risk:
   1. A history of unsatisfactory performance, material violations of terms and conditions, or large cost disallowances on previous awards from OSM or other Federal agencies.

   2. Serious deficiencies in program or business management systems, such as substantial failure to comply with the financial management standards contained in the Grants Management Common Rule.

   3. Inexperience, such as may occur in newly-formed organizations or in those which have not previously received Federal grants.

4. OSM has several options to minimize the risk after a determination that a recipient is high-risk:
   1. Do not award a grant or convert the grant to a cooperative agreement. A grant should not be made if the nature and extent of the risks are so serious that inadequate or improper performance is probable.

   2. Prepare a grant but include special protective conditions and generally closer monitoring. This could include:
      1. Special reporting procedures -- more detailed or more frequent reports;
         
      2. Additional prior approval requirements;
         
      3. After-the-fact reimbursement;
         
      4. Frequent site visits.

   3. Prepare a grant, but arrange for appropriate technical assistance to the grantee.

5-50-50 TECHNICAL ASSISTANCE

The purpose of technical assistance is to raise the level of competence of the recipient organization. In making the decision on what type of technical assistance is appropriate, the following range of services may be considered:
1. Tell the recipient what the problem is and require the recipient to correct the problem and get technical assistance, if necessary.

2. Where problems and minor commitments are involved, furnish technical assistance directly through site visits by Headquarters or FO personnel.

3. Provide substantial technical assistance directly at the site.

4. Contract with a national or regional contractor to supply technical assistance of specified kinds and authorize the recipient to call on the contractor for specified services.

5. Call on other available organizations to supply such assistance, as appropriate.

EXHIBIT X5-50-1

GRANT OR COOPERATIVE AGREEMENT MONITORING STATEMENT

Recipient Name:

Grant No.:

1. MONITORING ACTION PERFORMED

   (e.g., Review of financial status report dated 2/15/80 for period 1/1/99 - 12/31/99)

2. FINDINGS

   _______________________________________

   _______________________________________

3. RECOMMENDED ACTIONS

   _______________________________________

   _______________________________________

MONITORING OFFICIAL:

______________________________
(Signature and Date)

______________________________
(Printed or Typed Name, Organization, and Telephone No.)

Attach Additional Sheets If Necessary

Distribution:
Grant File
___________

FEDERAL ASSISTANCE MANUAL
January 2, 1998