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New York State Department of State
Division of Community Services
Community Services Block Grant
Program and Fiscal Monitoring Process and Guidelines
Effective Date: October 1, 2007
41 State Street, Suite 1100
Albany, NY 12231
Telephone: 518-474-5741
Fax: 518-486-4663
Website: www.dos.ny.gov
May 2007
Table of Contents
Monitoring
Program Monitoring
Individual Monitoring Plan
Certification
Program Certification
Refunding Process
Board Certification
Board and Committee Meetings
Regional Meetings
Specialized Technical Assistance and Support
Attendance at Grantee Functions
Program Certifications
Grantee Services Contact Report (GSCR)
Fiscal Monitoring
General Responsibilities
Performance Standards for Monitoring Activities
Scope of Monitoring
Attachments
Grantee Services Contact Report
GSCR Attachment Form: Documentation – Board Certification and Compliance with Grantee Bylaws
GSCR Attachment Form: Documentation – Board Meeting
| The CSBG program was created to ameliorate the causes of poverty in communities. Through a network of 56 CSBG grantees, a range of services is provided to meet the needs of low-income New Yorkers in all of New York’s 62 counties. Services are determined through local assessments of customers, the community, and the grantee to determine needs to be addressed and resources available. DOS-DCS provides direction and support to local agencies to ensure that comprehensive services are provided as needed. As the CSBG administering agency, DOS-DCS establishes goals and objectives which provide program evaluation, monitoring, and oversight, and ensures compliance with Federal and State statutes, laws, policies, and procedures. DOS-DCS is the primary liaison with grantees, monitoring the program as well as providing training and technical assistance in areas such as governance, management, service delivery, and program operation. |
Monitoring
Monitoring is a comprehensive approach to reviewing, assessing, and evaluating CSBG grantees with the goal of improving the quality of services provided by grantees to individuals, children, families, and communities. It is also proactive, result oriented, and conducted to provide assistance to grantees to improve their capacity to achieve measurable results, and to meet the requirements of Federal and State authorizing legislations, the Management Plan, and the CSBG contract.
In accordance with 42 U.S.C. 9901, et seq., Section 678B, as amended, monitoring activities will be conducted to determine whether eligible entities meet performance goals, administrative standards, financial management, and other requirements set by the State.
General Responsibilities
Monitoring is conducted by community services program analysts and fiscal representatives assigned to individual grantees. Department of State (DOS) staff assigned to conduct program and fiscal monitoring must possess and demonstrate adequate professional proficiency, including knowledge of:
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assigned agencies, programs, activities, functions, service areas, organizational structure, and board composition;
applicable statutes, rules, regulations, policies and procedures governing programs and organizations; and,
CSBG National Goals and National Performance Indicators and their applicability to assigned agencies.
Staff must also:
comply with applicable Executive Orders and DOS Policies and Procedures;
communicate clearly and effectively both verbally and in writing;
exercise professional care in conducting monitoring;
base findings and conclusions on objective evaluations of pertinent information;
recognize, honor and respect human diversity;
preserve the dignity of customers and clients; and,
uphold confidentiality.
Staff assigned to monitoring:
serve as representatives of the State of New York, Department of State and must actively participate in the administration of CSBG and related programs;
assist in implementation of goals and activities outlined in the most recent CSBG Management Plan; and,
provide comprehensive technical assistance to grantees in administration of programs funded by CSBG.
Program Monitoring
Individual Monitoring Plan – An Individual Monitoring Plan (IMP) is developed for each grantee. The purpose of the IMP is to establish and define the partnership between the program analyst and the grantee during a given program year. The IMP will identify the nature and frequency of the program analyst’s monitoring and support in response to individual agency needs relating to:
- continuous improvement goals;
- corrective action plans;
- recommendation from Grantee Comprehensive Assessment Protocol; and,
- effective monitoring of the Work Plan and other contractual obligations.
The IMP must identify the number of on-site visits as well as the date, purpose, and the expected result of each visit. The dates must be scheduled before the beginning of the federal fiscal year and confirmed with follow-up communication prior to each visit. A copy of the IMP must be sent to the grantee and a copy placed in the agency’s DCS contact file. Grantees must be provided with adequate notice of changes or cancellations.
