Compliance Monitoring

OVERVIEW

According to OMB Circular A-133 .400(d)(3), “all pass-through entities are required to monitor the activities of subrecipients as necessary to ensure that federal awards are used for the authorized purposes in compliance with laws, regulations, and the provisions of contracts or grants agreements and that performance goals are achieved.”

Pass-through entities, like CJCC, are responsible for managing the day-to day operations of subaward-supported activities, as well as monitoring those activities.

Scrutiny from internal and external forces is another reason for monitoring subawards. Congress, Federal awarding agencies, and the public want to ensure taxpayer dollars are being spent properly and efficiently.

CJCC has adopted the preferred method of conducting on-site reviews or site visits as a common monitoring style. Additional monitoring activities include desk reviews and technical assistance.


DESK REVIEW

  • Conducted regularly by grant staff
  • Includes a very detailed analysis of financial and programmatic reports, correspondence, expense tracking, audit reports, and other documentation.

Findings from a desk review can prompt a Site Visit or Technical Assistance.


TECHNICAL ASSISTANCE

There are several things that could prompt a need for technical assistance:

  • Issues identified by the Grants Specialist during a desk review (e.g., weak internal controls, inaccurate reports, late reports, etc).
  • New Leadership: CJCC staff provides technical assistance to ensure that new Executive Directors and/or Project Directors receive full knowledge of the grant requirements.
  • Key Personnel – Key personnel may include individuals who are responsible for submitting the various required reports. CJCC staff provides technical assistance to ensure that key personnel are adequately trained on how to request reimbursements and prepare progress reports.

SITE VISITS

Objectives:

  • To meet and acknowledge the efforts of grant staff performing the work
  • To ensure compliance with the terms of the grant award
  • To ensure accuracy and consistency of financial and programmatic reporting
  • To provide immediate technical assistance (if necessary)