# Presentation: 226046

## MANAGING VETSCOMPETITIVE GRANTS

- VETERANS’ EMPLOYMENT
-  AND
-  TRAINING SERVICE
-  HVRP & VWIP GRANTS

**Notes:**
We will be providing an overview of what it takes to effectively manage vets competitive grants

## ASPECTS OF HVRP/VWIP GRANTS

**Solicitation**
**Application**
**Notice of Award**
**Grant Law & Regulations**
**Oversight Responsibilities**
**	****Quarterly Desk Review**
**	****Annual On-Site Review**
**	****Technical Assistance**

**Notes:**
These are some of the more important aspect of our grants.  We will cover each aspect individually & talk about they are interlinked.  Our feeling is the better we understand the requirements set forth in the SGA, the commitment made by grantees, and the laws & regs governing the process, the better job we will do managing these grants.

## GRANT LAW & REGULATIONS 

**Notes:**
Grant law & regulations are the overarching aspect of grants.  They control what occurs throughout the grant process.  Grant policy is based on laws and regulations governing the administration of DOL grants.

## SOLICITATION OF GRANT APPLICATION

**Participant Eligibility**
**Program Concept and Emphasis**
**Scope of Program Design**
**Results-Oriented Model**
**Required Content**
**Proposal Content**
**Cost Proposal Narrative**

**Notes:**
Here we have the various components of the SGA;  we will discuss each one individually.  For ease of discussion, we will base this presentation on HVRP grant requirements.  Acknowledging the fact some specific VWIP requirements may be different however, the concept remains the same.

## PARTICIPANT ELIGIBILITY

**Individuals must be homeless veterans**
**Persons who lack a fixed regular nighttime residence**
**Those in public or private temporary shelters**
**Private place not designed as sleeping accommodations for human beings (42 USC 11302(a))**
**Persons who served on active duty & discharge other than dishonorable (38 USC 101(2))**

**Notes:**
This slide shows the requirements for HVRP participant eligibility; VWIP participants must meet the veteran status and must also meet at least one of the following characteristic requirements: A service-connected disability; significant barriers to employment; have served on active duty in the armed forces during a war or in a campaign or expedition for which a campaign badge has been authorized; be a recently separated veteran (within 48 months of release or discharge).

## PROGRAM CONCEPT AND EMPHASIS

**To provide services to assist in reintegrating homeless veterans into meaningful employment within the labor force**
**To stimulate the development of effective service delivery systems to address complex problems facing homeless veterans**

**Notes:**
Here we have the concept & emphasis.  The emphasis for the grantee is to act as an agent or conduit, if you will, with other agencies to effect improvement in the delivery of services to clients.

## SCOPE OF PROGRAM DESIGN

**Core services**
**Coordination with veterans’ services programs & others**
**Referrals to necessary treatment & rehabilitative services**
**Referral to housing assistance**
**Employment and training services**

**Notes:**
Here we outline the required components of a grantee’s program design.  It delineates the required services to be provided by grantees, and the linkages they need to develop in order to take a holistic approach to meeting client needs.

## RESULTS-ORIENTED MODEL

**Applicant must design a program that is responsive to the local needs of homeless veterans**
**Carry out the objective to successfully reintegrate homeless veterans into the workforce**
**Discuss steps/processes to be taken to achieve successful reintegration of clients**

**Notes:**
Grantees must focus on meeting the needs of their clients, their goal must achieving positive outcomes, not just processes, and they need to tell us how they are going to achieve these results.

## REQUIRED CONTENT

- SEVEN CORE PROGRAM ACTIVITIES (employment focused)
**Outreach**
**Pre-enrollment assessments**
**EDP’s for all clients**
**Case Management**
**Job Placement & Retention Follow-up at 90 & 180 Days**
**Utilization of DVOP/LVER staff**
**Utilization of linkages with other programs & services which provide support to homeless veterans**

**Notes:**
Here we have the core functions.  Utilization of DV/LV staff as well as other linkages is vitally important.

## PROPOSAL CONTENT, (Part one technical)

**Narrative proposal**
**Outreach component**
**Employment focused**
**Need for program**
**Approach or strategy to increase employment & retention**
**Linkages**
**Supportive services**
**Capability**

**Notes:**
Here we ask for grantees to tell us why their program/services are needed in their community, and how they expect to develop community linkages to meet these needs, and why they feel capable of meeting client’s needs..   

## PROPOSAL CONTENT, (Part two cost)

**Standard Forms,  SF-424 & SF-424A, ****(Budget Information Sheet)**
**Detailed cost breakout of each line item on SF-424A**

**Notes:**
The 424’s are self-explanatory.  The detailed cost breakdown is important because on this form is where they tell us how they expect to utilize grant funds.  It will be necessary for grantees to submit a modification request if they want to deviate from this plan.   

## COST PROPOSAL NARRATIVE

**Breakout of personnel costs by position**
**Explanation & breakout of any extraordinary fringe benefits ****(35% Or More Of Wages)**
**Explanation of purpose & composition of & method to derive costs of:**
**	****Travel, equipment, supplies, sub-****	****awards/contracts, and other costs**

**Notes:**
This is a more detailed explanation of the budget document.  Here for example, they breakdown fractional administrative positions.  It is doubtful that any request for extraordinary benefits would make it through the review & award process w/o negotiation.  We also have applicants explain the need for expenses & how they determine the costs for these expenses.

