. 

U. S. Department of Housing and Urban Development

Office of Inspector General for Investigation

Inspections and Evaluations Division

HUD’s Supportive Housing Program

Survey of Grantee Monitoring of Project Sponsors

February 16, 2011

IED‐11‐002R
2 

Executive Summary 

The Office of Inspector General (OIG), Inspections and Evaluations Division, conducts 

independent, objective examinations of U.S. Department of Housing and Urban Development 

(HUD) activities, programs, operations, and organizational issues. 

We conducted a survey of HUD’s Supportive Housing Program (SHP); specifically, grantee 

monitoring of nonprofit subgrantees (project sponsors) that deliver supportive housing and/or 

supportive services. OIG investigations of alleged fraudulent activity by employees of project 

sponsors raised concerns about oversight on the part of HUD and the grantees. The objective of 

the survey was to assess whether SHP grantees followed Federal regulations and HUD guidance 

on monitoring project sponsor activities and program expenditures. We also looked at HUD’s 

role in grantee monitoring of project sponsors. Questionnaires were sent to all 44 HUD Office of 

Community Planning and Development (CPD) regional and field offices and to a sample of 11 

SHP grantees and 12 project sponsors. 

Survey responses indicated that overall HUD is actively providing monitoring guidance to SHP 

grantees and that most grantees reported compliance with Federal regulations related to their 

monitoring of project sponsors. Responses to the survey also indicated that improvement is 

warranted in certain aspects of HUD’s guidance and the grantees’ monitoring of project sponsor 

activities. For example, 

 3 CPD offices did not assess grantee monitoring of project sponsors in their jurisdictions, 

 17 CPD offices did not provide specific instructions to SHP grantees on their 

responsibility to ensure that project sponsors had not been debarred or suspended from 

participating in Federal programs, 

 7 CPD offices reported that not all grantees in their jurisdiction reviewed project sponsors 

to identify possible conflict-of-interest concerns, and 

 Standards differed among SHP grantees as to what was considered adequate 

documentation to support project sponsor expenditures. 

HUD and SHP grantees identified staffing and funding as primary barriers in meeting their 

oversight and monitoring responsibilities. More than half of the CPD field offices cited 

inadequate staffing, insufficient funds to pay for onsite grantee monitoring visits, and the lack of 

knowledge and program expertise. Several grantees also expressed concern over insufficient 

funding to pay for onsite monitoring visits to project sponsors and inadequate staff levels. 

Recent passage of the Homeless Emergency Assistance and Rapid Transition to Housing Act 

(HEARTH) in 2009 may help to reduce some of the barriers. For example, HEARTH doubled 

the percentage of program funds (from 5 to 10 percent) that grantees may use for administrative 

costs such as monitoring. The SHP Director expects that the increase should help grantees meet 

their monitoring responsibilities. Further, CPD plans to offer additional technical assistance to 

help SHP grantees deal with their staffing difficulties.1

 

 

1

At the time of this survey, HUD was preparing proposed regulations and program guidance to codify and 

implement the HEARTH Act, including provisions of the Act which incorporates services that were formerly funded 

under SHP. 
3 

Effective oversight and monitoring are crucial to ensuring that SHP funds are properly spent to 

assist in the transition of persons out of homelessness. When SHP grantees accept Federal funds, 

they also accept the responsibility to manage the program in accordance with all applicable 

Federal and HUD regulations. Therefore, monitoring of grantees and project sponsors that 

deliver supportive housing services is essential for program success. In this regard, HUD should 

reinforce compliance with Federal regulations and monitoring guidance and ensure that its 

monitoring reviews include an assessment of SHP grantee project sponsor management. 

