Mississippi Administrative Code › Title 18 - HUMAN SERVICES › Part 15 - Division of Community Services › Chapter 1 - Community Services Block Grant (CSBG) › Rule 18-15-1-1 - Community Services Block Grant (CSBG) State Plan › Attachment - ATTACHMENT › Attachment - COMPLIANCE MONITORING

Current through June 25, 2024
Statutory Reference 2605(b)(10)
Division of Monitoring (DPI)
MONITORING
The Mississippi Department of Human Services (MDHS) is
						required to monitor the activities of its subgrantees by following the Single
						Audit Act Amendments of 1996, the Office of Management and Budget (OMB)
						Circular A-133,
Audits of States, Local Governments, and Non-Profit
						Organizations,
and the OMB Circular A-133 Compliance Supplement. MDHS
						shall monitor each project, program, subgrant, function, or activity supported
						by a Federal award to assure compliance with applicable Federal regulations and
						that performance goals are achieved.
POLICY
MDHS has established uniform monitoring policies designed
						to ensure that all subgrants under the jurisdiction of MDHS are administered in
						compliance with Federal requirements and with the terms of the subgrant
						agreements. Monitoring subgrants, for compliance with the applicable Federal
						regulations, State laws, Agency policies, and the terms of the subgrant
						agreements, is the responsibility of the MDHS Division of Monitoring.
Subgrant monitoring procedures may include several of the
						various options available. These options include: reviewing reports submitted
						by the subgrantee; reviewing documentation supporting expenses reported under
						MDHS subgrants; reviewing the subgrantee's single audit or program-specific
						audit results and evaluating audit findings and the subgrantee's corrective
						action plan; performing on-site reviews of fiscal and programmatic records and
						observing subgrantee operations; and/or, arranging for limited scope audits of
						specific compliance areas.
Planning Considerations
When determining the extent of monitoring procedures to
						perform, MDHS will consider factors such as the amount of the subgrant, the
						percentage of a Federal program's total funds awarded to subgrantees, and the
						complexity of the compliance requirements. To determine the appropriateness of
						monitoring procedures, MDHS will consider the cost-effectiveness of monitoring
						procedures compared to the relative size and complexity of the Federal awards
						administered by the subgrantee. The following factors will also be considered
						when determining the monitoring procedures to be performed to ensure compliance
						with the Federal regulations, State laws, Agency policies and procedures, and
						the terms of the subgrant agreement:
1. The amount of the subgrant in relation to
					 the total amount of the program;
2.
					 Prior experience of the subgrantee operating subgrants supported by Federal
					 funds;
3. Results of the MDHS
					 follow-up on prior year single audit findings;
4. Results of the review of documents
					 submitted by the subgrantee;
5.
					 Results of the desk review of supporting documentation for
					 expenditures;
6. Results of
					 previous on-site fiscal and programmatic reviews; and/or,
Monitoring Procedures
1.
Review of Reports Submitted by
					 Subgrantees
Subgrants may be monitored by reviewing reports submitted
						by the subgrantee for compliance with the subgrant agreement and program
						instructions. For example, the monthly reporting worksheets may be reviewed for
						accuracy and completeness or the quarterly programmatic report may be reviewed
						to ensure that each element of the Scope of Services is being met.
2.
Review of Supporting
					 Documentation for Expenditures
Subgrants may be monitored by performing a desk review of
						supporting documentation for expenditures reported under the subgrant. This
						review consists of contacting the subgrantee and requesting documents to
						support certain amounts included on the subgrantee's reporting worksheets.
						These documents will be examined by the monitors to determine compliance with
						the subgrant agreement and with State and Federal regulations. The results of
						the desk review will be communicated in a written report to the subgrantee and
						to the MDHS Funding Division.
Desk reviews may be conducted at any time by staff of the
						MDHS, Division of Monitoring. The desk review procedure may be used in lieu of
						or in conjunction with an on-site fiscal review or as a follow-up to an on-site
						fiscal review to ensure that corrective actions have been implemented.
