Risk Analysis

So how do we choose who gets monitored?

HQ gives each Field Office a monitoring goal they must meet.

Each year HUD reviews all of its grantees and scores them on certain risk factors to determine who will be monitored in that year.

Risk AnalysisFactors that are reviewed

1.) Financial

2.) Physical

3.) Management

4.) Satisfaction

5.) Services

Monitoring Work Plan Field Office creates a Work Plan based

on the Risk Analysis

Monitoring reviews are tentatively scheduled for the year

Most reviews are done on-site, however sometimes remote reviews are conducted.

Monitoring Exhibits

The HUD monitoring manual includes six possible checklists that can be used to review S+C grants.

Project ProgressS+C HousingS+C ClientsS+C Match DocumentationS+C Subrecipient ManagementS+C Overall Grant Management

Other Federal Requirements Lead Based Paint

Visual assessmentsLead Pamphlet

Civil Rights/Fair HousingAffirmative marketingCollection of demographic dataAccessibility

File Sampling

Normally, HUD staff will

Request a list of all participants from a certain time period

Select a sample of files from that list to review

However, HUD can expand the file sample if needed.

Staff Interviews In addition to file reviews, HUD staff will

also likely interview staff to discuss the program.

Each program is different but common staff interviewed include:Executive DirectorProgram DirectorHousing SpecialistFinancial Officer/AccountantCase Manager

Areas of emphasis

Client eligibility and Service provision Unit Inspection and Rent Calculation Draw Review Program Administration and Due

Process

Client Eligibility and Services Eligibility

Homeless documentationDisability documentation

Services AppropriateOngoing needs assessmentAdequate match amount provided

Unit Inspection and Rent Calculation Unit Inspection

HQS inspection done

Rental Calculation and documentation

Contract Rent - Tenant Contribution = S+C Subsidy

Contract rent is based on rent reasonablenessTenant contribution is based on income

Draw reviews

Sometimes HUD staff will select a few draws from LOCCS for review

We would be looking for Adequate source documentation

for the draw amountSound overall financial

management

Program Administration Written procedures or program

guidelinesIncluding participant termination due

process policies

Grantee-Sponsor communication and division of duties

Administration costs and documentation

After the visit Exit Conference

Discuss the results of the review and likely outcome

Monitoring LetterHUD has 45 days after the exit conference to

send out a letter that details the results of the review and any findings and correction actions

Monitoring ResponseNormally HUD requests a response to the

monitoring letter within 30 days (if there are findings to resolve)

Findings vs Concerns

FindingDeficiency based on a statutory, regulatory

or program requirement for which sanctions or other corrective actions are authorized. Grantee MUST respond to findings.

ConcernPotential deficiency or performance issue

that could lead to future finding. Sanctions or corrective actions are not authorized for concerns.

Common Monitoring Findings Homelessness Documentation

Rent Calculation

Service Match documentation

HQS Standards

Homeless/formerly homeless participation on Board