We provided a draft copy of the report to the Assistant Secretary for CPD on December 16, 

2010. The Assistant Secretary in a memorandum dated January 31, 2011, agreed with our 

observations and concurred with the recommendations. OIG considers CPD’s planned corrective 

actions to be responsive to our three recommendations. However, the recommendations remain 

open pending verification of corrective actions taken. The complete text of CPD’s response is 

included in Appendix A to this report. 
4 

Table of Contents 

Introduction ......................................................................................................................................5 

Scope and Methodology ..................................................................................................................6 

Observations 

1. Enhancements Needed in Some Areas of HUD and Grantee Monitoring ............................7 

2. Barriers to Effective Grantee Monitoring .............................................................................9 

Recommendations ..........................................................................................................................10 

Comments and OIG Response .......................................................................................................11 

Appendixes 

A. HUD Office of Community Planning and Development’s Comments..............................12 

B. CPD Questionnaire .............................................................................................................13 

C. Grantee Questionnaire ........................................................................................................15 

D. Project Sponsor Questionnaire ...........................................................................................18
5 

Introduction 

Supportive Housing Program 

The Supportive Housing Program (SHP) is one of several homelessness programs authorized by 

Title IV, Subtitle C, of the McKinney-Vento Homeless Assistance Act of 1987 as amended. 

SHP is designed to develop supportive housing and services that will allow homeless persons to 

live as independently as possible. Eligible applicants are State and local governments, public 

housing authorities, and private nonprofit entities. As prescribed in 24 CFR (Code of Federal 

Regulations) 583.115 and 583.120, program funds may be used for leasing, including paying rent 

for entire structures or individual units to provide housing for program participants and/or for 

supportive services such as case management and health care. A portion of the grant funds may 

also be used by grantees for operations and to cover administrative costs.2

 SHP allows grantees 

to contract with other organizations, typically nonprofits, to deliver the supportive housing and 

services to eligible participants. These nonprofits are referred to as project sponsors. 

The following table shows SHP funding by major components for fiscal years (FY) 2008 and 

2009.3

SHP activity

FY 2008

(in millions)

No. of

projects

FY 2009

(in millions)

No. of

projects

Permanent housing for

persons with disabilities $374.1 1,888 $438.9 2,300

Transitional housing $435.5 2,140 $428.8 2,212

Supportive services $129.7     829 $132.1     834

Total $939.3 4,857 $999.8 5,346

SHP is administered by the U.S. Department of Housing and Urban Development’s (HUD) 

Office of Special Needs Assistance Programs (SNAPS) within the Office of Community 

Planning and Development (CPD). SHP management is decentralized, with CPD regional and 

field offices being responsible for ensuring that the grantees and project sponsors comply with 

applicable Federal laws and regulations and HUD policies and procedures. 

Applicable Federal Regulations 

Federal regulations for monitoring HUD-funded programs are found in 24 CFR 84.51 for 

nonprofits and 24 CFR 85.40 for State and local government agencies. These regulations require 

grantees to monitor subgrant-supported activities (e.g., project sponsors). Specifically, 24 CFR 

84.51 states that grant recipients are responsible for managing and monitoring each project, 

program, and subaward, including compliance with Office of Management and Budget (OMB) 

Circular A-133, “Audits of States, Local Governments and Non-Profit Organizations.” 

Regulations at 24 CFR 85.40 contain similar language that requires grantees to manage the day-

 

2

 Federal statute limits the amount of grant funds that may be used by the grantee for administrative costs, such as 

monitoring, to not more than 5 percent of the grant award. 

3

 FY 2010 SHP funding data were not available at the time of this survey. 
6 

to-day operations of grant and subgrant-supported activities to ensure compliance with Federal 

requirements and that performance goals are achieved. Section 85.40 also mandates that 

grantees submit annual performance reports to HUD. Additionally, 24 CFR 583.330 codifies 

Federal regulations related to SHP and cites 24 CFR Part 85, which prohibits conflicts of interest 

by grantees and subgrantees. These regulations also reference OMB Circulars A-87 and A-122, 

which require that costs incurred by subgrantees using Federal program funds be reasonable and 

adequately documented. 

Scope and Methodology 

We conducted a survey of SHP in response to concerns raised about oversight on the part of 

HUD and the grantees. The concerns resulted from Office of Inspector General (OIG) 

investigations of alleged fraudulent activity by employees of project sponsors. The objective of 

the survey was to assess whether SHP grantees followed Federal regulations and HUD guidance 

on monitoring project sponsor activities and program expenditures. We also looked at HUD’s 

role in grantee monitoring of project sponsors. 

