Common use of Subrecipient Monitoring Clause in Contracts

Subrecipient Monitoring. The recipient is required by federal Office of Management and Budget (OMB) Circular A-133 to ensure that federal CDBG program requirements are met, that the funds are used for the purpose of the program, and that the Subrecipient complies with reporting and auditing requirements. If the Subrecipient is required to have an A-133 audit (as discussed below), the Recipient must review the A-133 audit report and follow up on any audit findings that relate to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue a management decision within six months of receipt of the audit report and ensure that the Subrecipient takes appropriate and timely corrective action. The management decision shall clearly state whether or not the audit findings are sustained, the reasons for the decision, and the expected subrecipient action to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reports. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by the Recipient to the Subrecipient’s CDBG-assisted facilities. At regular intervals during the term of this Agreement, the Recipient may conduct reviews of the content and progress of the Subrecipient services. If, as a result of such reviews, it is the opinion of the Recipient that revisions to the Scope of Services (paragraph 2) is necessary or the methods employed by the Subrecipient are inappropriate, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisions. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.

Subrecipient Monitoring. 21.01 The recipient Grantee is required solely responsible for monitoring its subrecipients and will submit copies of all executed subcontracts from subrecipients through WebGrants within 60 calendar days of the execution of this Agreement. Subcontracts should cover all personnel contained in the “contractual” line item within the grant budget. Each listed agency shall have its own subcontract signed by federal Office the Grantee and an employee of Management and Budget (OMB) Circular A-133 the subrecipient agency that is authorized to ensure that federal CDBG program requirements are met, that the funds are used enter into legally binding contracts for the purpose of entity receiving funds. Failure to submit these documents to the programSCAO within 60 calendar days may result in withholding future payment or other penalties, and that as determined by the Subrecipient complies with reporting and auditing requirements. If the Subrecipient is required to have an A-133 audit (as discussed below)SCAO. 21.02 Before any Services are rendered by subrecipients, the Recipient Grantee must review the A-133 audit report and follow up on any audit findings that relate to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue obtain a management decision within six months of receipt of the audit report and ensure that the Subrecipient takes appropriate and timely corrective action. The management decision shall clearly state whether or not the audit findings are sustained, the reasons for the decision, and the expected subrecipient action to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reportswritten subcontract executed by all affected Parties. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by 21.03 The Grantee’s subcontracts with subrecipients shall require the Recipient subrecipients to the Subrecipient’s CDBG-assisted facilities. At regular intervals during the term comply with all applicable terms of this Agreement, including all OHSP Grant Management Requirements (Attachment 2) incorporated into this Agreement. The Grantee shall provide all subcontractors with a copy of this Agreement and a copy of OHSP Grant Management Requirements (Attachment 2). 21.04 In the Recipient may conduct reviews event of a conflict between provisions in this Agreement and subrecipients’ subcontract provisions, this Agreement shall prevail, and this term shall be included by the Grantee in all subrecipient subcontracts. A conflict between this Agreement and the subrecipient’s subcontract, however, shall not be deemed to exist where the subcontract requires the subrecipient to perform Services in less time than this Agreement affords the Grantee. The Grantee is solely responsible to the SCAO for any and all subcontracted Services and for any breaches caused by subrecipients. 21.05 Expenses must be reasonable and necessary. If detailed Expense information is not included as part of the content and progress of the Subrecipient services. If, as a result of such reviews, it is the opinion of the Recipient that revisions to the Scope of Services (paragraph 2) is necessary or the methods employed by the Subrecipient are inappropriateapplication process, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisionsGrantee must submit a request seeking approval once sufficient detail has been supplied. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.