## APPLICATION

**Must be submitted timely**
**Must be responsive to the SGA**
**Program concept and emphasis**
**Scope of program design**
**Budget information**

**Notes:**
Basically, the application must be responsive to all the requirements set forth in the SGA.  Understanding the application is vitally important because here the grantee is saying if you give me the requested grant dollars, we will do this & this to successfully reintegrate homeless veterans into society.  They are committing to performing what they specify they will do. 

## NOTICE OF AWARD

**Agreement period**
**Funding amount**
**Special provisions**
**General provisions**
**Copy of recipient’s application**
**Recipient’s approved budget**
**Quarterly technical performance goals **

**Notes:**
Here the grant officer is stating:  We feel you have met our requirements now go forth & do great things!  This is the binding contract reiterating the requirements & spelling out our expectations.  It is imperative that the grant provisions be reviewed with the grantee.  These provisions may contain policy changes from previous grant awards.

## SPECIAL PROVISIONS

**Scope**
**Payments/interest earned**
**Reporting requirements**
**Grant administration**
**Travel**
**Printing & duplicating**
**Sub-grants**
**Salary payments**
**Limits on administrative costs**
**Indirect charges**

**Notes:**
The Special Provisions specify requirements & set limits in all of these different areas.  We must become very familiar with both the Special & General provisions; it is also very important for you to ensure your grantee administrators know these provisions.  

## GENERAL PROVISIONS

**Administrative provisions**
**Modifications to grant**
**Allowable costs**
**Interest earned & program interest**
**Property acquisition & management**
**Grant close-out procedures**
**Suspension & termination procedures**
**Encumbrance of grant funds**
**Site visits**
**Order of precedence**

**Notes:**
Cites the Uniform Administrative Requirements governing these grants.  May be unilaterally modified by the GO due to change in statue, regulation or law, and also talks about the need for grant officer approval for any deviation from grant objectives, scope or budget.  Allowable costs refers to OMB Circulars A-87 (govts)  A-122 (non-profits), and A-21( Educational institutions).  Close-out procedures, suspension & termination, encumbrance, site visits & order of precedence.; Special, general provisions & application.

## GRANT LAW AND REGULATIONS

**DOL 29 CFR Subtitle A, Parts 95-99**
**Uniform Administrative Requirements OMB Circulars:**
**  ****A-102 State & Local Governments**
**  ****A-110 Non-Profits**
**Cost Principals OMB Circulars:**
** ****A-87 State & Local Governments  **
** ****A-122 Non-profits**
** ****A-21 Educational Institutions**
**Grant Provisions**

**Notes:**
Administrative requirements deal with the operation of the grants.  Cost principals deal primarily with grantee operating & administrative costs.  Then as before, the grant provisions.

## OVERSIGHT RESPONSIBILITIES

**Develop working relationship with grantee; provide assistance**
**Monitor quarterly reports**
**Analyze reports**
**Complete quarterly desk review with comments on your analysis**
**Conduct annual on-site review**
**Address concerns/deficiencies with grantee**
**Keep your Regional Administrator appraised on any potential problems**

**Notes:**
Having a working relationship is not a responsibility but if you do this, it makes everything else a whole lot easier!  The next thing is to really look at the reports, do an analysis, track the numbers, is the grant being operated according to plan?  Resolve issues before sending the report forward!!!  Work with your grantees, let them know when you see issues & get them resolved.  Another very important responsibility is to Keep management informed of potential problems/issues!!!

##  Grant Monitoring

- DOL/VETS emphasizes thorough monitoring of grantees.
- One of the key roles of the state level DVET in the administration of grants is the monitoring and provision of technical assistance to grantees.
- The “program start date” is the date on which a grantee can legally begin to spend Federal grant funds.

**Notes:**
In most cases, the DVET is appointed as the Grant Officer's Technical Representative (GOTR).
In this function, the DVET/GOTR is responsible for monitoring the grant, providing technical assistance as necessary, identifying any instances of non-compliance, and recommending corrective action.

## Grant Monitoring - continued

- On a basic level, monitoring ensures that grantees comply with the Grant Agreement and all laws, regulations, and policies concerning grants in general, and VETS grants in particular.
- Monitoring should be seen as a largely positive activity.
- VETS uses two methods for obtaining information about grant performance - **desk reviews **and **on-site visits**.

**Notes:**
Not only can monitoring assist in identifying potential challenges and allow for sufficient time in order to find solutions to those challenges, it can help reveal program successes as well.

## QUARTERLY DESK REVIEW

**Profile of the grant**
**Program performance review**
**Past performance**
**Financial review**
**Analysis**
**Summary of the desk review**
**Program Strengths**
**Program Weakness**
**Potential Problematic Areas**

**Notes:**
These are the components of the desk review; you will be addressing each of these areas.

A desk review is a review of reports submitted by the grantee, including the quarterly technical performance report, the financial status report and requests for payment.

As described, each grant recipient is required to file a quarterly technical performance report.

The quarterly technical performance report is also the primary instrument by which the GOTR monitors the progress of a grantee and is one basis for suggesting any necessary corrective action or modification.

Review of the quarterly report is, in part, an exercise in comparing projected to actual performance (PVA). That is, the information provided on the quarterly report on monies actually spent and veterans actually served (and other program goals) are compared to the projected figures contained in the Grant Agreement (or modification, if there is one.)

## Desk Review

- A review of this information can therefore:
- 	·  Identify potential or existing problem areas;
- 	·  Provide background information  concerning program design, operational procedures and previous monitoring activities; and
- 	·  Identify the priorities/activities to be reviewed during the on-site visit.