We designed three questionnaires to collect the majority of the information for this survey. One 

questionnaire (appendix B) was used to collect information from all 44 CPD regional and field 

offices nationwide, covering the 10 HUD regions.4

 Four of the offices did not complete the 

questionnaire because they did not have any grantees that used sponsors to deliver SHP services 

in their jurisdiction. Therefore, the data analyzed were based on 40 completed questionnaires. 

The questionnaire covered topics related to the CPD offices’ guidance to SHP grantees on 

monitoring project sponsors and their assessment of grantee monitoring in the respective 

jurisdiction. 

We sent two other sets of questionnaires (appendixes C and D) to 9 SHP grantees5 and 9 project 

sponsors that delivered SHP services for these grantees covering 9 of the 10 HUD regions. The 

survey responses were supplemented by responses to questionnaires that we tested at two other 

grantees and three of their sponsors located in HUD Region 2.6 Therefore, the survey obtained 

results from a total of 11 grantees and 12 sponsors. The information collected from the grantee 

and project sponsor questionnaires covered the monitoring activities of the selected grantees and 

relationships with their project sponsors. 

We used data provided by SNAPS to select the 11 SHP grantees for survey. SNAPS provided 

information on all SHP grantees that used project sponsors to provide rental assistance and/or 

supportive services during the review period, January 2008 through August 2010. They also 

provided a list of SHP grantees that were designated as high risk for FY 2010. We also obtained 

project expenditure data from HUD’s Line of Credit Control System. 

 

4

 The 50 States, the District of Columbia, and five U.S. territories are divided among 10 HUD regional offices. 5

 In accordance with restrictions placed on Federal agencies by the Federal Paperwork Reduction Act (44 U.S.C. 

(United States Code) 35), we were limited to the number of grantees and sponsors that were sent questionnaires. 

6

 HUD Region 2 covers the States of New York and New Jersey. The regional office is located in New York City, 

with field offices in Buffalo and Newark. 
7 

The factors considered in the selection of the 11 SHP grantees were as follows: 

 Grantee representation in all 10 HUD regions, 

 Grantees that were designated as high-risk grantees in 2010 by CPD based on an annual 

risk assessment conducted by CPD regional and field offices, 

 Grantees that had an agreement with a nonprofit sponsor to deliver housing assistance 

and/or supportive services to eligible project participants, and 

 SHP funds expenditures between January 2008 and August 2010. 

We received a 100 percent response rate from the CPD offices as well as from SHP grantees and 

project sponsors. CPD’s Acting Deputy Assistant Secretary for Operations and the SHP Director 

assisted in coordinating the transmission of the questionnaire to the 44 CPD regional and field 

offices in the country. 

We conducted the survey in accordance with the Quality Standards for Inspections adopted by 

the Council of the Inspectors General on Integrity and Efficiency. 

Observations 

Observation 1: Enhancements Needed in Some Areas of HUD and Grantee Monitoring 

 

Survey results showed that CPD regional and field offices play an important and active role in 

educating, instructing, and providing guidance to SHP grantees on their federally required 

monitoring responsibilities. While the survey indicated that 10 of the 11 selected grantees (with 

the exception of one located in New York, HUD Region 2) monitored their project sponsors and 

generally complied with the Federal monitoring regulations, it also identified some areas of 

grantee monitoring that can be improved. 

HUD Guidance Provided to Grantees 

HUD fulfills its monitoring role through various means. Responses to the survey indicated that 

most of the CPD field offices participate in annual live video startup conferences for new and 

existing grantees. These conferences are sponsored by CPD field offices, and the training is 

provided by CPD field staff and HUD contractors. The conference curriculum covers topics that 

are germane to monitoring, such as SHP project sponsor management, annual progress reports, 

eligibility checklists, and financial management. Federal regulations such as 24 CFR Parts 84 

and 85 are distributed to the grantees, or the grantees are given Internet links to the material. 

