Documentation Collection Document For Use in Section Date Received (or N/A) Comments Description: This Section provides a list of documents required to answer the questions within this Checklist. Execute this Section prior to beginning the review. Procurement Policies and Procedures 2.1 Contracting Policies and Procedures 2.2 Financial Management Policies and Procedures 2.3 Monitoring Policies and Procedures 2.4 Record Keeping Policies and Procedures (onsite only) 2.5 Most Recent Draw Request/Request for Payment and supporting documentation 3.4 Appropriate Audit/Financial Report An A-133 if the Subrecipient has expended more than $500,000 in federal funds within a fiscal year 3.3 Annual sworn financial statement if revenue received was $50,000 or less 3.3 Annual compilation if revenue received was more than $50,000 but less than $200,000 3.3 An annual review along with the required agreed upon procedure report if revenue received was $200,000 or more but less than $500,000 3.3 Federally Approved Indirect Cost Plan, if applicable 3.4 504 Self Evaluation 4.1 Section 504 Assurance 4.1 Evidence of the administration of a Fair Housing Activity 4.2 Title VI Record Documentation 4.3
Subrecipient : Monitor: Date Completed: Policies and Procedures Review Requirements Response Issue Type Comments Procurement Policies and Procedures Description: Execute this Section to determine if the Subrecipient is in compliance with applicable regulations. Regulations: 24 CFR 84.44,24 CFR 85.36, and 24 CFR 570.502 Does the Subrecipient have procurement policies and procedures in place? [24 CFR 85.36; 24 CFR 84.44] If no, the remaining questions within this Section are not applicable. Technical Assistance should be provided. Yes No N/A Finding Concern Have the Subrecipient’s procurement policies and procedures been reviewed during a previous monitoring review? Yes No N/A Finding Concern Have any issues been discovered based on prior reviews of the Subrecipient’s procurement policies and procedures or have any revisions been made since the previous review? If No, mark the remaining questions in this Section as “N/A”. Yes No N/A N/A Finding Concern Are the policies and procedures documented? Yes No N/A Finding Concern Does the Subrecipient have a process in place for communicating policies and procedures (including updates) to staff? Yes No N/A Finding Concern Procurement Policies and Procedures Requirements
Are the Subrecipient’s contract administration policies and procedures adequate? Contract Administration best practices include: Utilizing Contract Templates for developing contract; Identifying a contract administrator for each contract executed; Implementing a process to ensure contractor abides by the terms of the contract procedures; Implementing a deliverable review/approval process; and, Implementing a process for managing issues that may arise with the contractor. Yes No N/A Finding Concern Isaac Only Grantees implementing projects utilizing funding from the Hurricane Isaac allocation are required to meet these guidelines. Does the Subrecipient maintain a record of achieving certification of a comprehensive green building program or completion of the HUD CPD Green Building Retrofit Checklist, as appropriate? Yes No N/A Finding Concern If yes, proceed to question 2. If no, is the Subrecipient exempt from meeting the green building standard? Yes No N/A Finding Concern Did the Subrecipient require procured contracts to contain (1) performance measures and associated penalties and (2) a period of performance or the date of completion? Yes No N/A Finding Concern If an Action Plan Amendment is submitted after 11/18/2013, did the subrecipient describe its process for the selection and design of green infrastructure projects or activities, and/or how selected projects or activities will incorporate green infrastructure components? (Per Fed. Reg. 78 No. 222) Yes No N/A Finding Concern Financial Management Policies and Procedures Description: Use this Section to determine if the Grantee Recipient/Subrecipient’s financial management policies and procedures meet the requisite standards. Regulations: 24 CFR 84.21, 24 CFR 85.20, 24 CFR 570.502
Does the Subrecipient have financial management policies and procedures in place? If no, the remaining questions within this Section are not applicable. Technical Assistance should be provided. Yes No N/A Finding Concern Have the Subrecipient’s financial management policies and procedures been reviewed during a previous monitoring review? Yes No N/A Finding Concern Have any issues been discovered based on prior reviews of the Subrecipient’s financial management policies and procedures or have any revisions been made since the previous review? If no, mark “N/A” for the remaining questions in this Section. Yes No N/A N/A Finding Concern Are the policies and procedures documented? Yes No N/A Finding Concern Does the Subrecipient have a process in place for communicating policies and procedures (including updates) to staff? Yes No N/A Finding Concern Financial Management Policy and Procedures Requirements Internal Controls Requirements - Do the financial management policies and procedures require defined staff qualifications and duties, lines of authority, and separation of functions? [24CFR85.20(b)(3) and 84.21(a)(3)] Yes No N/A Finding Concern Internal Controls Requirements - Do the financial management policies and procedures require control over secure access to assets, blank forms, and confidential documents? [24CFR85.20(b)(3) and 84.21(b)(3)] Yes No N/A Finding Concern Internal Controls Requirements - Do the financial management policies and procedures include a process for approving and recording transactions? [24CFR85.20(b)(3) and 84.21(b)(3)] Yes No N/A Finding Concern
