Monitoring Monitoring ScheduleSchedule

David Chappell, 202-401-David Chappell, 202-401-9356 or 9356 or

David.Chappell@acf.hhs.gDavid.Chappell@acf.hhs.govov

Monitoring ScheduleMonitoring ScheduleSix Criteria UsedSix Criteria Used

To comply with GAO’s recommendations and other To comply with GAO’s recommendations and other Federal standards, we evaluated the states based on Federal standards, we evaluated the states based on six criteria:six criteria:

1.1. The DSA Agency Status List - Eligible Entities who The DSA Agency Status List - Eligible Entities who have been identified by their State as Vulnerable, In have been identified by their State as Vulnerable, In Crisis, Terminated;Crisis, Terminated;

2.2. Distance - the complexity of monitoring compared to Distance - the complexity of monitoring compared to the state’s physical size, the total number of eligible the state’s physical size, the total number of eligible entities in the state, and the personnel resources the entities in the state, and the personnel resources the state allocated to its CSBG Program;state allocated to its CSBG Program;

3.3. Poverty - the population living at or below 100% of Poverty - the population living at or below 100% of the poverty level compared to the total number of the poverty level compared to the total number of eligible entities in the state, and the personnel eligible entities in the state, and the personnel resources the state allocated to CSBG;resources the state allocated to CSBG;

Monitoring ScheduleMonitoring ScheduleSix Criteria Used (Cont.)Six Criteria Used (Cont.)

4.4. Client population – the number of people Client population – the number of people receiving service compared to the total number receiving service compared to the total number of eligible entities in the state, and the of eligible entities in the state, and the personnel resources the state allocated to personnel resources the state allocated to CSBG. CSBG.

5.5. Evidence of past problems as reflected by OMB Evidence of past problems as reflected by OMB Circular A-133 audit reports; andCircular A-133 audit reports; and

6.6. Timeliness- ranking of States who have been Timeliness- ranking of States who have been late in the submission of their CSBG State late in the submission of their CSBG State Plans or the NASCP Information Survey Plans or the NASCP Information Survey

Monitoring ScheduleMonitoring ScheduleCriteria Under Criteria Under ConsiderationConsideration

State PlansState Plans. DSA staff choose the most . DSA staff choose the most detailed, innovative state plans. detailed, innovative state plans.

State AuditsState Audits. States notify DSA when an . States notify DSA when an audit had been conducted. (A DSA audit had been conducted. (A DSA monitoring visit may not be necessary.)monitoring visit may not be necessary.)

An alternate state self assessmentAn alternate state self assessment. . Possibly including: Possibly including:

Staff Staff experience and turn-overexperience and turn-over Evaluations conducted by other agenciesEvaluations conducted by other agencies Other Criteria suggested by the statesOther Criteria suggested by the states

Monitoring ScheduleMonitoring ScheduleThree Year ScheduleThree Year Schedule

Annual schedule will be published by Information Annual schedule will be published by Information Memorandum: Memorandum:

Three Financial EvaluationsThree Financial Evaluations

Two-week visitsTwo-week visits Four Financial Team members and Two Program Team membersFour Financial Team members and Two Program Team members

Two Program EvaluationsTwo Program Evaluations

Four day visitsFour day visits Two Program Team members and two Financial Team membersTwo Program Team members and two Financial Team members

Four Desk Reviews: Four Desk Reviews:

Documentation reviewDocumentation review Two Program and one Finance Team members Two Program and one Finance Team members

FINANCIAL FINANCIAL EVALUATIONSEVALUATIONS

David Chappell, 202-401-David Chappell, 202-401-9356 or 9356 or

David.Chappell@acf.hhs.gDavid.Chappell@acf.hhs.govov

Financial EvaluationsFinancial EvaluationsThe CSBG LawThe CSBG Law

(a)(a) Fiscal controls, procedures, audits, and inspections Fiscal controls, procedures, audits, and inspections

(1)(1) In general In general A State that receives funds under this chapter shallA State that receives funds under this chapter shall— —

(A) establish fiscal control and fund accounting procedures (A) establish fiscal control and fund accounting procedures necessary to assure the proper disbursal of and accounting for necessary to assure the proper disbursal of and accounting for Federal funds paidFederal funds paid to the State under this chapter, including to the State under this chapter, including procedures for monitoring the funds provided under this chapter; procedures for monitoring the funds provided under this chapter;

(B) ensure that cost and accounting standards of the Office of (B) ensure that cost and accounting standards of the Office of Management and Budget applyManagement and Budget apply to a recipient of the funds under this to a recipient of the funds under this chapter; chapter;