**Notes:**
The DVET uses all three of these methods in the monitoring of grantees. The following sections describe more fully both desk reviews and on-site visits.
The quarterly technical performance report is the primary source for statistical reports to both Congress and the public on the performance of VETS programs.
The GOTR, whether the DVET, ADVET, or a Grant Specialist in the VETS National Office, is responsible for preparing the Quarterly Grant Summary.

## Desk Review - continued 

- Each program year quarter, the GOTR’s desk review will include an assessment of the Quarterly Technical Performance Report including the grantee’s expenditures;
- The GOTR reviews the Financial Status Report (SF-269) and compares it with the quarterly HHS 272, and
- review of other pertinent narrative data, such as previous monitoring reports and Corrective Action Plans.

**Notes:**
Any discrepancies (plus or minus a 15 percent variance) between those documents and between planned and actual expenditures are noted on the monitoring instrument as part of the desk review.
If available, monitoring reports from state or other Federal sources, is also completed.

## Reporting and GrantMonitoring - Grantee Reporting Requirements

- Throughout the grant period and following the end of the grant period, grantees are required to submit reports on both the programmatic and financial status of the grant program;
- Reporting instructions are covered in the grant Special Provisions.

**Notes:**
To be in compliance with the award provisions, grantees are required to submit the following reports.

## Reporting and GrantMonitoring - Grantee Reporting Requirements

**Technical Performance Reports **– The grantee must submit a Quarterly Technical Performance Report 30 days after the end of each Federal fiscal quarter as per the most recent guidance;
- This report must contain the following:
- 	1. A comparison of actual accomplishments to established goals for the reporting
- 	period, and any findings related to monitoring efforts; and
- 	2. An explanation for variances of plus or minus 15 percent of planned program and/or expenditure goals. The explanation must also include a corrective action plan and timetable.

**Notes:**
The Technical Performance Report is divided into two parts, and both are submitted on a quarterly basis.
First, the grantee must complete a standard format which contains such information as the number of Federal dollars expended, the amount of non-federal funds spent, if applicable, and the number of veterans served.  
Second, each grantee is expected to file a written report on the grant program. The narrative should do more than simply put into textual format the data already shown on the standard form. 

Until we once again have access to VOPAR, all reports are to be submitted to the GOTR electronically.  For grantees with HV designation in their grant number are to submit via E-grants.

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

- It should explain, in some detail, what is happening in the program and why. If some aspects of the program are doing much better than expected, the grantee should explain why;
- If other aspects are not on target, the grantee should both offer an explanation and describe what is being done to improve performance in those areas;
- If the grantee foresees the need to change the program schedule or anticipates problems, this report should address this explicitly.

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

**Financial Reports **– The grantee must report outlays, program income, and other financial information on a quarterly basis no later than 30 days after the ending date of each Federal fiscal quarter during the grant period (i.e., October 30, January 30, April 30 and July 30);
- The financial report is a standard form (SF-269A, Financial Status Report, Short Form) available on the Internet at
**	**_[http://www.whitehouse.gov/omb/grants/sf269a.pdf](http://www.whitehouse.gov/omb/grants/sf269a.pdf)_

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

**Request for Payment **– In addition to these performance status reports, the grantee is required to submit a request for payment in order to process grant payments, on a quarterly basis. (This form is HHS-PMS 272, and is explained at the Post-Award Conference.)
**Ninety (90) Day Report Package **– No later than 120 days after the grant expiration date, the grantee must submit a final report containing the following:

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

- Financial Status Report SF-269;
- Technical Performance Report including updated 90 and 180 day after exit quarter retention in employment data for all participants that entered employment during the active grant performance period.

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

**One Hundred Eighty (180) Day Report **– No later than 210 days after the grant performance period ends, the grantee must submit a follow-up report containing the following:
- 1. Financial Status Report (SF-269A);
- 2. Technical Performance Report with updated data (as in the 90 day report);

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

- Two Hundred Seventy (270) Day Final Report no later than 300 days after the active grant performance period the grantee must submit:
- Final Longitudinal Report;
- Final Financial Status Report (if not already submitted)
- Updated Technical Performance Report
- See Section IV of the Grant Special Provisions for details on reporting requirements.

## Reporting and GrantMonitoring - Grantee Reporting Requirements (continued)

**     ****Issues Affecting Performance Reporting**
- Two aspects of performance reporting have often created challenges (or difficulties) for both the grantee and VETS staff monitoring the grantee in the past. These two issues include properly projecting goals and the period covered by the first quarterly report.
**Projected Goals: **are not accurately stated either in the grant application or the Grant Agreement.
**Period Covered by the First Quarterly Report: **A second issue concerns the period covered by the first quarterly report.

**Notes:**
Frequently, projected goals are not accurately stated either in the grant
application or the Grant Agreement. For example, the applicant may simply divide the annual program goals by four to obtain the quarterly goal figures required in the grant application and in the Grant Agreement (i.e., an applicant proposing to train 100 veterans and place 40 of them in employment over the 12-month period of the grant, might propose that in each quarter of the grant 25 veterans will be trained and 10 placed). Although this approach seems logical, it might present problems relative to achieving the target performance objectives according to the proposed schedule.
In the specific example outline above, it is likely that the applicant proposes to develop a program, publicize it, register veterans, train them, and assist in job placement. It is reasonable to assume that much of the first quarter of the grant will be spent in developing and publicizing the program. Most likely during the first quarter, few veterans will actually be enrolled and trained, and probably none will actually be placed.
Placement is not likely to occur until much later in the program.
A more realistic plan would take this into account and indicate in the grant application incrementally increasing goals that will take place on a quarterly basis. For example, for the goals in this example outlined above, the applicant/grantee might propose to train 10 veterans in the first quarter and 45 in each of the second and third quarters. Placement goals might show 0 for the first and second quarters, 10 in the third, and 30 in the fourth.