Subrecipient Monitoring. The recipient is Grantee will monitor the performance of Subrecipient in accordance with regulations of Subrecipient Monitoring and Management, 2 CFR 200.330 – 2 CFR 200.332, to ensure compliance with all of the requirements of this Agreement and the goals and performance standards as stated in this agreement. Subrecipient shall provide Grantee all necessary reporting information as required by federal Office of Management and Budget (OMB) Circular A-133 the DOH. Substandard performance as determined by the Grantee will constitute noncompliance with this Agreement. If action to ensure that federal CDBG program requirements are met, that the funds are used for the purpose of the program, and that correct such substandard performance is not taken by the Subrecipient complies within 30 days after being notified by ▇▇▇▇▇▇▇, the Grantee may impose additional conditions on the Subrecipient and its use of CDBG funds consistent with reporting 2 CFR 200.207, suspend or terminate this Agreement, or initiate other remedies for noncompliance as appropriate and auditing requirementspermitted under 2 CFR 200.338. Monitoring procedures may include, but not be limited to, on-site visits by Grantee staff, limited scope audits, or other procedures. The Subrecipient agrees to comply and cooperate with any monitoring procedures/processes deemed appropriate by the Grantee. If the Grantee determines that a limited scope audit of the Subrecipient is appropriate, the Subrecipient agrees to comply with any additional instructions provided by the Grantee to the Subrecipient regarding such audit. The Subrecipient further agrees to comply and cooperate with any inspections, reviews, investigations or audits deemed necessary by the DOH. In addition, the Grantee will monitor the performance and financial management by the Subrecipient throughout the period of agreement to ensure timely completion of all tasks. A Subrecipient that expends $750,000 or more in federal funds, in a single fiscal year, is required to have an A-133 audit (as discussed below), the Recipient must review the A-133 audit report in compliance with 2 CFR 200 Subpart F. The Subrecipient is responsible for submitting a data collection form and follow up on any audit findings that relate reporting package to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue a management decision federal clearinghouse within six nine months of receipt the end of the audit report and ensure that the Subrecipient takes appropriate and timely corrective actionperiod. The management decision shall clearly state whether or not audit must be filed electronically on OPM’s audit reporting system by the auditor. Subrecipients are required to make the audit findings are sustained, the reasons for the decision, and the expected subrecipient action to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reports. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by the Recipient report available to the Subrecipient’s CDBG-assisted facilities. At regular intervals during the term of this Agreement, the Recipient may conduct reviews public no later than thirty days (30) after completion of the content and progress of the Subrecipient services. If, as a result of such reviews, it is the opinion of the Recipient that revisions to the Scope of Services (paragraph 2) is necessary or the methods employed by the Subrecipient are inappropriate, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisionsaudit. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.

Subrecipient Monitoring. The recipient is required by federal Office of Management and Budget (OMB) Circular A-133 to ensure that federal CDBG program requirements are met, that the funds are used for the purpose of the program, and that the Subrecipient complies with reporting and auditing requirements. If the Subrecipient is required to have an A-133 audit (as discussed below), the Recipient must review the A-133 A- 133 audit report and follow up on any audit findings that relate to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue a management decision within six months of receipt of the audit report and ensure that the Subrecipient takes appropriate and timely corrective action. The management decision shall clearly state whether or not the audit findings are sustained, the reasons for the decision, and the expected subrecipient action to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reports. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by the Recipient to the Subrecipient’s CDBG-assisted facilities. At regular intervals during the term of this Agreement, the Recipient may conduct reviews of the content and progress of the Subrecipient services. If, as a result of such reviews, it is the opinion of the Recipient that revisions to the Scope of Services (paragraph 2) is necessary or the methods employed by the Subrecipient are inappropriate, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisions. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.

