Completing Your Grant: Section 12.2 Sub-recipient MonitoringMany projects or programs will be carried out by a subrecipient. Although the grantee will contract with the subrecipient to carry out the CDBG activities and pass through funds, this does not mean that the grantee can transfer or “assign” its responsibilities as a grantee. Since the state’s contract is with the grantee, it is the grantee’s performance which the state will monitor. It then becomes the grantee’s responsibility to ensure that its subrecipient is carrying out the project in conformance with the certifications and requirements that it has inherited as a result of receiving CDBG funds. As a result, grantees need to assure such compliance by undertaking monitoring of all subrecipieints.
A subrecipient must be monitored to ensure compliance with all of the requirements outlined in its agreement with the grantee. A well thought out and clear agreement is essential in avoiding problems. Most agreements are project-specific, with many of the general requirements only referenced. Monitoring is, in effect, a method of determining if the subrecipient is either in default of the agreement or will be in default (if things are allowed to continue).
Grantees may want to develop a plan and procedures to monitor subrecipients. Attachment 12-1 provides guidance on how to develop such a monitoring plan and procedures. The subrecipient monitoring process, which is consistent with the monitoring that CDFA performs of grantees, should include the following:
1. Monitoring Schedule: There is no required frequency, except that there must be at least one formal monitoring during the life of the project.
2. Monitoring Checklist: This list will vary, depending on the activities to be monitored. See Attachment 12-2 for CDFA’s example checklist to use in performing monitoring.
3. Perform Monitoring Visit: While there is no formal requirement as to how to conduct the monitoring visit, Attachment 12-1 provides suggested steps to set up and undertake the monitoring visit.
4. Send Formal Monitoring Letter and Follow-Up: The grantee should issue a summary of the visit and monitoring process. The grantee should address any problems or areas of non-compliance with the subrecipient prior to closing out its contract/agreement.