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HOMEfires - Vol. 4 No. 4, September 2002
Q: What are a Participating Jurisdiction's (PJ's) responsibilities for monitoring with respect to entities using its HOME funds?
While the annual review process is a requirement of the HOME program, it is also a helpful tool the PJ can use toward achieving program compliance and effectiveness. Performing regular monitoring helps the PJ:
Monitoring involves reviewing organizations the PJ has entrusted with HOME funds (such as subrecipients and CHDOs) as well as internal monitoring, to ensure that the PJ's own administration of its program is effective and complies with HOME requirements. When performing external monitoring, the PJ must assess compliance of the entity and its projects with HOME requirements, cross-cutting federal requirements, and applicable OMB circulars. The PJ should also assess the entity's efficiency, timeliness, and adherence to the terms of its written agreements with the PJ during project development and throughout the period of affordability.
The staff and financial resources available to a PJ are generally insufficient to permit an on-site review of each entity participating in its HOME program each year. Therefore the PJ should develop a risk assessment process by which it can determine which HOME recipients have the highest probability of non-compliance. To develop a risk assessment protocol, the PJ must identify important factors to measure an organization's capacity and performance. Some factors the PJ might include in a risk assessment protocol are: level of previous experience/ track record of the entity, amount of commitment of HOME funds, timeliness/productivity of project, and staff turnover. The PJ then assigns points to each factor and totals them to provide a final score indicating the organization's level of potential risk. PJs should document the results of the risk assessment and its decisions with respect to the reviews to be conducted. When HUD field staff monitor a PJ for HOME compliance, they assess the frequency and quality of the PJ's oversight of the entities participating in its program. Failure to comply with the annual review requirement is the basis for a finding of non-compliance. Consequently, the PJ should document each step of its annual review process. For more information and resources regarding monitoring and risk assessment see:
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Content Archived: May 19, 2011 | |
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