How We Monitor Your Progress
The city’s Housing and Community Development Division (HCD) staff conducts monitoring of its entitlement programs through a variety of methods. Methods are dictated by the complexity of the activity, funding source regulations, subrecipient performance, citizen complaints, agency capacity and available resources. Monitoring techniques may include phone conversations, written correspondence, desk and on-site monitoring and other methods.
We've outlined our process below so you know what to expect each step of the way.
Step 1 - Eligibility Analysis
Every new program year we do an Eligibility Analysis to ensure your program meets an Eligible Activity/a National Objective and benefits low-and moderate-income persons (as defined under CDBG entitlement regulations 570.201.)
Step 2 - Risk Assessment Monitoring
We then do a Risk Assessment Monitoring to determine the level (i.e., High, Medium or Low) of risk your program has. The factors that shape the level of risk are:
- Contract Dollar Amount
- Program Oversight
- Type of Contract
- Number of Clients Served
- Key Organizational Change
- Program Participants
- Performance Measurements
- Contract Experience History
- Last Monitoring Visit
- Corrective Action (Any Monitoring)
Risk Assessment Form
Step 3 - Desk Monitoring
We conduct monthly Desk Monitoring which includes the ongoing process of reviewing subrecipient performance.
- Requests for reimbursements and accompanying source documents.
- Audit reports
- Staff reports from prior monitoring visits
- Client/Citizen comments and complaints
- Information provided by other State, Federal, County, and local agencies.
- Subrecipient responses to monitoring and/or audit findings
- Original grant application
- Subrecipient Agreement and amendments if applicable
- Monthly or quarterly progress reports
- Changes in personnel or project-related changes to scope or budget
- Litigation if applicable
Desk Monitoring Form
Step 4 - On-Site to Monitor
Depending on the level of risk assessed for your program, we then come On-Site to Monitor. Please note: Due to COVID-19, on-site monitoring may take place virtually.
- Before we come on-site, we provide a formal 30-day notice to you. We also outline exactly what documentation we’re requesting to monitor.
- Activities considered to be high risk will receive on-site monitoring first, preferably within the first few months of the program year. This proactive approach can help head off any potential areas of non-compliance, and provide subrecipients with any technical assistance needed to ensure compliance with CDBG requirements.