The first quarterly report is due at the end of the first Program Quarter during which a program was active. This is true regardless of the length of time between the Program Start Date and the end of that quarter. For example, if a Program Start Date is November 15, a quarterly report is due for the quarter ending December 31 even though there will be only six weeks of program operation, not a full quarter, upon which to report.

## Quarterly Desk Review

- The Desk Review must contain a written summary of the progress and problems (if any) of the grant program;
- The summary is typically no more than one or two pages unless the GOTR has concerns about grantee progress or performance.  In that case, the Summary includes:
- A description of the problem or potential problem;

## Quarterly Desk Review  continued

- A summary of any actions taken to rectify the issue (such as provision of technical assistance, discussions with the grantee, or a request for a Corrective Action Plan (CAP)8 along with the date(s) such action(s) was taken;
- An indication of whether or not a CAP will be required of the grantee;
- An assessment of whether or not a Grant Modification might be necessary; and
- Any additional information required to explain and/or document fully the situation.

## Quarterly Desk Review  continued

- The quarterly review of grantee information is important, both to ensure that the grantee remains in compliance and to help identify potential problems early;
- Equally as important, the desk review is used to prepare for the on-site evaluation and should be
- 	conducted before an on-site visit is scheduled;
- The Quarterly Desk Review is submitted according to current reporting policy.

## Monitoring Visits

- Monitoring visits allow the GOTR to assess in person the operations of a grantee program;
- The purpose of the visit is to provide for a more in-depth review of the grant operation and to help address issues or concerns that have surfaced as a result of the quarterly review of performance reports;

**Notes:**
1) an on-site monitoring visit may be a regularly scheduled review/evaluation, or 2) a special visit triggered by the grantee, something discovered in the quarterly desk review, a complaint, or some other cause.

## Monitoring Visits - continued

- Two factors determine the length and the depth of the monitoring visit – the purpose for the visit and the size and complexity of the grant;
- Regular evaluation visits are completed in the third program quarter of the program year and are intended to review the operation of the entire grant program;
- A special monitoring visit is typically completed to investigate one particular aspect of a grant program;

## Monitoring Visits - continued

- The on-site monitoring process is comprised of five steps:
- 	·  Desk review and on-site review preparation;
- 	·  On-site review;
- 	·  Documentation of Findings (Report);
- 	·  Corrective Action (if necessary); and
- 	·  Follow-up.

**Notes:**
The first step for the monitoring visit involves the GOTR’s off-site review of previously submitted quarterly technical performance reports, as well as the original Grant Agreement, in order to develop the agenda and determine the length of time for the monitoring visit. 

## Monitoring Visits - continued

- The GOTR will consider the following questions about the grantee:
- 	·  Which grantee program components contain potential challenges?
- 	·  Who should be interviewed to identify and understand any concerns?
- (financial, programmatic, or administrative staff, clients/customers, staff from partner organizations, clients, etc.)

## Monitoring Visits - continued

- 	·  What records should be examined and what information gathered?
- 	·  What activities should be observed?
- 	·  What needs to be documented, recorded and reported? Are the grantee’s
- 	    records complete?
- 	·  What questions need to be asked or data collected in order to provide appropriate technical assistance to this grantee?

## MonitoringVisits  - continued

- On-site visits are expected to take one to two days and will typically begin with an “entrance interview” to explain the purpose of the visit, and will end with an “exit interview” to review any initial findings from the visit;
- The GOTR may provide the grantee with an agenda for the on-site visit ahead of time. A typical agenda, as well as checklists for review of financial and other grant program information;
- The GOTR will develop a written *monitoring instrument *to use to collect information about the grantee while on-site.

**Notes:**
VETS COMPETITIVE GRANT DESK REVIEW – document

VETS COMPETITIVE GRANTS ANNUAL ON-SITE REVIEW - document

## Monitoring Visits - continued

- Typical components of the monitoring instrument include:
- 	·  Review of project financial and non-financial records;
- 	·  Review of the administrative and management structure and system;
- 	·  Review of the flow of participants through the program, if applicable;
- 	·  Documentation of visits to work sites and training institutions, if applicable.

**Notes:**
If time permits and if it is determined to be necessary;
	·  Review of other specific items and questions identified during the desk review; and
	·  Exit interview with the project director.

## Monitoring Visits - continued

- Using the monitoring instrument, the GOTR’s collection of grantee information is usually accomplished through three methods. These include: review of participant records;  staff and/or client interviews; and general observation.
- Review of participant records is used to:
- 	·  Validate quantitative data previously submitted in quarterly reports;
- 	·  Validate eligibility of participants;

## Monitoring Visits - continued

- 	·  Validate that activities proposed are being carried out as planned;
- 	·  Ensure the grantee is complying with all record-keeping requirements;
- 	·  Identify and provide a focus for on-site interviews and observations; and
- 	·  Monitor grant program costs.

