Grantee Learning Series for COVID-19 Relief Programs: Monitoring (U.S. Department of Education, August 2, 2023)
Summary
U.S. Department of Education slide presentation, Grantee Learning Series for COVID-19 Relief Programs on Monitoring, dated August 2, 2023, from the Office of State and Grantee Relations. The slides state the objectives of understanding the office's framework for oversight of pandemic-relief programs and the components of each type of monitoring, and review the requirements of pass-through entities under 2 C.F.R. § 200.332. They describe a Performance Review Framework with routine monitoring, including monthly check-ins launched in fall 2022, and formal monitoring such as targeted and biannual reviews. The text is the Department's own presentation and ends mid-slide.
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“Grantee Learning Series for COVID-19 Relief Programs: Monitoring (U.S. Department of Education, August 2, 2023).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-presentation-www-ed-gov-74b7a6e4fd/
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Grantee Learning
Series for COVID-19 Relief
Programs
The Office of State and Grantee Relations
Date: August 2, 2023
Chris Fenton, Program Officer, Office of State and Grantee Relations
Christopher Tate, Group Leader, Office of State and Grantee Relations
1
Monitoring
2
Objectives
Participants in this meeting will:
1. Understand SGR’s framework for providing oversight
for pandemic-relief programs
2. Know both the components of each type of
monitoring conducted by the program office and the
focus of each monitoring type
U.S. Department of Education 3
Agenda
1. 2 C.F.R.§200.332 Requirements of Pass-Through Entities
2. Performance Review Framework
3. Routine Monitoring
4. Formal Monitoring
5. FY 2023 and FY 2024 Review Schedule
U.S. Department of Education 4
2 C.F.R.§200.332 Requirements of Pass-Through
Entities
(a) Ensure that every subaward is (d) Monitor the activities of the (f) Verify that every subrecipient is
clearly identified to the subrecipient as necessary to ensure audited when it is expected that
subrecipient as a subaward and that the subaward is used for the subrecipient's Federal awards
includes the following information authorized purposes, in compliance expended during the respective
at the time of the subaward and if with Federal statutes, regulations, fiscal year equaled or exceeded the
any of these data elements and the terms and conditions of the determined threshold.
change, include the changes in subaward; and that subaward (g) Consider whether the results of the
subsequent subaward performance goals are achieved. subrecipient's audits, on-site
modification. (e) Depending upon the pass-through reviews, or other monitoring
(b) Evaluate each subrecipient's risk of entity's assessment of risk posed by indicate conditions that necessitate
noncompliance with Federal the subrecipient the following adjustments to the pass-through
statutes, regulations, and the monitoring tools may be useful for entity's own records.
terms and conditions of the the pass-through entity to ensure (h) Consider taking enforcement action
subaward for purposes of proper accountability and against noncompliant
determining the appropriate compliance with program subrecipients.
subrecipient monitoring. requirements and achievement of
(c) Consider imposing specific performance goals.
subaward conditions upon a
subrecipient if appropriate.
U.S. Department of Education 5
Performance Review Framework
MOEq
Late
MOE
Liquidation
Annual
Performance Audits
Reporting
Review Domains
FFATA
Reporting Monitoring
Initial
C&A
Reports
U.S. Department of Education 6
Performance Review Framework
Routine Monitoring Formal Monitoring
- Grantees identified based on an assessment
- Ongoing of risk that considers fiscal data, drawdown
patterns, audit information, administrative
- Less structured capacity, timeliness and quality of
- Proactive identification of technical issue performance reporting
- Collaborative problem-solving - Standardized compliance review for all
- Provision of timely technical assistance identified grantees
-Targeted Monitoring
-Drawdown analyses
-Biannual Reviews
-FFATA reporting analyses
-Comprehensive Monitoring
-Monthly check-ins
-Consolidated Monitoring
U.S. Department of Education 7
Routine Monitoring-Monthly Check-ins
• Launched in fall of 2022 with the intent to improve communication with grantees
• Focus on information sharing and technical assistance to inform continuous
improvement of grant implementation
• Collaborative agenda intended to proactively identify and address grantee issues
• Timely topics identified based on the grants administration cycle and calendar
• Drawdown analysis
• Late Liquidation Requests
• FFATA Reporting
Monthly calls are resuming in August!