Do the monitoring policies and procedures provide guidance on conducting, documenting, and reporting on monitoring activities and on follow up on areas of Monitoring best practices may include: Prioritizing based on Risk Prescribing a Sampling methodology Monitoring Performance Implementing a tracking system Technical Assistance procedures Yes No N/A Finding Concern Do the monitoring policies and procedures include monitoring Project/Program performance? Monitoring best practices may include monitoring based on: Compliance with approved application scope, funding specifications, and other requirements Program guidelines Implementation schedule and milestones [24CFR84.51 and24 CFR 85.40 Yes No N/A Finding Concern Record Keeping Policies and Procedures – ONSITE ONLY Description: Use this Section to determine if the Subrecipient’s Record Keeping Policies and Procedures are sufficient. Regulations: 24 CFR 85.40, 24 CFR 84.53, 24 CFR 570.506, and 24 CFR 570.490 Does the Subrecipient have Record Keeping policies and procedures in place? If no, mark “No” for the remaining questions in this Section. Yes No N/A Finding Concern Have the Subrecipient’s record keeping policies and procedures been reviewed during a previous monitoring review? Yes No N/A Finding Concern Have issues been discovered based on prior reviews of the record keeping policies and procedures or have any revisions been made since the previous review? If no, mark “N/A” for the remaining questions in this Section. Yes No N/A N/A Finding Concern Are the policies and procedures documented? Yes No N/A Finding Concern Does the Subrecipient have a process in place for communicating policies and procedures (including updates) to staff? Yes No N/A Finding Concern
Validation of Financial Management System Requirements Response Issue Type Comments If there’s program income, is the Grantee/ Recipient/Subrecipient disbursing program income prior to making further draw requests? Yes No N/A N/A Finding Concern Has the Subrecipient charged any indirect costs? Yes No N/A Finding Concern If yes, did the Subrecipient submit a federally-approved Indirect Cost Plan to OCD/DRU? Yes No N/A N/A Finding Concern Are the Subrecipient’s administrative costs at or below the authorized threshold? Yes No N/A Finding Concern Internal Controls – Is there evidence that there are appropriate separation of duties in the approving of a Request for Payment and the payment of invoices? Yes No N/A Finding Concern
Subrecipient : Monitor: Date Completed: Civil Rights Requirements Response Issue Type Comments Section 504 Description: Section 504 of the Rehabilitation Act of 1973, as amended, requires that no handicapped individual can be excluded from participation (including employment), denied program benefits, or subjected to discrimination based solely on his or her handicap. Has the Subrecipient’s Section 504 Compliance been previously reviewed? Yes No N/A Finding Concern Were issues identified during the previous review? If yes, continue through this Section. If no, continue to next Section. Yes No N/A N/A Finding Concern Has the Subrecipient submitted a Section 504 Self Evaluation? Yes No N/A Finding Concern Has the Subrecipient completed the Section 504 Assurance? Yes No N/A Finding Concern Have any complaints been received? Yes No N/A Finding Concern If yes, have the complaints been resolved? Yes No N/A Fair Housing Description: Title VIII of the Civil Rights Act of 1968, as amended (referred to as the “Fair Housing Act”) prohibits discrimination in housing on the basis of race, color, religion, sex, or national origin. The Subrecipient is required to administer at least one fair housing activity annually. Is the Subrecipient ensuring that all activities are implemented to affirmatively promote fair housing? Yes No Has the Subrecipient administered at least one fair housing activity within the last year? Notate the date and identify the type of activity of the most recent fair housing activity within the Comments field. Yes No Have any complaints been received? Yes No If yes, have the complaints been resolved? Yes No
Does the Subrecipient have written procedures (i.e., “Section 3 Plan”) governing how Section 3 residents are to be notified about employment and training opportunities generated by program participant or its contractors as a result of the expenditure of covered financial assistance? [24CFR 135.32 (a)] Yes No N/A N/A Finding Concern Does the Subrecipient have written procedures (i.e., “Section 3 Plan”) governing how Section 3 business concerns are to be notified about contracting (or subcontracting) opportunities generated by the program participant or its contractors involving covered financial assistance? [24 CFR 135.32 (a)] Yes No N/A N/A Finding Concern Does the Subrecipient have written procedures (i.e., “Section 3 Plan”) governing how applicable entities are notified about their requirements pursuant to Section 3? [24 CFR 135.32(b) and 24 CFR 135.32(f)] Yes No N/A N/A Finding Concern Does the Subrecipient have written procedures (i.e., “Section 3 Plan”) governing how compliance with the requirements of Section 3 will be monitored? [24 CFR 135.32(d) and 24 CFR 135.32(f)] Yes No N/A N/A Finding Concern Does the Subrecipient have written procedures (i.e., “Section 3 Plan”) describing the steps taken to facilitate meeting the minimum numerical goals for employment and contracting opportunities? [24 CFR 135.32(c)] Yes No N/A N/A Finding Concern
Grantee/ Recipient/ Subrecipient : Monitor: Date Completed: File Review – ONSITE ONLY Requirements Response Issue Type Comments Instructions: Use this Section to indicate the completeness of the files reviewed during the onsite review. Refer to Section 4 of the OCD Disaster Recovery CDBG Grantee Administrative Manual for a list of documents that should be kept in each file. Additionally, if a Project Review has recently occurred (or is underway), the Monitor may use the results of the Project Review to draw conclusions regarding the sufficiency of the files. Are the Subrecipient’s General files adequate? Yes No Finding Concern Review the Subrecipient’s Citizen Participation Files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Procurement and Contracting files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Management/Personnel files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s monitoring files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Acquisition files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Relocation files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Section 504 files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Equal Opportunity files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Labor files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s audit files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Environmental Review files. Are the files adequate? Yes No Finding Concern Pull a sample of the Subrecipient’s Close-Out files. Are the files adequate? Yes No N/A Finding Concern Pull a sample of the Subrecipient’s National Objective / Eligible Activities files. Are the files adequate? Yes No Finding Concern