4.7 Subrecipient Monitoring

4.7.2 Monitoring Requirements

Effective date: TBD

Subrecipient monitoring is conducted to measure performance against established targets or standards, and to provide feedback on the effectiveness of processes and on areas for improvement. Monitoring activities are necessary to ensure funds are being expended as intended to carry out program objectives, in compliance with appropriate laws, regulations, DWD-DET policy, and the terms and conditions of the subaward. Subrecipient monitoring must be conducted on an annual basis and must cover each program, function, or activity.¹

• ¹ 2 CFR § 200.329(a)

4.7.3 Monitoring Plan Requirements

Effective date: TBD

The recipient must develop a monitoring plan that addresses the scope, frequency, and subrecipient performance standards. This monitoring plan must be included in the grant plan. The monitoring plan should describe the monitoring approach, the monitoring responsibilities of each party involved, the monitoring methods to be used, and the rationale for their use.

4.7.4 Report

Effective date: TBD

The recipient must document findings and issues in written reports to the subrecipient.

4.7.5 Corrective Action

Effective date: TBD

The recipient must comply with the following provisions for corrective action and sanctions:

1. Corrective Action for Noncompliance. The recipient must attempt to resolve noncompliance issues by: Notifying the subrecipient of the identified monitoring findings; and either requiring or providing a corrective action plan that provides a resolution within a specified timeframe. Sanctions should be included if the corrective action is not implemented.
2. Notification of Sanctions. The recipient must provide written notification to the subrecipient of sanctions to be invoked if the subrecipient refuses to submit to or agree to adhere to the plan, or the monitoring finding continues after corrective action is required. The notification must provide the rights to an appeal and hearing process in accordance with this policy and procedure manual.
3. Severity of Sanctions. Sanctions must reflect the severity of the monitoring finding. The recipient must inform DWD-DET, in writing, of any sanction imposed or any referral to other agencies for prosecution. Other sanctions may result due to referral from the appropriate governmental agency or law enforcement agency for prosecution or other action as provided by law.
4. Monitoring Corrective Action Results. The recipient must monitor the corrective action plan to ensure the results and timeframes specified are achieved.

4.7.6 Records

Effective date: TBD

The recipient must maintain written records to verify that required monitoring, corrective action, follow-up, and resolution have occurred.

4.7.7 Risk Assessment

Effective date: TBD

A risk assessment of each subrecipient must be conducted on an annual basis to determine the appropriate level of monitoring. This risk assessment should rate risk based on the following factors:

• Prior experience with the same or similar subawards
• Financial stability
• Management systems and standards
• History of performance
• Audit reports and findings
• Ability to effectively implement requirements

This list is not exhaustive as other factors may be considered in the annual risk assessment.

The recipient should use professional judgment in evaluating risk and determining the level of monitoring needed for subrecipients; the level of monitoring should be documented. Monitoring findings must be considered in subsequent program planning and in the selection of subrecipients. Subrecipients that are deemed high-risk may be subject to additional terms and conditions in the grant agreement to help ensure success of the grant. The workforce development area (WDA) may consider imposing specific subaward conditions upon the subrecipient, if appropriate, as described in 2 CFR §200.208.