## Monitoring Visits - continued

- Candidates for in-person interviews include:
- 	·  Program staff, including administrative program staff, such as program managers, trainers, counselors, job developers, etc.;
- 	·  Clients/customers of the program;
- 	·  Chief elected official of the geographic area in which the program is operating (for example, governor, mayor, or county executive);
- 	·  Community members affected by the program; and
- 	·  Leaders and members of appropriate interest groups, particularly local veterans’ organizations, which may be linked to the project in the program narrative, or whose services may be claimed as a match.

## Monitoring Visits - continued

- Staff and client interviews can provide useful information about a program that cannot be obtained in any other way. The purpose of interviewing is to:
- 	·  Verify and expand upon information obtained from the desk review and other on-site review activities;
- 	·  Obtain qualitative information on activities;
- 	·  Identify causes of problems, deficiencies or of exceptional performance; and
- 	·  Identify management or administration issues requiring more in-depth review.

## Monitoring Visits - continued

- Observation is also a technique for gathering information about the operation of a grantee’s program;
- Through observation, the GOTR may formulate objective opinions about the adequacy of buildings, furnishings, equipment, signs, and other posted information during the on-site visit;
- Such impressions will be included as part of the written report and might also be shared during the exit interview with the grant manager.

**Notes:**
The GOTR prepares a written report on the results of the on-site monitoring visit.

## How Grantees Should Prepare for Monitoring Visits?

- To help the grantee prepare for a monitoring visit, the GOTR communicates with the grantee both in writing and by telephone about the purpose of the upcoming visit, the types of information the GOTR will review, and the methods to be used during the visit.

**Notes:**
As described, the monitoring activities might include review of written materials or client files, interviews with staff and clients, as well as observation of grantee operations.

## How Grantees Should Prepare for Monitoring Visits? - continued

- The GOTR should in advance provide the grantee a copy of the monitoring instrument that will be used;
- With this, the grantee can prepare staff and others who may be asked for an interview, and can ensure that program records are up to date and organized in such a way that will allow access by the GOTR.

## On-Site Review

- On-site monitoring visits are typically conducted in the second quarter of the grant period;
- Whether completing a desk or an on-site review, VETS staff use three review processes in monitoring:

## On-Site Review - continued

**Plan Versus Actual Monitoring (PVA): **This is a review and analysis of current program information to determine the extent to which grantees are achieving goals established in the Grant Agreement.

## On-Site Review - continued

**Managerial Monitoring: **This review of the quality of the program and the provided to veterans involves troubleshooting to determine the cause of identified problems. This review involves assessing the  organizational capacity of the grantee in carrying out the proposed program.

**Notes:**
Managerial monitoring also includes determining corrective action, provision of technical assistance, and providing ongoing liaison with grantees to ensure that corrective action occurs. Managerial monitoring is a process that is performed throughout the program activity period.

## On-Site Review - continued 

**Data Validity Monitoring: **This review is a systematic monitoring method to substantiate the reliability of program and financial information reported by grantees.

## ANNUAL ON-SITE REVIEW

**	**
**Entrance conference**
**Program review**
**Interview staff responsible for program**
**Review and document a sample of participants files**
**Review program files **
**Placement review**
**Exit conference**
**Follow-up Letter/report**

**Notes:**
By doing on-sites for new grantees at this time, we will be able to identify & address potential problems much sooner that before.  Grantees who had program or fiscal issues in the past may also be candidates for early monitoring.
In addition to the monitoring instrument, a written report must be sent to the grantee and to the N.O. through the RAVET.  This is effective with the visits conducted this past quarter.

## Monitoring Findings

- GOTR must prepare a written report on the results of the on-site monitoring visit;
- issues covered in the report will be those that had been identified during the desk review but remain unresolved; supplemented by any new issues that came to the attention of the GOTR as a result of the on-site record review, interviews, or observations.

**Notes:**
The GOTR must prepare a written report on the results of the on-site monitoring visit. In most cases, the issues covered in the report will be those that had been identified during the desk review but remain unresolved, supplemented by any new issues that came to the attention of the GOTR as a result of the on-site record review, interviews, or observations.
If the GOTR provides the monitoring instrument, the grantee can perform its own
“simulated” monitoring visit prior to the formal visit, in order to identify any deficiencies that should be corrected before the actual monitoring visit.
In reporting on the grant, the GOTR may use any format that adequately summarizes the findings of the on-site visit. The monitoring instrument will
generally serve as the guide to the issues covered in the monitoring report.
The findings and recommendations, particularly those involving corrective action, must be objective, accurate and related to the goals and objectives of the particular grant. The monitoring instrument and written report must be submitted to the RAVET, who forwards them to the National VETS Office, where they become part of the official grant file.
The GOTR must also inform the grantee in writing of the findings and recommendations no later than ten days after the on-site visit. The findings may be summarized, or the GOTR may include the full report. Generally, there are four types of findings reports as a result of an on-site monitoring visit. These include:
·  Grantee is exceeding goals. In this case, the grantee is currently exceeding the goals outlined in the Grant Agreement.
·  Grantee has no problems or potential problems: In this case, the GOTR has determined that the grantee is currently operating according to plan, with no current or potential problems.
·  Grantee has some potential challenges: In this case, the GOTR has determined no current concerns, but has identified areas where challenges may arise in the future.
The GOTR identifies these challenges, and makes a recommended course of action
to address these concerns. Typically, a follow-up telephone conference between the
grantee and GOTR takes place to discuss the recommendations and the time frame
for addressing them.
·  Grantee requires a Corrective Action Plan (CAP): In this case, the GOTR determined that there are concerns significant enough to warrant a Corrective Action Plan.
Typically, a follow-up telephone conference between the grantee and GOTR takes
place so that the GOTR may outline these concerns, indicate that the grantee is not in compliance with the Grant Agreement, and offer to provide technical assistance to work with the grantee to bring the grant back into compliance. The GOTR also
indicates that a CAP is required and establishes a time frame by which the CAP is to be submitted to the GOTR. Minor Problems: For example, the GOTR might
note a minor issue such as inadequate signage at the program site, and may 
suggest that additional signs be posted. Or, the GOTR may point out that many
enrollment applications do not have the date entered.
In order to correct these minor problems, the grantee would post new signs or
ensure that all program personnel are informed that the enrollment applications
must be dated.

