Attachment B - Monitoring.Assessment.Audit Policy.pdf

MONITORING AND ASSESSMENT/FINANCIAL REVIW TOOL

I. Purpose of Policy This policy describes the process utilized by the Maryland Department of Aging (MDoA) for the monitoring and assessment/audit of programs carried out by the area agencies on aging (AAAs) and other grantees.

A. The MDoA has the responsibility to ensure that all programs receiving Older Americans Act funds and other programs administered and funded by the MDoA operate effectively and in compliance with the conditions of their awards. The MDoA is required to allocate funds in a manner that maximizes their impact on aging needs in Maryland.

B. The process requires that the MDoA have a system for monitoring, assessing and auditing programs and grantees. This section describes the monitoring, assessment and auditing system used by the MDoA and similar requirements of the AAAs for subgrantees.

II. Definition of Monitoring/Assessment/Auditing To provide a common reference, the following definition is set forth:

Monitoring, which contains the element of assessment, is the ongoing process by which the Maryland Department of Aging:

1. Systematically gathers fiscal, programmatic, personnel and other data about activities and programs carried out under the State Plan and area plans on aging;

2. Identifies the strengths and weaknesses of programs and activities;

3. Provides AAAs with assistance to ensure that they operate within the constraints of legislative and administrative regulations, policies, guidelines and contractual agreements.

III. Standards for Monitoring and Assessments A. In carrying out its monitoring and assessment responsibilities, the MDoA adheres to the following standards:

1. The MDoA has developed and maintains an ongoing monitoring and assessment system, which includes procedures and monitoring tools for conducting on-site assessments.

2. The system provides for at least the following:

(a) a review of written reports from each AAA and other grantees;

(b) immediate follow up to correct problems or deficiencies identified through monitoring activities;

(c) Monitoring visits to AAAs to be conducted by staff of the MDoA;.

(d) a methodology for informing area agencies and grantees of the subject areas to be covered; and

(e) the submission of a written report of findings to the AAA/grantee within 45 days of the visit.

(f) follow-up on corrective actions and/or provision of technical assistance.

3. The Department of Aging will maintain reports of all monitoring and assessment activities.

IV. The Role of the MDoA in Monitoring and Assessments The MDoA will monitor and assess the program performance and the fiscal system of all grantees receiving Older Americans Act or other Maryland Department of Aging administered funds. Such monitoring of grantees will not include contractors of grantees except in special conditions. Monitoring activities will be directed at ensuring project adherence to all applicable laws, regulations and operating procedures.

A. Scope of monitoring and assessment.

1. Performance monitoring and assessment. Annually, the MDoA will monitor and assess grantees to determine that they are operating effectively and according to applicable program performance standards. Aspects of program performance include:

(a) Performance of the services and activities specified in the program;

(b) The quality of project operations as measured against the approved Area Plan;

(c) Compliance with applicable law; regulations, the Administration on Aging and the

State’s policies and procedures, and the approved Area Plan;

(d) Compliance with the staffing and related grantee capability conditions of the award;

(e) Identify the need for technical assistance in areas where there are apparent weaknesses or problems;

(f) Compliance with all civil rights, equal employment opportunity, and minority contractor requirements; and

(d) Other performance aspects, as appropriate.

2. Fiscal Monitoring/Auditing. The Maryland Department of Aging will monitor/audit grantees to determine that each establishes and operates its fiscal system according to the conditions of the award document and to ensure that funds are requested and expended according to grantee needs and eligible costs. Specific aspects of fiscal operations that may be monitored include:

(a) Adequacy of the fiscal system and procedures used by the grantee;

(b) Adequacy of fiscal reporting information;

(c) Verification of requests for funds;

(d) Grantee understanding of fiscal requirements and capability to perform; and

(e) Proper use of grant funds, as prescribed by the award document.

B. Methods of monitoring and assessment. The MDoA will conduct its performance and fiscal monitoring and assessment through several types of activities, including the following:

1. Review of Requests for Payment of Funds, Quarterly Financial Reports, Program

Performance Reports, and other written communications. These Reviews will be conducted at the MDoA, but may be verified during site visits or through other communications.

2. Discussion between the Department’s staff and the grantee’s staff via telephone communications.

3. Examination of program records and discussions with grantee staff during annual or other visits conducted on site.

C. Use of program performance and fiscal monitoring results.

1. Information obtained by the MDoA through its program performance and fiscal monitoring of grantees will be used to:

(a) Determine that each grantee performs the activities and services for which the grant award was made;

(b) Identify deficiencies in performance that must be corrected;

(c) Determine whether the “Request for Payment” forms submitted by each grantee are correct and payable or if a revision of the amount requested is necessary;

(d) Determine whether program funds are being expended in accordance with the award document and other applicable requirements;

(e) Identify the grantee’s understanding of Older Americans Act/State fiscal procedures and requirements;

(f) Determine if technical assistance by MDoA is needed at any point during the project year; and

(g) Establish a basis for initiating sanctions against a grantee when serious problems are not corrected.

