Monitoring Overview

HIDOE Community Engagement Branch (CEB) is required by the US Department of Education (under ESEA OF 1965 as reauthorized ESSA 2015 §§ 4203(a)(14)), to monitor subgrantees to ensure compliance with:

  • Program Implementation;
  • Using the results of evaluations to refine, improve, and strengthen the program and to refine performance measures; and
  • Subgrantee expenditure of funds during the period of availability.

Monitoring by the non-Federal Entity

The HIDOE - CEB:

  1. Is responsible for oversight of the operations for the Federal award supported activities. The non-Federal entity must monitor its activities under Federal awards to assure compliance with applicable Federal requirements and performance expectations are being achieved. (2 CFR 200.329 (a))
  2. Must submit performance reports at the interval required by the Federal awarding agency or pass-through entity* to best inform improvements in program outcomes and productivity. Intervals must be no less than frequent annually nor more frequent than quarterly except in unusual circumstances. (2 CFR 200.329(1))

* Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal Program. (§200.1)

Roles/Responsibilities:

  • HIDOE - CEB Program Manager monitors Individual subgrantees to ensure that program is adhering to the original proposal and ongoing, systematic monitoring is occurring.
  • Subgrantee Project Directors monitor individual sites/centers to ensure that programs are being implemented with fidelity including:
    • Safety and security
    • Program occurrence/student enrollment/attendance
    • Data collection and reporting
    • Student engagement
    • Alignment/congruence to school day
    • Improved academic achievement in math, reading, science
    • Fiscal management

Tools:

  • Aukahi Financial Management System (AFMS)
  • DOE subgrantee AFMS reports
  • Community-based Organization subgrantee accounting records
  • Subgrantee Income/Expenditure reports
  • TransAct / Pathwise Reports

Indicator:

Evidence of subgrantee monitoring

Non-DOE subgrantee conducts annual single audit

Possible Evidence:

HIDOE Community Engagement Branch (CEB)

  • Monitoring Schedule
  • Post Monitoring Report
  • Follow-Up/Corrective Action Plan Evaluation
  • Risk Analysis

Subgrantee

  • State Monitoring Plan/Protocol/Report Form
  • Pre Monitoring Report
  • Documentation of center/site program monitoring
    • Program Observation Forms – submitted monthly by Site Coordinator
  • HIDOE Monitoring Reports and Findings
  • Follow-Up/Corrective Action Plan
  • Evidence of Implementation of Follow-Up/Corrective Action
  • Evidence of single audit (community-based organizations)
  1. Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.
  2. Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with §200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) of this section.
  3. Program-specific audit election. When an auditee expends Federal awards under only one Federal program (excluding R&D) and the Federal program's statutes, regulations, or the terms and conditions of the Federal award do not require a financial statement audit of the auditee, the auditee may elect to have a program-specific audit conducted in accordance with §200.507. A program-specific audit may not be elected for R&D unless all of the Federal awards expended were received from the same Federal agency, or the same Federal agency and the same pass-through entity, and that Federal agency, or pass-through entity in the case of a subrecipient, approves in advance a program-specific audit.
  4. Exemption when Federal awards expended are less than $750,000. A non-Federal entity that expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards is exempt from Federal audit requirements for that year, except as noted in §200.503. Records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and Government Accountability Office (GAO).
  5. Federally Funded Research and Development Centers (FFRDC). Management of an auditee that owns or operates a FFRDC may elect to treat the FFRDC as a separate entity for purposes of this part.
  6. Subrecipients and Contractors. An auditee may simultaneously be a recipient, a subrecipient, and a contractor. Federal awards expended as a recipient or a subrecipient are subject to audit under this part. The payments received for goods or services provided as a contractor are not Federal awards. Section §200.331 sets forth the considerations in determining whether payments constitute a Federal award or a payment for goods or services provided as a contractor.
  7. Compliance responsibility for contractors. In most cases, the auditee's compliance responsibility for contractors is only to ensure that the procurement, receipt, and payment for goods and services comply with Federal statutes, regulations, and the terms and conditions of Federal awards. Federal award compliance requirements normally do not pass through to contractors. However, the auditee is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Also, when these procurement transactions relate to a major program, the scope of the audit must include determining whether these transactions are in compliance with Federal statutes, regulations, and the terms and conditions of Federal awards.
  8. For-profit subrecipient. Since this part does not apply to for-profit subrecipients, the pass-through entity is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient's compliance responsibility. Methods to ensure compliance for Federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. See also §200.332
  9. [78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75887, Dec. 19, 2014]

2 CFR 200.332(b)

  1. Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:
    1. The subrecipient's prior experience with the same or similar subawards;
    2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program;
    3. Whether the subrecipient has new personnel or new or substantially changed systems; and
    4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).
  2. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in §200.208
  3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:
    1. Reviewing financial and performance reports required by the pass-through entity.
    2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward.
    3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521.
  4. Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and goals: achievement of performance
    1. Providing subrecipients with training and technical assistance on program-related matters;
    2. Performing on-site reviews of the subrecipient's program operations;
    3. Arranging for agreed-upon-procedures engagements as described in §200.425