## Monitoring Findings - continued

- The monitoring instrument will generally serve as the guide to the issues covered in the monitoring report;
- The findings and recommendations, particularly those involving corrective action, must be objective, accurate and related to the goals and objectives of the particular grant;
- The monitoring instrument and written report must be submitted as per current grant reporting requirements.

**Notes:**
VETS COMPETITIVE GRANT DESK REVIEW – document

VETS COMPETITIVE GRANTS ANNUAL ON-SITE REVIEW - document

## Monitoring Findings - continued

- The GOTR must also inform the grantee in writing of the findings and recommendations no later than ten days after the on-site visit. Generally, there are three types of findings reports as a result of an on-site monitoring visit. These include:
**Grantee is meeting or exceeding goals and  has no problems or potential problems; **

**Notes:**
The findings may be summarized, or the GOTR may include the full report.

## Monitoring Findings - continued

-  **Grantee has some potential challenges - **In this case, the GOTR has determined no current concerns, but has identified areas where challenges may arise in the future.  The GOTR should identify these challenges, and collaborate with grantee on a course of action to address these concerns;
**Grantee has challenges that require a Corrective Action Plan (CAP).**

## Monitoring Findings - continued

- Typically, a follow-up meeting or communication between the grantee and GOTR so the GOTR can outline any concerns, indicate areas where the grantee is not in compliance with the Grant Agreement, and offer to provide technical assistance to bring the grant back into compliance;
- The GOTR also indicates that a CAP is required and establishes a time frame by which the CAP is to be submitted to the GOTR.

## TECHNICAL ASSISTANCE

**Be prepared to provide assistance as requested**
**Do not hesitate to provide assistance as you feel it is warranted**
**Utilize your resources**

**Notes:**
Mr. Bolls is primary contact, I am available to assist with technical questions.  We will move questions up the ladder until we have an answer

## Technical Assistance and Corrective Actions

- DOL/VETS wants to do everything feasible to ensure the success of all grantees in carrying out their proposed programs;
- In many cases, only minor problems are found as a result of the monitoring process;
- In some cases, however, potential challenges, or current problems significant enough to warrant a Corrective Action Plan (CAP) are identified.

**Notes:**
In order to maximize the success of grantees, VETS offers technical assistance (TA), when appropriate, as part of the follow-up to the grant monitoring process. In many cases, only minor problems are found as a result of the monitoring process. In general, these minor problems are relatively easy to address. In some cases, however, potential challenges, or current problems significant enough to warrant a Corrective Action Plan (CAP) are identified. These situations are discussed below.
If minor problems are found, a CAP is not required. However, even
minor problems can be identified and must be addressed. A schedule
for correcting the problem(s) will be and the GOTR will provide any TA
necessary to implement solutions to the problem(s). The GOTR will
contact the grantee at a mutually agreed upon time to ensure that
corrective action has been taken. In subsequent quarterly desk reviews,
the GOTR will look for evidence that these minor problems have been corrected and are not adversely affecting grant performance. If necessary, the GOTR may schedule another on-site visit to validate that corrective action as been taken.
If potential challenges are found as a result of the monitoring process, the GOTR will work with the grantee to ensure that these challenges do not become real. This might be as simple as pointing out the potential problems to the grantee, or it might involve providing specific technical assistance. In either case, the GOTR contacts the grantee at a later, mutually agreed upon date, to determine if appropriate action has been taken. During subsequent quarterly desk reviews, the GOTR looks for evidence that potential problems have not developed into real problems.
If significant problems are found either in the desk review or as a result of the on-site visit, a CAP is required. A difference of more than 15 percent from program goals or expenditures would necessitate a CAP. Other significant problems might include deviation from other planned program activities such severe under-enrollment or lack of specific planned efforts, such as a job fair. Development of the CAP is the grantee’s responsibility, with assistance and direction provided by the GOTR.
A CAP is required if the GOTR finds the grantee is not in compliance with the Grant
Agreement. Specifically, if any actual data is 15 percent below projected goals, or the approved budget, the grantee must develop a CAP. The CAP should contain three basic elements:
·  A description of the problem(s) being addressed;
·  A detailed, step-by-step plan to correct the problem(s); and
·  A schedule for implementing the plan.
On the basis of the schedule contained in the CAP, the GOTR contacts the grantee to ensure that the proposed actions have been taken. The GOTR also determines whether or not the grantee believes the actions taken are effective. Grantee quarterly summary reports submitted after a CAP has been filed must indicate the grantee’s performance in fulfilling the CAP. The GOTR must consult both the original Grant Agreement and the CAP when performing desk reviews to ensure that the grantee is in compliance with both.
If necessary, the GOTR should schedule a follow-up on-site visit.
Program Success: CAPs are discussed here as plans for correcting problems. However, a grantee may deviate more than 15 percent from projected goals, or spend less money than the approved budget for other than negative reasons. The GOTR may therefore deem that a CAP is not necessary. For example, a grantee might train and/or place 15 percent more targeted veterans than proposed. Alternatively, the grantee might be meeting training and placement goals at a cost significantly lower than anticipated.
Monitoring in these cases can help showcase promising practices and grantee “high
performers.” In some cases when a grantee is significantly exceeding goals, a Grant
Modification may be necessary (discussed further below.)
If the GOTR has determined that these figures do not constitute a problem (e.g., a
possible problem might be that the projected goals and expenditures were unrealistic to begin with), the grantee should explain in writing why its performance was better than expected. This document is carefully reviewed, first by the GOTR, then by the RAVET and It is the responsibility of the grantee to develop the CAP. However, the GOTR should provide technical assistance as necessary to help the grantee prepare the CAP. If the GOTR is not able to provide needed TA (for example, if the grantee requires assistance in accounting or some other specialized skill), the GOTR will notify the RAVET. The RAVET is then responsible for identifying an individual, not necessarily a member of the VETS staff, to provide the needed assistance.
VETS National Office staff, to determine if other grantees can benefit from this
information. In some cases, an on-site monitoring visit or a desk review will uncover problems severe enough that a CAP is an inadequate response. In most of those situations, a Grant Modification will be necessary. In some, there may be sufficient cause to begin the process of determining whether or not criminal or other sanctions need to be imposed.

