ESBD_487724_1770386166546_Exhibit J.5 - Subrecipient Assessment and Monitoring Plan.pdf

RECOVERY, MITIGATION, AND STANDARDS

RMS Guidance Document No. 18-004

October 2018

Subrecipient Assessment and Monitoring Plan Development

Program Public Assistance and Hazard Mitigation

Purpose To provide guidance on the necessary steps and timing to complete the Subrecipient Assessment and Monitoring Plan.

Rule or Regulation Title 2, Code of Federal Regulations, Part 200, Subpart D, §331. (b), “Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section…”

Applicability The Texas Division of Emergency Management (TDEM) considers risk factors associated with grants administered by TDEM and evaluates each subrecipient in order to decide where to focus grant monitoring resources and determine if any additional monitoring may be required. The assessment is based upon an evaluation of both general factors related to overall project risk and with subrecipient capability and experience.

TDEM will monitor and evaluate the progress and completion of each subrecipient’s projects on a continuous monitoring basis. The purpose of this monitoring is to help prevent the risk of improper expenditure of federal funds and the duplication of disaster expenditures between projects. Monitoring and evaluating will include subrecipient instruction on emergency projects, debris removal, environmental compliance, improved projects, alternate projects, contracting processes (including proof of checking the debarment list of eligible contractors), and maintenance of project and financial records. These actions are intended to improve the subrecipient’s performance, reduce program non-compliance, and diminish any issues that may arise early on in the process. The monitoring process will include a combination of personal visits, phone calls, and email exchanges with the subrecipient, site visits/inspections of the project, desk audits of invoices and other supporting documentation, and quarterly report progress monitoring.

At a minimum, all subrecipients receive the same level of support and monitoring as described above. Subrecipients are presented with relevant grant guidance information and training opportunities. All procurement actions, payment requests, and quarterly submissions undergo the same review regardless of the subrecipient’s experience, which is documented in the workflows of the TDEM Grants Management System (GMS). Additional monitoring requirements would generally address any deficiencies noted in the subrecipient’s compliance with the terms and conditions of the subgrant award and its projects or that may result from Single Audit findings and corrective action considerations.

Guidance for Public Assistance During the Account Activation workflow process in GMS, the Support Affiliate (Support) will work with the subrecipient and complete the Subrecipient Assessment for Monitoring Plan (Assessment). Once completed, Support will upload the Assessment in GMS to the Account Activation workflow, using document type “Subrecipient Assessment” and with the file naming convention to include Subrecipient Name, DR number, “Assessment” and current date.

The Grant Coordinator (GC) will review the Assessment for completeness, accuracy, and reasonableness. If additional monitoring recommendations are identified, the GC will send a note to the Section Administrator (SA) in GMS, requesting review and approval of each additional monitoring action. Upon receipt of response from the SA, the GC will create a separate Issue for each monitoring action approved by the SA that includes a detailed description of the additional monitoring action needed and the due date. Then assign it to the individual or GMS role responsible for its execution.

Standard monitoring activities are captured in the Communications log entries, Notes, and attached documents. Additional monitoring activities are captured in the Issue created for tracking the execution of that activity.

Instructions for completion of the Assessment are included in the Assessment instrument.

A new Assessment must be made for each disaster in which the subrecipient participates. Valid and applicable portions of prior assessments may be copied to the new Assessment.

Guidance for Hazard Mitigation During the Application workflow process in GMS, Support will work with the subrecipient and complete the “Subrecipient Assessment for Monitoring Plan” (Assessment). Once completed, Support will upload the Assessment in GMS to the Application workflow using document type “Subrecipient Assessment” and with the naming convention to include Subrecipient Name, DR number, “Assessment” and current date.

The Grant Coordinator (GC) will review the Assessment for completeness, accuracy and reasonableness. If additional monitoring recommendations are identified, the GC will send a note to the Section Administrator (SA) in GMS, requesting review and approval of each additional monitoring action. Upon receipt of response from the SA, the GC will create a separate Issue for each monitoring action approved by the SA that includes a detailed description of the additional monitoring action needed and the due date. Then assign it to the individual or GMS role responsible for its execution.

Standard monitoring activities are captured in the Communications log entries, Notes, and attached documents. Additional monitoring activities are captured in the Issue created for tracking the execution of that activity.

Instructions for completion of the Assessment are included in the Assessment instrument.