U.S. Department of Education 8
Formal Monitoring-Targeted & Biannual
Reviews
• Identified if there is a risk of noncompliance based on a grantee’s course of action
during the performance period
• Focused on specific topic or set of topics (e.g., cash management)
• Targeted monitoring also occurs:
• Annually for the unique Maintenance of Effort and Maintenance of Equity
provisions required by the pandemic relief Acts
• Biannually for all 50 States, the District of Columbia, and Puerto Rico on a
timely, high-priority aspect of program implementation
• The goals of these reviews are to-
• Identify practices that can be shared across States
• Identify technical assistance needs
• Inform areas where additional monitoring is needed
U.S. Department of Education 9
Formal Monitoring- Comprehensive and Consolidated
Comprehensive Monitoring
• Consists of a full programmatic and fiscal review focused on a grantee’s
implementation of the pandemic relief programs
• This type of monitoring evaluates the systems and processes a grantee uses to
implement its programs (including the grantee’s accounting systems and fiscal
controls, internal controls, personnel, allocations, budgeting, and subrecipient
monitoring)
• Led by SGR and the grantee’s program officer
Consolidated Monitoring
• A cross-program review of a grantee’s implementation of its K-12 formula grants, for both
pandemic relief funding and Elementary and Secondary Education Act of 1965 formula grant
programs
• Led by the Management Support Office, in collaboration with the grantee’s program officer
U.S. Department of Education 1
0
Formal Monitoring- Comprehensive and Consolidated
Timeline & Expectations*
90 days prior to the review:
• Grantee is notified of the Department’s intent to monitor
• Dates for the review are identified
• Protocols are shared and the grantees begin compiling documentation and
completing self-assessments
• 2 grantee subrecipient’s are identified and begin compiling documentation and
completing self-assessments
30 days prior to the review:
• Grantee and subrecipient documentation and self-assessments are submitted
to the Department for review
15 days prior to the review:
• Grantee receives the final meeting agenda, including additional questions
* The Comprehensive Monitoring timeline, managed by SGR, is shared in this
presentation. The activities and timeline for Consolidated Monitoring, managed by
the Management Support Office, are slightly different.
U.S. Department of Education 1
1
Formal Monitoring- Comprehensive and Consolidated
Timeline & Expectations cont.
Within 5 days of the review:
• The Department will coordinate with the grantee to receive any additional
information requested during the review
Within 25 days of the review:
• Grantee receives a draft of the monitoring report for review and to provide
technical edits
• A conference call is conducted to review determinations made as a result of
monitoring
Within 30 days of the review:
• Grantee submits technical edits to the Department
• The monitoring reporting is published
Within 30 days of publishing the final report:
• Corrective actions are due to the Department
U.S. Department of Education 1
2
Formal Monitoring- Protocols and Reports
Fiscal Elements Elementary and Emergency Governor’s
Secondary School Assistance to Non- Emergency
Emergency Relief Fund Public Schools Education Relief
Funds
- Accounting Systems - State Context - Governor’s Office - State Context
and Fiscal Controls - Grantee Budgeting - State Educational - Budgeting for the
- Cash Management (Administrative and State Agency Administrative
and Payment Activities) Reservation and
Systems - Allocations/Sub-Award Subawards
- Period of Availability Process - Allocations/Sub-Award
- Internal Controls - Transparency Act Reporting Process
- Audit Requirements - Risk Assessment of LEAs - Transparency Act
- Records and and Other Subrecipients Reporting
Information - Subrecipient Monitoring - Risk Assessment of
Management - Equitable Services Subrecipients
- Equipment and - Liquidation Extension - Subrecipient Monitoring
Supplies Requests - Equitable Services
Management - Liquidation Extension
- Personnel Requests
- Procurement
- Indirect Costs
Monitoring reports are located on SGR’s website.
1
U.S. Department of Education 3
FY 2023 & FY 2024 Monitoring Schedule
Biannual Reviews
FY 2023, Quarter 2 (January-March)
• Review of grantees’ awarding of GEER funds and subrecipient oversight
FY 2024, Quarter 1 (October-December)
• Review protocol to be shared in September
• Reviews will occur October/November
• ARP ESSER will be the focus, but the subtopic is TBD
Consolidated and Comprehensive Monitoring
FY 2023
• Florida Consolidated Monitoring, November 2022
• Washington Consolidated Monitoring, February 2023
• Maine Consolidated Monitoring, May 2023
• New Mexico Consolidated Monitoring: September 2023
• New Jersey Comprehensive Monitoring, September 2023
FY 2024
• The Department will identify grantees for Comprehensive and Consolidated Monitoring
starting in August
U.S. Department of Education 1
4
QUESTIONS
15
Thank You
16
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