## Technical Assistance and Corrective Actions - continued

- If **minor problems **are found, a CAP is not required. However, even minor problems must be addressed;
- If **potential challenges **are found as a result of the monitoring process, the GOTR will work with the grantee to ensure that these challenges do not become major compliance issues.

## Technical Assistance and Corrective Actions - continued

- If **significant problems **are found either in the desk review or as a result of the on-site visit, a CAP is required. A difference of more than 15 percent from program goals or expenditures would necessitate a CAP;
- Development of the CAP is the grantee’s responsibility, with assistance and direction provided by the GOTR.

## Technical Assistance and Corrective Actions - continued

- A CAP is required if the GOTR finds the grantee is not in compliance with the Grant Agreement. The CAP should contain three basic elements:
- 	·  A description of the problem(s) being addressed;
- 	·  A detailed, step-by-step plan to correct   the problem(s); and
- 	·  A schedule for implementing the plan.
- On the basis of the schedule contained in the CAP, the GOTR contacts the grantee to ensure that the proposed actions have been taken.

**Notes:**
Specifically, if any actual data is 15 percent below projected goals, or the approved budget, the grantee must develop a CAP.

## Sanctions And Penalties 

- The Special Provisions of the Grant Agreement specify three sanctions that may be taken when a grantee is not performing in compliance with the terms and conditions of the grant:
-   Withholding of Funds;
-   Suspension; and
-   Termination.

## Sanctions And Penalties - continued

**Withholding of Funds**
- If a grantee has expended funds in a manner which is not permissible, or if the grantee’s financial report (SF-269) does not justify the expenses requested on the SF-270 (or the amount of money drawn down by Letter-of-Credit), the Grant Officer has the authority to withhold payment.

**Notes:**
Withholding of Funds
If a grantee has expended funds in a manner which is not permissible, or if the grantee’s financial report (SF-269) does not justify the expenses requested on the SF-270 (or the amount of money drawn down by Letter-of-Credit), the Grant Officer has the authority to withhold payment by instructing the Department of the Treasury not to honor requests for payment from the grantee.  Withholding of funds continues until the Grant Officer is satisfied that any previous problems have been corrected and that the grantee has instituted procedures to prevent a recurrence of the problem.

## Sanctions And Penalties - continued

**	****Suspension of a Grant Program**
- Suspension of a grant temporarily suspends Federal assistance under the grant pending corrective action by the grantee or pending a decision to terminate the grant;
- When a grant is reinstated, the Grant Officer (GO) will allow all necessary and proper costs that the grantee could not reasonably avoid during the period of suspension, provided that they meet the provisions of the grant and any applicable Federal Cost Principles.

**Notes:**
Suspension of a Grant Program
Suspension of a grant temporarily suspends Federal assistance under the grant pending corrective action by the grantee or pending a decision to terminate the grant. Although in cases where funds are merely being withheld, the grantee may continue to operate a program (the grantee may use non-Federal funds or even Federal funds it had on hand before the withholding of funds was imposed), it may not, legally, continue to operate a program once a suspension has been imposed. Once corrective action is taken, a grant may be reinstated.
When a grant is reinstated, the Grant Officer (GO) will allow all necessary and proper costs that the grantee could not reasonably avoid during the period of suspension, provided that they meet the provisions of the grant and any applicable Federal Cost Principles.

## Sanctions And Penalties - continued

**	****Grant Termination**
- The termination of a grant means the cancellation of assistance under the grant, in whole or in part, at any time prior to the end of the grant period;
- If a grant is terminated, the Grant Officer will promptly notify the grantee and the GOTR, RAVET, and OASVET in writing;
- In addition to termination for cause, a grant may also be terminated for convenience;
- A grant may also be terminated “in part” – a partial termination – when some portion(s) of a program is terminated, but others continue.