Fiscal monitoring through a desk review will include, at
						a minimum, a review of all documents to support all expenses reported for one
						month of the subgrant period. Documents shall be reviewed to support costs
						reported on the reporting worksheet submitted for the month in which the
						highest dollar amount of expenses was reported as of the date that the schedule
						letter was prepared to begin the desk review and request support
						documents.
When fiscal monitoring is initiated through a desk review
						and sufficient documents are not provided by the subgrantee/contractor to
						support costs reported on the reporting worksheet, the desk review shall cease,
						and fiscal monitoring shall be completed through an on-site review.
Fiscal monitoring shall not be performed through a desk
						review on the first subgrant awarded to a subgrantee. In addition, monitoring
						through a desk review shall be alternated with on-site reviews so that on-site
						fiscal monitoring is performed at least every other year.
Monitoring for programmatic compliance cannot be
						performed through a desk review.
3. Review of the Subgrantee's Single Audit
					 Report for Compliance, Evaluation of Audit Findings, and Follow-up on
					 Corrective Actions
Subgrantees that expend $500,000.00 or more of Federal
						financial assistance during the subgrantee" s fiscal year shall have an audit
						performed by an independent Certified Public Accountant in accordance with the
						Single Audit Act and OMB Circular A-133. As a part of MDHS" monitoring of each
						of its subgrants, these independent auditor's reports shall be obtained from
						the subgrantees and reviewed for compliance with Federal regulations.
Any audit findings identified in the independent auditor
						' s reports, as well as the subgrantees proposed corrective action plans, shall
						be evaluated by the MDHS Funding Divisions. If the subgrantee's corrective
						action plan is acceptable, a management decision will be issued by the MDHS
						Funding Division to resolve the audit findings. The MDHS Division of Monitoring
						will follow-up on the subgrantee's corrective action plan during the next
						on-site fiscal review that is conducted.
4. On-Site Reviews for Program Compliance
On-site reviews for program compliance are required to be
						conducted at least once during the subgrant period for every MDHS subgrant.
						On-site reviews for program compliance may be performed on any subgrant at any
						time and may be repeated as often as deemed necessary by MDHS. These reviews
						for program compliance will be conducted by the MDHS Division of
						Monitoring.
The on-site programmatic reviews are formal in nature and
						are normally preceded by written notification to the subgrantee and to the
						appropriate MDHS Funding Division Directors. However, unannounced on-site
						programmatic reviews may also be conducted. On-site entrance and exit
						conferences will be conducted with subgrantee officials and a written report
						will be issued communicating the results of the review to the subgrantee and to
						the MDHS Funding Divisions. The Agency shall follow-up on the subgrantee's
						corrective action plan for any programmatic monitoring findings.
5. On-Site Reviews for Fiscal
					 Compliance
On-site reviews for fiscal compliance will be conducted
						by the Division of Monitoring, as provided under this section. These visits may
						also be conducted at the request of the MDHS Executive Director or the MDHS
						Funding Division Director.
These reviews are formal in nature and are normally
						preceded by written notification to the subgrantee. The appropriate Funding
						Division Directors shall also receive written notification of on-site fiscal
						reviews. However, unannounced on-site fiscal reviews may also be conducted.
						On-site entrance conferences will be conducted with subgrantee officials. Exit
						conferences will be conducted and a written report will be issued communicating
						the results of the review to the subgrantee and to the MDHS Funding Divisions.
						MDHS shall follow-up on the subgrantee's corrective action plan for any fiscal
						monitoring findings.
6.
					 Limited Scope Audits of Specific Compliance Areas
The Agency may engage an independent Certified Public
						Accountant to perform a Limited Scope Audit of certain MDHS subgrants. The need
						for this type of review shall be determined on an individual basis and shall be
						documented by the Division of Monitoring. The results of this review shall be
						communicated to the subgrantee and to the MDHS Funding Divisions in a written
						report.
