OMB Monitoring Provisions
Office of Management and Budget
http://www.whitehouse.gov/omb/index.html
MAASFEP 2005 NCLB Program Monitoring http://www.whitehouse.gov/omb/circulars/a133_compliance/04/ed.pdf
Subrecipient Monitoring Provision Excerpts
OMB, A-102 Common Rule, Sec.__ 40, Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments, Monitoring and reporting program performance:
(a) Monitoring by grantees. Grantees are responsible for managing the day-today operations of grant and subgrant supported activities. Grantees must monitor grant and subgrant supported activities to assure compliance with applicable Federal requirements and that performance.
OMB, A-110, Sec.__.51, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations, Monitoring and reporting program performance:
(a) Recipients are responsible for managing and monitoring each project, program, subaward, function or activity supported by the award. Recipients shall monitor subawards to ensure subrecipients have met the audit requirements as delineated in __.26.
OMB, A-133, __400, Audits of States, Local Governments and Nonprofit Organizations:
(d) Pass-through entity responsibilities. A pass-through entity shall perform the following for the Federal awards it makes:
(3) Monitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contacts or grant agreements and that performance goals are achieved.
OMB A-133 Compliance Supplement, 2004 Edition Part 3, Compliance Requirements:
M. SUBRECIPIENT MONITORING
Compliance Requirements, During-the-Award Monitoring:
Following are examples of factors that may affect the natures, timing, and extent of during-the-award monitoring:
• Program Complexity – Programs with complex compliance requirements have a higher risk of non-compliance
• Percentage passed through – The larger the percentage of program awards passed through the greater the need for subrecipient monitoring.
• Amount of awards – Larger dollar awards are of greater risk.
• Subrecipient risk – Subrecipients may be evaluated as higher or lower risk to determine the need for closer monitoring. Generally, new subrecipients would require closer monitoring. For existing subrecipients, based on results of during-the-award monitoring and subrecipient audits, a subrecipient may warrant closer monitoring as either a recipient or subrecipient, (2) new personnel, or (3) new or substantially changed systems.]
OMB, A-102 Common Rule, B. Requirements Regarding High-risk Grantees
Sec. 12 Special grant or sub grant conditions for “high-risk” grantees.
(a) A grantee or subgrantee may be considered “high-risk” if an awarding agency determines that a grantee or subgrantee:
(1) Has a history of unsatisfactory performance, or
(2) Is not financially stable, or
(3) Has a management system which does not meet the management standards set forth in this part, or
(4) Has not conformed to terms and conditions of previous awards, or
(5) Is otherwise not responsible; and if the awarding agency determines that an award will be made, special conditions and/or restrictions shall correspond to the high risk condition and shall be included in the award.
(b) Special conditions or restrictions may include:
(1) Payment on a reimbursement basis;
(2) Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given funding period;
(3) Requiring additional, more detailed financial reports;
(4) Additional project monitoring (includes reporting, site visits & contact);
(5) Requiring the grantee or subgrantee to obtain technical or management assistance;
(6) Establishing additional prior approvals.
(c) If an awarding agency decides to impose such conditions, the awarding official will notify the grantee or subgrantee as early as possible, in writing, of:
(1) The nature of the special conditions/restrictions;
(2) The reason(s) for imposing them;
(3) The corrective actions which must be taken before they will be removed and the time allowed for completing the corrective actions and
(4) The method of requesting reconsideration of the conditions/restrictions imposed.
OMB Circular A-110, __.14 Special award conditions
If an applicant or recipient: (a) has a history of poor performance, (b) is not financially stable, (c) has a management system that does not meet the standards prescribed in this Circular, (d) has not conformed to the terms and conditions of a previous award, or (e) is not otherwise responsible, Federal awarding agencies may impose additional requirements as needed, provided that such applicant or recipient is notified in writing as to: the nature of additional requirements, the reason why the additional requirements are being imposed, the nature of the coorective action needed, the time allowed for completing the coorective actions, and the method for requesting reconsideration of the additional requirements imposed. Any special conditions shall be promptly removed once the conditions that prompted them have been corrected.
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