2022 Consolidated Annual Perfprmance and Evaluation Report

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CR-40 - Monitoring 91.220 and 91.230 Describe the standards and procedures used to monitor activities carried out in furtherance of the plan and used to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements In a typical fiscal year, on-site audits at local agencies receiving CDBG, HOME, and ESG funds are scheduled per the HCD Plan,to ensure compliance. All CDBG, HOME,and ESG subrecipients are desktop-monitored multiple times throughout the calendar year.This monitoring occurs with each claim for reimbursement that is submitted to the Department of Community Investment.All subrecipients also receive feedback and/or guidance via email and phone communication,and in-person or virtual meetings with DCI staff throughout the year. In addition, Community Investment staff conduct a number of on-site monitoring visits of subrecipients every year to review their internal systems.As part of the monitoring visit, DCI staff meet with appropriate members of the subrecipient staff to review procedures, client files,financial records, and other pertinent data. In addition,any new subrecipient is monitored in its first year of funding. Subrecipients are selected for onsite monitoring based on factors such as delayed projects,slow draws, compliance concerns, staff turnover, and/or other concerns that may be identified through desktop monitoring. The audits are performed by two DCI staff members that review accounting procedures and program compliance. Onsite monitoring visits are in addition to the desk audits completed when reviewing subrecipient claims, constant communication on projects via phone and email,and various meetings to discuss program issues. Each claim for payment submitted by a subrecipient requires a progress report relevant to the goals stated in the Scope of Services. Turnover in Department of Community Investment and Administration and Finance staff resulted in delays while new staff received training to enable successful monitoring of all sub-receipients. The following remote monitorings were conducted by staff in 2022; no findings were identified: • South Bend Heritage Foundation (11/2022)—CDBG and HOME • 466 Works(03/2022)-CDBG • Near Northwest Neighborhood, Inc. (12/2022)—CDBG and HOME On-site monitoring is being scheduled for 2023 in addition to regularly scheduled meetings wiht sub- grantees with multiple contracts. When the City of South Bend contracts with CDBG and HOME subrecipients,a memo is provided detailing the process to engage M/WBEs. In addition,a list of M/WBEs in St.Joseph County from the CAPER 36 OMB Control No:2506-0117(exp.09/30/20211