Certification – As a condition for each payment to a grantee, program analysts are required to complete the Grantee Services Contact Report (GSCR) certifying that substantial progress is being made toward achieving the results as stated in the approved Work Plan and that the grantee is eligible to receive payment. Certification can be accomplished through a combination of on-site visits, review of documents, and telephone interviews. The four required certifications documented in the GSCR are prepared and submitted on a schedule that allows for payments to grantees to be processed in a timely manner. A copy of the GSCR is shared with the Contract Review Unit (CRU), supervisor, fiscal representative, grantee, and division director.
Program Certification – This is accomplished by reviewing the data provided in the program progress report and noting exceptions and the reason for these exceptions, as agreed; and, review and analysis of the results of customer and/or partnership surveys.
Refunding Process – The refunding process is completed for each grantee as required by the CSBG Management Plan and Refunding Application. The Refunding Application package contains all federal and state required forms and documents.
Analysts will review the Refunding Application for reasonableness as well as completeness. Special attention must be given to the grantee’s use of CSBG dollars for administration and for the grantee’s ability to achieve the levels of performance indicated in the Work Plan. After the Refunding Application package is reviewed by the assigned program analyst and fiscal representative, the program analyst will determine if a follow-up visit is necessary to provide technical assistance to ensure there is a complete and acceptable application. The program analyst is responsible for communicating to the agency executive director either by e-mail or by letter, whether the application was acceptable, or, if not acceptable, listing issues and concerns and scheduling a follow-up meeting.
Board Certification – To maintain eligibility for CSBG funding, each eligible entity must comply with federal and state statutes regarding board composition and function. Grantees are required to have on file with DOS-DCS a certified list of current board members. The list must be updated as changes occur and validated annually by the program analyst. The GSCR will include a certification by the program analyst that the list of board members is valid. Validation occurs as a result of the program analyst’s review of individual board member files to determine how they were elected/selected; length of term on the board; and, tracking appointments/reappointments/resignations and removals through review of board meeting minutes. If a program analyst is unable to verify this information, the agency will be given a specific timeframe by which the required information is to be provided. If the information is not provided by the specified time, it is possible that a subsequent payment could be held until the required information is provided. An additional form must be prepared and submitted with the GSCR (see the attached form, “Board Certification and Compliance with Grantee Bylaws”).
Board and Committee Meetings – Program analysts are required to attend a minimum of one board meeting each federal fiscal year for each assigned agency to observe board function and to share information. Additional visits with board or board committees may be scheduled as determined by the IMP or as needed. Program analysts should read board meeting minutes for each assigned agency and formally address any issues or concerns noted. An additional form must be prepared and submitted with the GSCR (see the attached form, “Board Meeting”).
Regional Meetings – Regional meetings with assigned agencies are encouraged and may be held whenever possible for sharing information, providing training and technical assistance, determining joint priorities and activities, enhancing collaboration and obtaining opinions on state administration.
Specialized Technical Assistance and Support –
- Specialized services and support are provided during and after a disaster or crisis. Agencies are encouraged to become active members of their local emergency management teams. Emergency telephone numbers are maintained by the DOS program analyst for each agency and are routinely updated. Agencies in areas affected by a disaster are contacted by the assigned program analyst and are made aware of the process to access CSBG funds set aside for disaster relief activities.
- Technical assistance needs are identified and assistance is arranged or provided. Special attention will be given for training and technical assistance on the CSBG National Goals and National Performance Indicators or any other requirements as directed by federal or state government.
- Conduct and/or participate in other reviews, as appropriate, including, but not limited to active participation in pre-PRISM joint governance reviews at the request of the agency.
Attendance at Grantee Functions – Attendance at grantees’ functions as a representative of DOS is encouraged, but must have the approval of the DCS director. All staff must comply with DOS Policies and Procedures and the Governor’s Executive Order. Staff cannot accept complimentary meal tickets. If there is a charge for the event and reimbursement will be requested, staff must obtain approval through a TTR. The TTR must be approved prior to attending the event. If attendance will result in overtime, prior approval must be obtained from Human Resources.
Program Certifications:
Payment #1: On or before September 1
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Payment #2: On or before December 1
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Payment #3: On or before March 1
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Payment #4: On or before June 1
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The following items must also be addressed within the federal fiscal year:
Follow up on administrative, programmatic, and fiscal updates, as needed.Follow up on findings and/or recommendations, as needed.
Provide technical assistance on National Goals and National Performance Indicators.
Review the grantees’ planning process, needs assessment, and strategic plan.