**Notes:**
Grant Termination
The termination of a grant means the cancellation of assistance under the grant, in whole or in part, at any time prior to the end of the grant period. If a grant is suspended, it may be reinstated once corrective action has been taken. The grantee is then permitted to continue its program. If a grant is terminated, no reinstatement option is available.
If a grant is terminated, the Grant Officer will promptly notify the grantee and the GOTR, RAVET, and OASVET in writing. The notification provides the reasons for and the effective date of the termination. Payments made to the grantee or recoveries of prior advances by VETS under grants terminated for cause shall be made in accordance with the legal rights and liabilities of the parties.
In addition to termination for cause, a grant may also be terminated for convenience. In such a case, the grantee or OASVET may terminate a grant, in whole or in part, when both parties agree that the continuation of the program would not produce beneficial results commensurate with the further expenditure of funds. Both the grantee and OASVET should agree on the termination conditions, including the effective date. A grant may also be terminated “in part” – a partial termination – when some portion(s) of a program is terminated, but others continue. In a partial termination, the grantee will not incur any new obligations for the terminated portion(s) after the termination effective date and shall cancel as many outstanding obligations as possible. Any non-cancellable obligations, properly incurred prior to the effective date, will be honored according to the terms of the Grant Agreement.

## Sanctions And Penalties - continued

**	****Imposition of Sanctions**
- Sanctions imposed on a grantee will depend upon the seriousness of the situation, the terms of the Grant Agreement, and the willingness and ability of the grantee to rectify the situation;
- Only the Grant Officer has the authority to impose sanctions on VETS grantees.

**Notes:**
Imposition of Sanctions
Sanctions imposed on a grantee will depend upon the seriousness of the situation, the terms of the Grant Agreement, and the willingness and ability of the grantee to rectify the situation. Only the Grant Officer has the authority to impose sanctions on VETS grantees.
The GOTR, however, has the responsibility to recommend the imposition of sanctions when there is good cause and adequate documentation. Situations in which the GOTR might forward a sanction recommendation to the RAVET include, but are not necessarily limited to, the following:
·  The grantee fails to submit timely and/or accurate quarterly reports and
GOTR letters requesting corrective action are ignored;
·  There is more than a 50 percent under expenditure of funds approved in
Section D of SF-424A after the second Program Quarter; or
·  The grantee has not achieved at least 50 percent of the approved grant
application goals after the second Program Quarter.
The RAVET reviews the recommendation and forwards it to OASVET for further review.
OASVET conducts appropriate discussions with the Grant Officer before any decision is made on the GOTR’s recommendation. In the sanctioning process, the GOTR is limited to making the initial recommendation and to providing the documentation necessary to support that recommendation. The imposition of sanctions is a legal process and, therefore, complete and accurate documentation is essential.

## Grant Close - out

**	**
- All VETS grants must be formally closed-out by the grantee, the GOTR and the Grant Officer;
- The Office of Cost Determination is currently responsible for the distribution of close out packages to grantees and the administrative tasks of closing the grant;
-  “Close out” means the official end of the grant period, the expenditure of all grant monies, and the accomplishment of grant project goals;
- Procedures for close out are outlined in the General Provisions of the Grant Agreement;
- Grant close out typically occurs within 6 to 12 months after the grant expires.

**Notes:**
Grant Close Out
At the end of the grant program year, all VETS grants must be formally closed-out by the grantee, the GOTR and the Grant Officer (GO). The Office of Cost Determination (OCD) is currently responsible for the distribution of close out packages to grantees and the administrative tasks of closing the grant. “Close out” means the official end of the grant period, the expenditure of all grant monies, and the accomplishment of grant project goals, and procedures for close out are outlined in the General Provisions of the Grant Agreement.
Grant close out typically occurs within 6 to 12 months after the grant expires. The General Provisions of the Grant Agreement specify the exact timing of the grant close out. The 6-month timeframe allows grantees time to conduct the required 6 -month follow-up to document employment retention rates, and to develop the final report.  In order to formally conclude the VETS grant, the grantee must submit the final technical and financial report to the GOTR, who ensures that the report is on time and accurate, and signs a form certifying this. The GOTR then submits the report to the Grant Officer.  Un –obligated Federal funds remaining at the end of the grant period may not be used for other purposes, and must be refunded to the U.S. Treasury. These un-obligated funds cannot be retained by the grantee for use on other grants. The Grant Officer makes a settlement for any upward or downward adjustments to the Federal share of costs within one year after the final financial
and performance reports are received.  Records pertaining to the administration and operation of a VETS-funded grant program must be maintained by the grantee for a minimum of three years. This includes program files, participant information, financial records, and other data related to the implementation of the grant-funded program. Specific guidance regarding the retention of program and participant
records is typically outlined in the Special Grant Provisions provided at the time of award.

## WEBLINKS

- _[http://www.dol.gov/vets](http://www.dol.gov/vets)_
**	****- Contract/Grant Award Info**
**	****	****VETS Guide to Grants, SGA’s & ****	****enclosures**
- _[http://whitehouse.gov/omb/circulars/index.html](http://whitehouse.gov/omb/circulars/index.html)_
**	****- Office of Management and Budget ****	****Circulars**
- _[http://www.access.gpo.gov/nara/cfr/waisidx_03/29cfrv1_03.html](http://www.access.gpo.gov/nara/cfr/waisidx_03/29cfrv1_03.html)_
**	****-**** **Code of Federal Regulations governing DOL grants

**Notes:**
VETS Guide to Grants is a very good document that can be very helpful for grantees to better understand the grant process.  Then you have the various SGA’s & enclosures.  The white house website will get you to the various OMB circulars

## DISCUSSION

**Questions**
**Comments**
**Suggestions**