(C) (C) subject to paragraph (2), subject to paragraph (2), prepare, at least every year, an audit of prepare, at least every year, an audit of the expenditures of the Statethe expenditures of the State of amounts received under this chapter of amounts received under this chapter and amounts transferred to carry out the purposes of this chapter; and and amounts transferred to carry out the purposes of this chapter; and

(D) make appropriate books, documents, papers, and records (D) make appropriate books, documents, papers, and records available to the Secretaryavailable to the Secretary and the Comptroller General of the United and the Comptroller General of the United States, or any of their duly authorized representatives, for examination, States, or any of their duly authorized representatives, for examination, copying, or mechanical reproduction on or off the premises of the copying, or mechanical reproduction on or off the premises of the appropriate entity upon a reasonable request for the items. appropriate entity upon a reasonable request for the items.

Financial Evaluations Financial Evaluations Prior to the VisitPrior to the Visit

Schedule Entrance Conference (notify State by Schedule Entrance Conference (notify State by phone & follow up with phone & follow up with letterletter))

Request background information from the State:Request background information from the State:

Copies of most recent A-133 Audits and State Copies of most recent A-133 Audits and State AuditsAudits

Copies of most recent monitoring reportsCopies of most recent monitoring reports

Download of State financial system CSBG Download of State financial system CSBG transactionstransactions

Accounting procedures and policiesAccounting procedures and policies

ROMA data ROMA data

Financial Evaluations Financial Evaluations Prior to the Visit (Cont.)Prior to the Visit (Cont.)

Review information and select CAAs to visitReview information and select CAAs to visit

Agree on objectives and site visit schedule Agree on objectives and site visit schedule with with State CSBG directorState CSBG director

Design visit specific evaluation guideDesign visit specific evaluation guide

Assess internal controls including:Assess internal controls including:

The thoroughness of the State’s monitoring The thoroughness of the State’s monitoring

Selected agencies’ policies and proceduresSelected agencies’ policies and procedures

Financial Evaluations Financial Evaluations During the Site VisitDuring the Site Visit

At the State CSBG OfficeAt the State CSBG Office

Conduct Entrance ConferenceConduct Entrance Conference

Assess internal controlsAssess internal controls

Review and verify:Review and verify: Statutory AssurancesStatutory Assurances

Financial DataFinancial Data

ROMA Procedures and DataROMA Procedures and Data

State Monitoring ProcessState Monitoring Process

Financial Evaluations Financial Evaluations During the Site Visit (Cont.)During the Site Visit (Cont.)

At Selected Community Action AgenciesAt Selected Community Action Agencies

Verify that State’s oversight through:Verify that State’s oversight through:

Interviews with directors and board membersInterviews with directors and board members

Interviews with people responsible for Interviews with people responsible for functional areas: functional areas: PersonnelPersonnel

FiscalFiscal

PropertyProperty

Case Management and ROMACase Management and ROMA

Financial Evaluations Financial Evaluations Generic Site Visit ScheduleGeneric Site Visit Schedule

Entrance Conference Team Team Leader Leader (TL) at (TL) at State State OfficeOffice

Evaluator 1 begins 1st

CAA TL finishes State Office

Evaluator 2 begins at 2nd CAA

TL assists

Evaluator 2 continues at 2nd CAA

TL assists

Evaluator 2 finishes 2nd CAA Evaluator 3 begins 3rd CAA

• Evaluator 3 continues at 3rd CAA

• TL assists

• Evaluator 3 finishes 3rd CAA • TL conducts Exit Conference

TL continues Evaluation at the State Office

Evaluator 1 continues at 1st CAA

TL assists

Evaluator 1 finishes at 1st CAA

TL assists

Monday Tuesday Wednesday Thursday Friday

Financial Evaluations Financial Evaluations After the Site VisitAfter the Site Visit

Continue evaluating and cross checking Continue evaluating and cross checking datadata

DocumentDocument evaluations and judgments evaluations and judgments Write Draft Report Write Draft Report Provide Draft to State and let them Provide Draft to State and let them

respond respond Provide Final Report to State incorporating Provide Final Report to State incorporating

the State’s commentsthe State’s comments Conduct Post-Evaluation Critique Conduct Post-Evaluation Critique

Financial Evaluations Financial Evaluations SummarySummary

Before Site Visit Schedule Visit & Request Info State Provides Information Analyze & Survey Information

Site Visit About three days at the State Office About three days at selected agencies

After Site Visit Document evaluation Write Draft Report Provide Draft to State Provide Final Report to State

Questions and Questions and AnswersAnswers

Peter ThompsonPeter Thompson