Subrecipient Monitoring. The recipient is required by federal Office of Management and Budget (OMB) Circular A-133 to ensure that federal CDBG program requirements are met, that the funds are used for the purpose of the program, and that the Subrecipient complies with reporting and auditing requirements. If the Subrecipient is required to have an A-133 audit (as discussed below), the Recipient must review the A-133 audit report and follow up on any audit findings that relate to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue a management decision within six months of receipt of the audit report and ensure that the Subrecipient takes appropriate and timely corrective action. The management decision shall clearly state whether or not the audit findings are sustained, the reasons for the decision, and the expected subrecipient action to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reports. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by the Recipient to the Subrecipient’s 's CDBG-assisted facilities. At regular intervals during the term of this Agreement, the Recipient may conduct reviews of the content and progress of the Subrecipient services. If, as a result of such reviews, it is the opinion of the Recipient that revisions to the Scope of Services (paragraph 2) is necessary or the methods employed by the Subrecipient are inappropriate, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisions. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s 's fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.

Subrecipient Monitoring. The recipient is SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required by federal Office of Management to manage and Budget (OMB) Circular A-133 monitor their subrecipients to ensure that federal CDBG program compliance with requirements are metof the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass- through entities. First, your organization must clearly identify to the subrecipient: (1) that the funds are used award is a subaward of SLFRF funds; (2) any and all compliance requirements for the purpose use of the programSLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Next, your organization will need to evaluate each subrecipient’s risk of noncompliance based on a set of common factors. These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. Accordingly, your organization should develop written policies and procedures for subrecipient monitoring and risk assessment and maintain records of all award agreements identifying or otherwise documenting subrecipients’ compliance obligations. Recipients should note that NEUs are not subrecipients under the SLFRF program. They are SLFRF recipients that report directly to Treasury. Recipients should also note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F. Many recipients may choose to provide a subaward or contract to other entities to provide services to other end users. For example, a recipient may provide a subaward to a nonprofit to provide homeless services to individuals experiencing homelessness. In this case, the subaward to a nonprofit is based on the services that the Subrecipient complies with reporting and auditing requirements. If the Subrecipient is required recipient intends to have an A-133 audit provide (as discussed belowassistance to households experiencing homelessness), the Recipient must review the A-133 audit report and follow up on any audit findings that relate to the CDBG project. If there are findings relative to the CDBG project, the Recipient must issue a management decision within six months of receipt of the audit report and ensure that the Subrecipient takes appropriate and timely corrective action. The management decision shall clearly state whether or not the audit findings are sustained, the reasons for the decision, and the expected subrecipient action nonprofit is serving as the subrecipient, providing services on behalf of the recipient. Subrecipients are subject to repay disallowed costs, make financial adjustments, or take other action. Recipient procedures to ensure that the Subrecipient is meeting program requirements may also include: (1) Perform an analysis of financial status reports. (2) Determine appropriateness of disbursements through review of supporting documentation. (3) On-site visits by the Recipient audit pursuant to the Subrecipient’s CDBG-assisted facilities. At regular intervals during the term of this AgreementSingle Audit Act and 2 CFR part 200, the Recipient may conduct reviews of the content and progress of the Subrecipient services. Ifsubpart F regarding audit requirements, as a result of such reviews, it is the opinion of the Recipient that revisions whereas contractors are not subject to an audit pursuant to the Scope of Services (paragraph 2) Single Audit Act and 2 CFR part 200, subpart F regarding audit requirements. Please note that as outlined in 2022 Final Rule FAQ 13.14, recipients’ useof funds in the revenue loss eligible use category does not give rise to subrecipient relationships. As a result, subaward reporting is necessary or not required for projects in the methods employed by the Subrecipient are inappropriate, the Recipient may require such revisions by notifying the Subrecipient in writing. Upon receipt of such notification of revision, the Subrecipient shall, within ten (10) days, propose the manner in which the Subrecipient will comply with the revisionsrevenue loss eligible use category. (4) Review limited scope audit reports. If the Subrecipient expended less than $500,000 in federal awards the Recipient may require an agreed-upon procedures engagement. These engagements may address only one or more of the following types of compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; matching level of effort, earmarking; and reporting. (5) Review any financial statement audits when other type audits are not required. The Recipient will also review the Subrecipient’s fidelity bonding and fiscal and accounting procedures to determine if they meet the requirements of the Agreement.