Small: Large:

Yes/No

Review any written policies and procedures and identify and deficiencies. If policies and procedures are not in place, advise the subrecipient that the policies, when written, should meet the standards for federal and state grant management, at a minimum. Provide the subrecipient with the appropriate OMB Administrative Rules and contracting guidance requirements for meeting the federal procurement guidelines. Determine how to best communicate those requirements to the subrecipient staff members that will be responsible for following the requirements and the elected official responsible for the administration of the program.

Does the subrecipient or subrecipient's personnel have recent experience administering or managing state and/or federal grants (within the last five years)?

Does the program complexity have the potential to exceed the administrative capacity of the subrecipient?

Does the subrecipient have the financial capacity to meet matching requirements if applicable?

Does the subrecipient have established written policies and procedures for financial administration and contract management?

Determine if this subrecipient has administerd or managed state and/or federal funds of any kind within the recent past. If it is determined that the subrecipient is deficient in experience with managing state and/or federal funds, identify an appropriate level of technical assistance, management assistance or additional oversight to address the level of deficiency.

If the subrecipient is new to you, contact the previous primary state contact (in GMS) to determine if they have had prior issues. Ask the Financial Manager or City Manager how they plan to meet match. If you are unable to determine, then consult the Quality Assurance Section and ask if they have any historical information on the subrecipient.

Determine if the subrecipient's management and organizational structure appears to be sufficient to successfully administer the program. If the subrecipient has areas that appear to be insufficient to lead to the successful administration of the program then identify an appropriate level of technical assistance, management assistance or additional oversight to address the level of deficiency.

Number of Projects by Size:

Choose the appropriate response for each question based upon the accompanying description immediately below each question. Utilize the Comments & Notes section below each question to provide relevant information related to the question. Formulate any additional monitoring actions based on the responses and outline those actions in the Monitoring Actions section at the end of this document. After completion of this Subrecipient Assessment for Monitoring Plan, convert this worksheet to PDF and upload as an issue in GMS under the Account Activation step for Public Assistance and the Application step for Hazard Mitigation.

Subrecipient Assessment for Monitoring Plan

Current Fiscal Year Ending Date:

Anticipated Cumulative Obligation Amount:

Grant Source:

Purpose

1) To evaluate the subrecipients capacity to successfully complete projects in a timely fashion, in accordance with Federal statutes, as well as with FEMA, state and local guidelines.

Instructions

Subrecipient:

2) To identify potential weaknesses and determine if a greater level of support, education, and monitoring is necessary to mitigate the risk(s) associated with the identified weaknesses.

Comments and notes:

Comments and notes:

Comments and notes:

Comments and notes:

Does the subrecipient have a history of incomplete or unnecessarily delayed projects?

Subrecipient Assessment for Monitoring Plan

Revision date: March 31, 2020

TDEM RC or UC Printed Name Date:

Support Affiliate Printed Name Date:

Sign Off

For any no response, identify the process/training within the standard monitoring procedures that will assist the subrecipient and document additional Subrecipient Monitoring conditions to assist the applicant in managing their grant award. Review and modify conditions as the subrecipient becomes more proficient in grant administration.

Standard monitoring procedures as described in RMS Guidance Document 18-004 have been implemented to ensure each subrecipient receives consistent and timely guidance. Recovery Coordinators (Recovery/Mitigation) and Affiliate Support have regular communication/outreach with subrecipients in their area of responsibility.

Comments and notes:

If the subrecipient has previously been awarded funds from TDEM, has the subrecipient successfully completed the projects associated with the award? If the subrecipient has not successfully completed projects under a previous award, determine what type of technical assistance or training is necessary to help ensure the successful completion of projects.

Monitoring Actions

Comments and notes:

Based upon your current interactions and/or the TDEM history with the subrecipient, determine if the subrecipient responds to inquires from TDEM in a timely manner. Determine if the subrecipient has an established history of submitting required reports in a timely manner. If the subrecipient does not respond in a timely manner, identify the appropriate subrecipient staff or leadership member(s) that will be required for effective communication.

If findings were identified, determine if the findings would have an impact on the successful administration of the grant award. Obtain an updated corrective action plan and adjust subrecipient monitoring to mitigate any weakness.

Comments and notes:

Has the subrecipient had any type of audit completed within the past year that resulted in audit findings? (Single Audit, Financial Audit, Program Audit, VAYGo, etc.)

Does the subrecipient respond to communications and reporting deadlines in a timely manner?