Other conference topics include compliance with OMB Circular A-133, conflict-of-interest 

issues, and the need for written agreements between the grantee and the project sponsor. 

The CPD respondents reported that instructions provided at the annual startup conferences were 

continuously supplemented, enforced, and updated through technical assistance provided by 

CPD staff or contractors, periodic workshops for grantees and sponsors, and feedback on 

grantees’ technical submissions, which is part of the grant application. Additionally, CPD 

provides printed material (either hardcopy or via the HUD Web site) to help grantees. The 

respondents predominately cited the SHP Desk Guide and the SHP Self-Monitoring Tools as 
8 

sources that grantees can rely on for guidance on how and what to monitor. In particular, the 

Self-Monitoring Tool guide book provides grantees and project sponsors with forms to enable 

staff to assess its project operations against the standards set by HUD rules and Federal 

regulations. It includes material on how to track eligible activities and expenses and how to 

determine and document participant eligibility. Further, this guide book references the Federal 

requirements for accounting records and source documents found in 24 CFR 84.21 and 85.20. 

These regulations also require that expenditures be supported by source documents such as 

cancelled checks, paid bills, payrolls, time and attendance records, contracts, etc. 

Exhibit 13-6 of HUD Handbook 6509.2, REV-6 (Community Planning and Development 

Monitoring Handbook), includes work steps for CPD offices to assess an SHP grantee’s project 

sponsor management, including oversight of the day-to-day operations of project sponsor 

activities. Survey results indicated that not all CPD offices followed these work steps when 

monitoring SHP grantees for compliance with Federal requirements and the achievement of 

performance goals identified in a grantee’s homeless assistance approved application. Three 

surveyed respondents reported that they did not perform an assessment of grantee project 

sponsor management. By not performing this assessment, they forfeit the opportunity to identify 

potential weaknesses with a grantee’s monitoring of project sponsors and to provide needed 

corrective assistance. This issue is especially important since the CPD offices focus their 

monitoring resources on grantees that are considered high risk and typically conduct onsite 

monitoring visits to grantees only once every 2 to 3 years. 

The survey results also indicated that CPD offices had not consistently provided guidance on the 

Federal regulations prescribed at 24 CFR 84.13 and 85.35, which state that grantees must not 

make any award or permit any award to any party which is debarred or suspended. Seventeen 

CPD offices reported that they did not provide specific guidance to the grantees on their 

responsibility to comply with these regulations. Many of the surveyed respondents stated that 

their guidance was accomplished by referring SHP grantees to the applicable regulations. 

Further, three surveyed SHP grantees reported that they did not determine whether their project 

sponsors had been debarred or suspended. The SHP Director stated that CPD relies on grantees 

to verify that project sponsors are not debarred or suspended. The HUD monitoring handbook 

does not include a work step for CPD to confirm grantee compliance in this area. 

Grantee Monitoring of Project Sponsors 

Survey results indicated that the majority of CPD offices (24 of the 40) were basically satisfied 

with the monitoring that SHP grantees performed. Overall, grantees have a management system 

for oversight and written agreements with their project sponsors. SHP grantees also perform 

monitoring steps such as determining whether costs submitted for reimbursement are for eligible 

activities and checking rent calculations for payment of subsidies. The results also disclosed that 

1 of the 11 surveyed SHP grantees (located in New York, HUD Region 2) reported that it did not 

follow HUD guidance on monitoring of project sponsors. The CPD field office recently 

conducted a monitoring visit to this grantee and confirmed that the grantee did not comply with 

Federal requirements involving the monitoring of project sponsors. 
9 

Three SHP grantees attributed their monitoring efforts to uncovering instances in which project 

sponsors submitted reimbursement claims for ineligible costs such as personal long distance 

phone charges and coffee service for the staff. One of the three grantees terminated the contract 

with the responsible project sponsor, and the other two grantees did not reimburse the project 

sponsors for the ineligible cost. A fourth grantee determined that two project sponsors were 

unable to perform their responsibilities and transferred the projects to other project sponsors. 