Provide information to grantees on changes being made as a result of the reauthorizing legislation.
Review of special grant awards or disaster relief funds, as needed.
Verify list of partners and types of formal relationships (i.e. contractual, MOU).
Verify systems for community and customer input in determining agency priorities.
Verify involvement of groups, associations and/or organizations, re: enhancement of existing activities and no duplication of services.
Review audit and balance sheet, revenue and expense projections, assets and liabilities, in conjunction with the fiscal field representative.
| Based on language in the reauthorizing legislation, these purposes may be expanded or amended as needed. |
Grantee Services Contact Report (GSCR)
The GSCR is used to record and document all contacts with grantees, including program certification, program review, on-site visits, telephone calls, in-office visits, board meetings, regional meetings, and annual meetings. The GSCR is a public document which is shared with grantees and is maintained in the contract files for review by auditors. When used for program certification, the GSCR must contain adequate information to document board compliance and significant progress toward achieving the goals and indicators stated in the approved CSBG Work Plan. The GSCR may also document the results of assistance provided by program analysts and must be stated in terms of outcomes versus performance.
Page 1 of the GSCR asks for general and identifying information, such as grantee name, date of contact, duration, federal fiscal year, contract number, purpose of contact, and personnel or board members contacted. Checking appropriate certification information under “Purpose/Results of Contact” is required.
Description of the Purpose/Results of Contact:
Determine if CSBG funds are being used according to the approved budget and in compliance with applicable fiscal regulations, policies, and procedures.
Determine whether services and activities complement, duplicate, or overlap other related services and activities.
Determine if technical assistance and/or training is needed or requested.
Verify compliance with applicable laws, rules, regulations, policies, and procedures.
Verify the procedures for reporting program progress and effectiveness.
Verify information provided by grantee staff in written reports or in interviews.
Verify comprehensive assessment determining factors and indicators.
Develop an Individual Monitoring Plan.
Verify board compliance.
| Required: 1) Program analyst signature; 2) supervisor initials; and, 3) program director signature. |
Pages 2 and 3 of the GSCR contain the following items. All sections require clear and objective information.
Grantee Concerns/Questions/Update – regarding Fiscal, Board, Administrative, Program, or Other.
Documents Reviewed – note any and all documents reviewed during the contact.
Technical Assistance Provided – check all that apply and give a brief description.
Training Opportunities Provided or Referral Made – provide a description of the training provided; or, list the referral.
Findings or Observations – cite instance(s) of compliance and noncompliance, and areas that may require improvement; reference specific documents that support the observation or finding.
Recommendations and/or Follow-up Activities, including the Timeframe and Expected Results - should contain recommendations made for corrective actions as well as support offered to facilitate compliance; recommendations should be appropriate, feasible, reasonable, and include a time frame for implementation.
Date and Purpose/Expected Results of Next Visit – describe briefly.
Preparing and Processing the GSCR – The GSCR should be complete, accurate, objective, and concise. Reports should give readers adequate and correct understanding of the extent and significance of reported findings and observations. The GSCR may include a statement about any pertinent information omitted because it was deemed confidential or because additional research is necessary. In those instances, a memo should be prepared by the program analyst stating the concern and the actions necessary to obtain additional information. The DCS division director will be responsible for follow-up to ensure resolution of the concern and to keep DOS Executive Office informed.
If there are concerns regarding observations, findings and recommendations, they should be discussed with the program analyst’s supervisor and the division director prior to submitting the report for processing and distribution. Subsequent to review by supervisor, the program analyst forwards an electronic copy to the Contract Review Unit (CRU), supervisor, fiscal representative, grantee, and division director. [For Certification #3 and #4: Subsequent to review by supervisor, a hard copy of the GSCR along with the PPR will be submitted to CRU for processing. An electronic copy of the GSCR will be shared with team members and grantees.]
The Contract Review Unit is responsible for posting the document on the database; then, CRU will print and forward it to the division director for signature and DCS filing.
It is the responsibility of the program analyst to ensure that: a) all required visits are made; b) supervisors, grantees, and fiscal representatives receive a copy of each report; c) a file for each assigned agency is maintained; and, d) a record of all contacts is available.
