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Subgrantee
Monitoring and Oversight
Monitoring
and Oversight is a top priority for CNCS and we want to ensure federal grant
expenditures are allowable, reasonable, and necessary under the terms and
conditions of the grant award. Therefore
we are issuing this monitoring and oversight bulletin to provide guidance to
prime grantees that have subgrants.
Grantees
are accountable to monitor their subgrantees and to hold them responsible for
the same rules that are in the Terms and Conditions issued to the prime
grantee.
CNCS
requires prime grantees to monitor and provide oversight both at the
prime, as well as subgrantee level, and encourages using the same three
step risk-based approach CNCS uses for its own monitoring and oversight
work: Prevent, Detect, and Enforce. This can be achieved through an
approach that seeks to:
-
Assess
training and technical assistance needs to prevent non-compliance
- Establish
a monitoring schedule to perform desk- and on-site monitoring
- Identify
and document non-compliance issues
- Deliver
pre- and post-award training, and re-train after staff turnover
- Establish
corrective action plans with deadlines
- Follow
up on corrective actions
A prime
grantee must have internal controls that ensure subgrantee monitoring is
performed on a regular schedule and addresses critical compliance matters.
Experience
has taught us that prime grantees often fail to formally pass along the Terms
and Conditions of their grants to their subgrantees, such as by attaching them
to the subgrant agreements.
As
for where to look in the Uniform Guidance, a good start would be to examine the
pass through rules found at: Section 200.331, Requirements For Pass-Through
Entities and the rules on Internal Controls, found at: Section 200.303,
Internal Controls. If you have no subgrantees, at this time, consider this
bulletin as a head’s up for a future program that might call for having or
being a subgrantee.
We
wish you success in your programs and your oversight activities. For more
information and resources on monitoring please visit our Knowledge Network
here: (eCourse or additional
resources).
If
you have questions on this topic or suggestions for future bulletin topics,
please contact Brad Lewis at: blewis@cns.gov.
In
Service,
Dana Bourne
Corporation for National and Community Service Grant Offices
Washington, DC and Philadelphia, Pennsylvania
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