However, survey results also identified inconsistencies among SHP grantees regarding 

compliance with Federal and HUD monitoring requirements. Seven CPD offices reported that 

not all grantees in their jurisdiction checked for conflicts of interests. Additionally, results 

indicated that not all grantees 

 Required written agreements with sponsors, 

 Reviewed rent calculations for subsidized living units, and/or 

 Verified that project participants lived at the addresses subsidized with program funds. 

Further, survey results disclosed inconsistencies in documentation that SHP grantees accepted as 

support for project expenses. Six CPD offices reported that SHP grantees accepted nonsource 

documents for expenses such as project sponsor-generated vouchers and other accounting 

records. One CPD office responded that grantees accepted unverified data reported by project 

sponsors in their annual performance reports. While a majority of grantees reported that they 

required source documentation from project sponsors such as cancelled checks, paid bills, and 

payroll registers, some SHP grantees reported that they accepted nonsource documents including 

payroll summaries and cash disbursement journals. Regulations at 24 CFR 84.21 and 85.20 

require that expenditures be supported by source documents such as cancelled checks, paid bills, 

payrolls, time and attendance records, contracts, etc. 

Observation 2: Barriers to Effective Grantee Monitoring 

Of the 40 CPD offices surveyed, 16 reported that they were either not satisfied with SHP 

grantees or concerned that they might not be doing a satisfactory job of monitoring their project 

sponsors. Further, 12 CPD offices indicated that they found instances in which program funds 

were used for ineligible costs or unsupported expenditures. 

Twenty-one CPD offices identified barriers which they believed hindered a grantee’s ability to 

perform effective monitoring of its project sponsors; specifically, 

 Insufficient funds to pay for adequate staff and conduct onsite monitoring, 

 Staff turnover, 

 Lack of knowledge and program expertise, and 

 Limited experience in performing monitoring.

Three grantees also expressed concern over insufficient funding to pay for onsite monitoring 

visits to project sponsors and inadequate staff levels. 
10 

Additionally, while 9 of the 11 grantees reported that they conducted onsite monitoring visits to 

project sponsors, the monitoring was neither performed on a regular basis, nor were all project 

sponsors visited. In particular, project sponsors that are located in large rural areas may not be 

visited because of insufficient staffing and lack of travel funds. 

Recent Legislation 

In 2009, Congress passed the Homeless Emergency Assistance and Rapid Transition to Housing 

Act (HEARTH), which reauthorized the McKinney-Vento Homeless Assistance Act of 1987. 

The legislation in part consolidates three of the separate homeless assistance programs 

administered by HUD under the McKinney-Vento Homeless Assistance Act into a single grant 

program. 

The eligible activities of the SHP will be combined with the Shelter Plus Care and Single Room 

Occupancy Programs’ program activities and services. The primary goal of these programs is to 

provide funds to State and local governments and non-profit organizations to offer housing and 

supportive services for homeless individuals and families. 

The current administration cap for SHP is five percent of the total grant amount. To pay for 

additional administrative requirements under HEARTH, such as monitoring, Congress doubled 

the percentage from 5 to 10 percent. 

The SHP Director acknowledged that limited administrative dollars may present a barrier to 

facilitating monitoring responsibilities for many organizations and believes that the increase in 

administrative funds through this new legislation should help grantees fulfill their monitoring 

responsibilities. The Director is hopeful that grantees will be able to hire additional staff to 

manage their funded projects and pay for more regular onsite monitoring. Recognizing that a 

number of grantees also have staff capacity problems, CPD plans to offer technical assistance to 

grantees that need to enhance their staff, organizational, and financial capacity. 

At the time of the survey, HUD was drafting proposed regulations and program guidance to 

codify and implement the HEARTH Act, including specific provisions related to Subtitle C – 

Continuum of Care Program; which incorporates services that were formerly funded under SHP. 

Recommendations 

Effective oversight and monitoring are crucial to ensuring that SHP funds are properly spent to 

assist in the transition of persons out of homelessness. When SHP grantees accept Federal funds, 

they also accept the responsibility to manage the program in accordance with all applicable 

Federal and HUD regulations. Therefore, monitoring of grantees and project sponsors that 

deliver supportive housing services is essential for program success. 