Fiscal Monitoring
Fiscal representatives conduct on-site visits for the primary purpose of monitoring expenditure and accountability of CSBG and local share funds. Monitoring includes a general review of the overall fiscal integrity of the grantee, as well as an in-depth review of selected fiscal activities. Samples of grantee expenditures are tested for compliance with the contract and with Generally Accepted Accounting Principles. Fiscal representatives review financial reports submitted to grantee boards of directors. Staff determine adequacy of systems and controls in place to safeguard CSBG funds and determine if these funds are being used according to the approved budget.
In addition to on-site reviews, fiscal representatives provide fiscal technical assistance, as well as review and approval of the annual audits of each CSBG grantee. As a condition of the contract, each recipient must comply with requirements of OMB Circular A-133.
General Responsibilities
- Follow up on the Grantee Comprehensive Assessment Protocol findings (Fiscal Functions section).
- Make on-site visits and submit a Fiscal Monitoring Report.
- Conduct a comprehensive financial assessment.
- Prepare and submit written reports to the supervisor of fiscal field operations with copies to the DCS director and program analyst.
- Provide technical assistance to grantee fiscal staff and finance committee/board members, as needed.
- Participate in refunding conferences.
- Collect and review refunding applications, contracts, amendments, financial reports, Unaudited Financial Statements, and OMB required reports.
- Maintain telephone and/or e-mail contact with grantees.
Performance Standards for Monitoring Activities
- Assessments are conducted based on agreed schedules and according to the processes and procedures stated in the Monitoring Guide. All reports are prepared and submitted in a timely manner. On-going monitoring is conducted to ensure that findings are corrected through the implementation of recommendations made in the reports. When necessary, fiscal support is provided.
- On-site visits are scheduled approximately four times a year based upon submission of CSBG Financial Reports and the needs of the agency. On-site visits should ensure that the expenditures charged to CSBG are in compliance with the contract budget, grant award legislation and OMB Circulars regarding the expenditure of federal grant funds.
- Reports of the results of the on-site visit are prepared and discussed with the supervisor of fiscal field operations. The reports are transmitted to the DCS director and the appropriate program analyst. Follow-up is conducted as needed to ensure that any findings noted are corrected by implementation of the recommendations made.
- Technical assistance needs are identified and assistance is provided or training is arranged.
- The refunding conferences scheduled by DCS are attended by fiscal representatives and information and technical assistance is provided as needed.
- All documents are collected from grantees and are reviewed in a timely manner. Information provided by grantees is evaluated to determine that expenditures are made in accordance with the CSBG legislation and OMB Circulars.
- Telephone and/or e-mail contacts are made and technical assistance is provided on an on-going basis.
Scope of Monitoring
On-site Visits - Fiscal representatives will contact assigned grantees to schedule on-site visits. This will be done by telephone or e-mail. The number of visits will vary depending upon reports submitted and the needs of the grantee.During the course of the fiscal year, the fiscal representative will conduct a review of the agency’s accounting records to ensure that the agency is in compliance with applicable laws and federal regulations. Documents reviewed will include, but not be limited to:
- revenue and expenditure reports
- general ledger transactions detail
- payroll registers and allocation reports
- contract budgets
- bank reconciliations
- indirect cost/cost allocation proposals
- invoices, cancelled checks and other disbursement documentation
- time sheets
- local share documentation (if applicable)
- audit
- balance sheets
Technical assistance will be provided as needed or training opportunities will be brought to the attention of the fiscal officer.
Follow-up on any findings as a result of prior visits or comprehensive assessment will be conducted to verify that corrective actions have been taken.
Content of the Fiscal Monitoring Report
Scope - A statement of the financial records and source documentation reviewed during the visit.
Background - A statement of how the documents and records were reviewed and the period covered by the review.
Findings - A statement of the problem(s) noted and the effect on the agency’s records and reports submitted to DOS. Where disallowances are made, the appropriate regulation will be cited.
Recommendations - A statement of the corrective action(s) necessary to bring the agency’s accounting records into compliance with applicable laws and regulations.
Follow-up - A statement that completion of the corrective actions noted in any recommendation will be verified at the next visit.
Comprehensive Assessment on Fiscal Management
The assigned fiscal representative will work in partnership with the team leader in planning and conducting any assessment. The fiscal representative will conduct assessments in accordance with the document developed in conjunction with DCS.
During subsequent fiscal monitoring visits, any findings and recommendations will be followed-up. Verification will be made that corrective actions were taken. When necessary, technical assistance will be provided to assist in the resolution of the finding.