Corrective Action Process
The Initial Report of Findings and Recommendations that
						is forwarded to the subgrantee and to the MDHS funding division shall require a
						written response from the subgrantee within fifteen (15) working days. Upon
						receipt of the response from the subgrantee, the Director of the Division of
						Monitoring and other appropriate staff shall assess each response for adequacy.
						If all responses are adequate, a letter will be issued to the subgrantee
						clearing all findings. If any responses do not adequately address the findings,
						the subgrantee will be notified in writing by the issuance of a Status Report
						acceptable to MDHS requiring a second response from the subgrantee within ten
						(10) working days.
If the subgrantee fails to satisfactorily resolve all of
						the monitoring findings, the Division of Monitoring will issue a Final Notice
						Letter to the subgrantee demanding that the subgrantee refund the amount of
						questioned costs and advising the subgrantee of the procedures to follow if
						they wish to request an administrative hearing with the MDHS Executive
						Director.
If the subgrantee does not respond to the Final Notice
						Letter, the subgrantee will be referred to the State of Mississippi Office of
						the Attorney General to recover the unresolved questioned costs, and the Agency
						may begin procedures for debarment and suspension against the subgrantee
						organization and the subgrantee authorized official.
Discovery of Possible Fraud, Mismanagement, or Program
						Abuse
In the event indications of possible fraud,
						mismanagement, or program abuse are discovered during the course of monitoring
						subgrants, the Director of the Division of Monitoring shall notify the Chief
						Compliance Officer, who shall notify the MDHS Inspector General. The MDHS
						Inspector General and appropriate personnel will decide the course of action to
						be taken, including the degree of disclosure to subgrantee personnel and to the
						MDHS Funding Divisions. The format for reporting such incidents will be
						determined by the Chief Compliance Officer and/or the MDHS Inspector
						General.
Division of Community Services (DCS)
Statutory Reference 2605(b)(10)
TRAINING AND TECHNICAL ASSISTANCE
						(T&TA)
DCS staff uses several tools and checklists to conduct an
						overall comprehensive review of the agencies' operations. Throughout both the
						programmatic and fiscal review process there should be ongoing, open
						communication with the staff to facilitate clarification of facts and prevent
						misunderstandings, provide the reviewer with a full understanding of the
						agencies' operations, and provide the agency with a full understanding of the
						review process.
Preliminary areas of noncompliance should be summarized
						and discussed with the Executive Director and/or designated staff during the
						exit conference. Copies of specific documents, supporting schedules, and
						reports obtained during the site visit to facilitate preparation of the report
						should be discussed during the exit conference. The agency is given the
						opportunity to provide comments and present additional information or
						explanation regarding a specific finding before it is included in the
						report.
The report should include specific timelines for any
						required corrective action associated with each finding. Copies of the report
						should be mailed to agency's Board and the agency's Executive Director. A copy
						should also be provided to the DCS Program Director and Compliance
						Officer.
The agency is required to respond in writing to each of
						the findings and observations mentioned in the report, including a detailed
						plan for taking corrective actions and implementing required changes. The
						initial response is due within 30 days from the date of the report. The
						agency's plan for resolution and corrective action will be reviewed by
						Compliance Team to ensure that all findings have been adequately
						addressed.
In the event an agency is unable or unwilling to correct
						a specified area of noncompliance within the prescribed timeline, DCS will
						report the deficiency to MDHS-Inspector General. If MDHS determines that the
						agency remains noncompliance in a specified area, DCS may contact DHHS to
						initiate proceedings to terminate the organization's designation as a Community
						Action Agency.
Division of Community Services (DCS)
Statutory Reference 2605(b)(10)
FEDERAL (SINGLE) AUDIT MANAGEMENT
						LETTER
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