In this regard, we recommend that HUD’s Office of Community Planning and Development 

 

1. Reinforce compliance with Federal regulations and HUD monitoring guidance; 

specifically, to ensure that SHP grantees 
11 

A. Confirm that prospective project sponsors are not debarred or suspended from 

participating in Federal programs before making an award. 

B. Check for any possible conflict-of-interest issues. 

C. Conduct onsite monitoring visits to project sponsors. 

D. Require project sponsors to provide adequate source documentation to support the 

expenditure of SHP funds as prescribed in 24 CFR 84.21 and 85.20. 

2. Ensure that monitoring reviews of SHP grantees include an assessment of grantee project 

sponsor management. 

3. Provide SHP grantees technical assistance and guidance as needed. 

Comments and OIG Response 

We provided a draft copy of the report to the Assistant Secretary for CPD on December 16, 

2010. The Assistant Secretary agreed with our observations and concurred with the related 

recommendations (Appendix A). We recognize CPD’s efforts to reinforce and improve 

compliance with federal regulations and SHP monitoring guidance and consider the planned 

corrective actions to be responsive to recommendations 1 through 3. However, the 

recommendations remain open pending verification of corrective actions. OIG will follow-up 

with CPD to determine the status of the corrective actions taken.
12 

Appendix A – HUD Office of Community Planning and Development’s Comments 
13 
14 
15 

Appendix B – CPD Questionnaire 

CPD Regional/Field Office Questionnaire

Point of contact with your office for possible follow‐up questions.

Name and position of

POC

Regional/field office

location – city/state

Telephone No. Email address

Question

# 1

What type of guidance and/or technical support does your office provide to SHP grantees

under your jurisdiction on the grantees’ responsibility to monitor sponsors that they have

agreements with to provide leasing and supportive services to project participants?

Answer

Question

#2

Identify for the following areas that your office provides guidance or instructions to the

grantee as it relates to their relationship with their sponsors.

Non‐federal audits in

compliance with OMB

Circular A‐133.

Conflict of interest

between employees

and individuals and

entities conducting

business with.

Written agreements

between grantee

(recipient) and sponsor

(sub‐recipients)

detailing a project

sponsor’s

responsibilities and

obligations.

Determining whether

project sponsors were

debarred or suspended

from participating in

federal programs.

   

Question

#3

Does your office provide the SHP grantees with guidance on the type of documentation

they should require the sponsor to provide them to support the eligibility of participants

and the expenditures of SHP grant funds?  Describe.

Answer

Question

#4

As standard procedure, does your office provide to the SHP grantees copies of the

Supportive Housing Program Desk Guide and/or the Supportive Housing Program Self‐

Monitoring Tools?

Answer

Question

#5

Does your office’s monitoring of SHP grantees include steps to assess grantee’s

monitoring of the sponsors?  Describe.

Answer

Question

#5a

As part of your grantee monitoring, do you also monitor the sponsors?

Answer

Question #

6

Since 2008, has your office, through its SHP grantee monitoring, found any instances of

material misuse of SHP funds by the sponsor and/or possible fraudulent activities by the

sponsor? Describe the circumstances.

Answer

 
16 

Question

#7

Based on your office’s monitoring of SHP grantees, do the grantees generally have or

conduct the following monitoring steps?

Management system for oversight

of its sponsors?

Execute written agreements with

sponsor?

Review sponsors for evidence of

conflict of interest?

Review sponsors’ documentation

supporting expenditures of SHP

funds?

Review sponsors’ system for

determining the eligibility of

participants, calculating rent, and

tracking the participants to ensure

that they are residing in the SHP

funded living units?

Question

#8

Based on your office’s contacts with the SHP grantees and sponsors, have you identified

any possible barriers or impediments to the grantees’ oversight and monitoring of the

sponsors?  If yes, describe.

Answer

Question

#9

Based on your office’s oversight of the SHP grantees, are you satisfied that the grantees

are doing a satisfactory job of monitoring their sponsors?

Answer

Question

#9a

If not, please explain reasons why.