CSBG Grantee Services Contact Report New York State Department of State
Division of Community Services
FFY: ___________________ Contract #: _____________________
Grantee: _______________________________________________________________________________________
Date of Contact: __________________________________ Time: _____________ to _________________
Type: Main Office On-Site Telephone Regional Meeting
Satellite Office On-Site E-Mail/Fax Desk Review (files/documents)
Other _________________________________________________________________________
| Grantee Personnel or Board Members Contacted (include Names and Titles): |
Purpose/Results of Contact: (check all that apply)
Attendance at a Board Meeting (attach a completed Board Meeting form)
Attendance at a Committee Meeting (identify) ______________________________________________________
Certification #1 Review and approval of Refunding Application (attach a completed Document Review Checklist)
Certification #2 Board validation and verification (attach a completed form)
Certification #3 Review and approval of PPR for October to December (attach a completed PPR)
Certification #4 Review and approval of PPR for January to March (attach a completed PPR)
Technical Assistance (identify on next page)
Training Provided (identify on page three)
Referral made (identify on page three)
Other ______________________________________________________________________________
Certification
(as per items checked above)
1) ___________________________________ _______________ 2) _____________________ ________________
Program Analyst (signature) Date Supervisor (initials) Date
3) ___________________________________ _______________
Program Director (signature) Date
Grantee: _______________________________________________________________________________________
Date of Contact: __________________ FFY: ___________ Contract #: _____________
| Grantee Concerns/Questions/Update: | |
| Fiscal: | |
| Board: | |
| Administrative: | |
| Program: | |
| Other: | |
| Documents Reviewed: |
|
Technical Assistance Provided: |
|
Board Governance |
Human Resources |
| Planning | Conflict of Interest |
| ROMA | Grievance Procedures |
| Evaluation | Notification of Head Start PRISM Reviews |
| Partnership | CSBG Assurances and Prohibitions |
| Leadership | Update on Grantee At-Risk, In crisis or Vulnerable |
| Administrative Systems and Procedures | Update on Compliance with Corrective or Quality Improvement Plan |
| Fiscal and OMB Procedures | |
| Other: __________________________________________________________________________________________ | |
| T/A Description (if needed) |
|
Grantee: _________________________________________________________________________________________________
Date of Contact: _________________________________ FFY: _____________ Contract #: ____________________
| Training Opportunities Provided or Referral Made: |
|
| Findings or Observations : |
|
| Recommendations and/or Follow-up Activities, including the Timeframe and Expected Results: |
|
| Date and Purpose/Expected Results of Next Visit: |
|
BOARD MEETING
FFY: ___________ Contract #: ______________
Grantee: __________________________________________________________________________________________________
Date of Contact: ______________________ Time: __________ to ___________________
Meeting Called to Order: ______________ (time) Meeting Adjourned: _________________ (time)
Meeting Chaired By: _______________________________________________________________ (name/title)
Total Number of Seated Board Members: _________________
Total Number Present: _________________
Total Number Needed for Quorum: _________________
Quorum was met (yes or no): _________________
How far in advance? ___________________________________________________________________________
2. Was attendance taken? ___ Yes ___ No
Title of person responsible for keeping attendance records: ___________________________________________
3. Were the minutes of the previous meeting reviewed and approved? ___ Yes ___ No
If applicable, were corrections made to previous minutes? ___ Yes ___ No
4. Executive Director Report
Presentation of Report: ____ Written _____ Oral
| Highlights of Report as Presented: |
|
5. Financial Report
Presentation of Report: ____ Written _____ Oral
Was a financial report prepared and distributed? ____ Yes _____ No
| Highlights of Report as Presented: |
|
6. Committee Reports
| The committees presenting reports: |
|
Grantee: __________________________________________________________________________________________________
Date of Contact: ______________________ FFY: ___________ Contract #: ______________
7. Program Report
Presentation of Report: ____ Written _____ Oral
| Highlights of Report as Presented: |
|
8. Old/New Business
| Highlights, if applicable: |
|
| Recommendations for Board Actions/Resolutions: |
|
9. Program Analyst observations/comments, including, but not limited to:
| Board member preparedness and participation: |
|
| Meeting procedures followed/agenda followed: |
|
Adequacy of physical arrangements, (i.e. tables/chairs, room size, acoustics, translation/ interpretation services, etc.): |
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| Staff present/Others present: |
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| Other Comments: |
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