2. Monitoring is viewed as a continuous process; therefore, grantees will be notified of the results of every monitoring activity conducted by the MDoA. When the MDoA finds that a monitoring activity has indicated a significant problem concerning a grantee’s performance or its fiscal system, it will notify the grantee in writing of its findings and indicate any requirements and procedures necessary to correct the problem. Written notification will be given within a reasonable period of time.

V. Monitoring Tools

The MDoA has developed and will use pre-monitoring and monitoring forms. Forms are used for monitoring and assessing the following:

1. Fiscal operations

2. Program activities

3. The relationships between fiscal operations and programs.

4. Summaries and recommendations of previous assessments.

5. Determining training and technical assistance needs of the AAAs and their service providers.

The AAAs will be monitored and assessed on-site, annually by the MDoA staff utilizing Monitoring Tools. Reports will be prepared and submitted to the AAA Director, appropriate AAA program staff, and MDoA staff.

B. Procedures for use of Monitoring Tools. The procedures that follow have been organized to include activities to be carried out before, during, and after the monitoring and assessment visit and to permit the area agency to involve appropriate staff.

1. Pre-visit procedures

(a) The MDoA will make available to the AAA Director and program staff a copy of the monitoring tool for review prior to the on-site visit.

(b) The MDoA will develop a monitoring schedule in cooperation with the area agency director and will give at least one month prior notification of the on-site visit.

(c) The MDoA will advise the AAA director of the subject area it intends to cover during the visit, the MDoA staff designated to conduct the visit, and the specific materials that are to be made available during the visit. The AAA director will advise appropriate AAA staff of this information.

(d) The AAA will organize and make available for review documents and reports on its internal activities and the activities of its sub-grantees including, but not necessarily limited to, program and financial reports, project review and assessment, and other appropriate documents. Where relevant documents are not available, indication of the date of availability is to be provided.

(e) The MDoA will review the Area Plan, fiscal and program reports, past assessments, and other pertinent materials.

2. Visit

(a) The MDoA staff will meet with the AAA program staff at a preliminary entrance meeting to discuss the conduct of the review, problems and achievements, previous visits, and communications, and to identify any area of the monitoring tool that may require clarification.

(b) The monitoring tool will be used by MDoA staff to systematically examine the components to be monitored and assessed during the visit, including a review of corrective actions taken as a result of previous visits.

(c) During the monitoring visit, MDoA staff may visit clients and ancillary sites, such as nutrition sites, senior centers, and long-term care facilities.

(e) The MDoA staff will review required records and files and ensure that all required data have been collected for completion of the follow-up report.

(f) The MDoA staff will discuss general observations and findings with appropriate AAA staff, advise them of program strengths and weaknesses, explain corrective actions that may be required and offer technical assistance.

(f) The AAA will advise the MDoA of the availability of materials that were not available at the time of the assessment visit and arrange to make them accessible.

3. Post-visit procedures

(a) The MDoA will prepare a written report as soon as possible following the monitoring visit. The report will follow the basic format of the tool and will highlight areas of commendation as well as any areas in need of corrective action or modification. The MDoA will offer technical assistance and/or training, as needed.

(b) The report will be sent to the AAA Director and appropriate AAA program staff.

(c) Significant issues raised during the monitoring visit that affect the MDoA policy are to be brought to the attention of the Division Chief, and the Secretary of the MDoA or Deputy Secretary.

(d) Responsibility for assuring that the AAA completes recommended actions will be assigned to appropriate MDoA program staff.

(e) The AAA will submit written documentation within 30 days of receipt of the annual assessment describing its plan for follow-up in carrying out recommended actions, including target dates for completion. The MDoA and the area agency should agree on the follow-up plan that will be used in future monitoring by the MDoA.

(f) A copy of the monitoring and assessment report will be maintained in the Maryland

Department of Aging files for a period of four years.

VI. Monitoring and Assessment of Subgrantees

AAAs must assess subgrantees service providers at least one a year, in addition to quarterly monitoring reviews. Assessment reports must be prepared and made available to the Department of Aging at the time of the State’s on-site visit. Grantees and contractors should be notified in advance of each assessment visit, and a written report on the assessment should be submitted to the head of the organization. Even in cases where the area agency is the direct service provider, a self-evaluation is encouraged.