Answer

Question

#10

Provide any further comments on SHP grantee monitoring of sponsors that you may like

to add.

Answer
17 

Appendix C – Grantee Questionnaire 

SHP Grantee Questionnaire  

Please provide responses to the following set of questions for your monitoring of sponsors for the SHP

project(s) identified below in Question #1 for the period covered by fiscal year (or program year) 2008

through to the present.  

Question # 1 Please provide the following information for each SHP project shown.

HUD/SHP Project

Number

Name of

Sponsor

Point of

Contact for

Sponsor

Telephone and Email

Contact for Sponsor

Type of Services

Provided

    

Question

#2

Describe your management system for the oversight and monitoring of your sponsor(s).

Answer

Question

#2a

Do you monitor sponsor activities and expenses, as found in HUD’s SHP Desk Guide and

the SHP Self‐Monitoring Tools? Describe how you accomplish this.

Answer

Question

#2b

Do you maintain a separate project monitoring file, as suggested in the HUD/SHP Desk

Guide, for each SHP project? List the documents included in the project monitoring file.

Answer

Question

#3

As part of your oversight, do you determine whether a prospective sponsor had been

debarred, suspended or otherwise excluded from or ineligible for participation in Federal

assistance programs or activities?  Describe how you determine this.

Answer

Question

#4

Do you review sponsors to determine whether there is any evidence of conflict of

interest, either between grantee and sponsor and the sponsor and any contractors or

employees?

Answer

Question

#5

As recommended in HUD’s SHP Desk Guide, do you have a “sub‐recipient agreement,”

which sets out the duties and responsibilities of the sponsor?  

If there is a sub‐recipient agreement, please provide a copy

Answer

Question

#6

Do you conduct monitoring on‐site visits to the sponsor’s place of business and/or

location(s) where project participants reside and/or receive supportive services to review

SHP funded program activities and records? Describe.

Answer

Question

#6a

How often do you make site visits? Did you make any monitoring site visits during the

period 2008 to present?  Provide date(s) of these monitoring site visits and identify which

sponsor visited.

Answer

Question

#6b

If you did not make any on‐site monitoring visits to the sponsor(s) from 2008 to the

present, explain why?

Answer

Question

#7

Do you review how sponsor(s) determined that project participants are eligible to receive

SHP funded assistance? Describe how.

Answer

Question

#7a

What documentation do you require from the sponsor to support the homeless status of

each participant?
18 

Answer

Question

#8

Do you verify that project participants who are receiving rental assistance from the

sponsor actually live in the living units being subsidized with SHP funds? Describe how.

Answer

Question

#9

Do you track the sponsors’ termination of housing and/or supportive services provided to

specific project participants?

Answer

Question

#9a

In accordance with 24 CFR 583.300 (b) (11) (d); do you assure that the sponsor providing

supportive services to project participants conducts ongoing assessments of the

participants’ needs and the availability of such services?

Answer

Question

#10

Do you review calculations made by the sponsor to determine if the rental amount

subsidized with SHP funds are correct and reasonable? Describe how.

Answer

Question

#11

In processing monthly (periodic) claims from sponsor for costs, either advance or

reimbursement payments, what documentation do you require from the sponsor to

process payments through HUD’s LOCCS?

Answer

Question

#12

Do you independently verify the data reported on the sponsor’s Annual Progress Report

(APR)?

Answer

Question #

13

How do you assure that sponsors are in compliance with the audit requirements

contained in the Single Audit Act Amendments of 1996 (31 U.S.C. 7501‐7507) and the

revised OMB Circular A‐133, “Audits of States, Local Governments, and Non‐Profit

Organizations.”

Answer

Question

#13a

If the sponsor is not required to submit an A‐133 audit, do you require an annual

independent audit of the sponsor?

Answer

Question

#14

Through your monitoring activities, have you identified any instances of the sponsor using

SHP funds for ineligible costs and/or found instances of sponsor misuse or possible

fraudulent activity?  Please describe.

Answer

Question

#14a

If the misuse of SHP funds and/or possible fraudulent activity was found during your

monitoring, was it reported to your local HUD CPD office or directly to the HUD Office of

Inspector General?

Answer

Question #

15

Are there any barriers or impediments to your ability to satisfactorily perform oversight

and monitoring of your sponsor(s)? Indentify any.

Answer

Question #

16

Provide any further comments or observations about monitoring conducted by SHP

grantees and other related topics, such as HUD guidance for grantee monitoring.

Answer

Please provide all monitoring reports (desk reviews and on‐site) prepared by your organization on the

identified project sponsors, from fiscal (program) years 2008 to the present.   
19 

Appendix D – Project Sponsor Questionnaire 

SHP Sponsor Questionnaire 

Please provide responses to the following set of questions as it relates to the grantee monitoring of the

supportive housing services that your organization provides as a sponsor for the following SHP grantee,

for the period covered by calendar years (or fiscal year) 2008 through to the present.  

SHP project number Name of grantee

   

SHP sponsor Name, position, and telephone# of sponsor point‐of‐contact

Name of landlord(s) if SHP funds are used to lease living units, and telephone number

Question

#1

Is your organization a not‐for‐profit or other type of entity?

Answer

Question

#2

What type of SHP funded supportive housing services is your organization providing to the

project participants at any time during the period of 2008 to present?

Answer   Housing assistance (lease/pay rent) Supportive services

Entire structure Individual units

Question

#3  

Show the amount of SHP funds the grantee actually paid your organization for the years

(calendar or fiscal) shown for the supportive housing services you provided to project

participants.   

Answer 2008 2009 2010 (to present)

Leasing

structure

for

participant

residences

Rental

assistance

for

individual

living units

Supportive

services

Question

#4

Has your organization ever been debarred and/or suspended from participating in

Federally funded programs or activities?   If yes, when and was it terminated prior to your

participation as a sponsor in the SHP?

Answer

Question

#5

Has the grantee provided you with Federal/HUD regulations on potential conflicts of

interest?

Answer

Question

#6

What guidance has the grantee provided on the types of eligible costs that are covered by

SHP funding and the required documentation to support the expenditures?  

Answer

Question

#7

What documentation do you provide to the SHP grantee to support requests for payment

for the services you provide?
20 

Answer Leasing structure or individual living units

for project participants

Supportive services

Question

#8

During the period 2008 to present, did the grantee make monitoring site visits to either

your place of business and/or the locations where the project participants reside and/or

receive supportive services? If yes, when?

Answer

Question

#9

Has your SHP grantee ever found possible misuse of SHP funds and/or fraudulent

activities during its monitoring of your organization?

Answer

Question

#9a

Has HUD/CPD ever visited your site and found instances of misuse or fraud involving SHP

funds?   

Answer

Question

#9b

Has your organization ever found any misuse or fraud by internal review/audit?

Answer

Question

#10

Do you provide the grantee with documentation to support the eligibility of your project

participants? If yes, describe the documentation provided to the grantee.

Answer

Question

#11

Do you provide the grantee with documentation to support the calculation on the

appropriate rental assistance funded with SHP grant funds? If yes, describe the

documentation provided to the grantee.

Answer

Question

#12

Do you verify that project participants are actually residing at the address that is

subsidized with SHP funds?

Answer

Question

#12a

Does the grantee verify that the project participants reside at the address subsidized with

SHP funds?

Answer

Question

#13

Has the grantee ever asked for documentation to support the data included in your

Annual Progress Report (APR)?

Answer

Question

#14

Has your organization filed an annual audit report per the audit requirements in the

revised OMB Circular A‐133, “Audits of States, Local Governments, and Non‐Profit

Organizations?”  Or other independent annual audit report to the grantee?

Answer

Question

#15

Identify any problems that the SHP grantee has or may encounter with its oversight and

monitoring of the project sponsors.

Answer

Questions

#16

Provide any further comments or observations about monitoring conducted by SHP

grantees and other related topics to your participation as a sponsor in the SHP.

Answer

Please provide all correspondence your organization has received from the SHP grantee since fiscal

(program) years 2008 to the present relating to its monitoring of your SHP activities.