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3.3 — Keeping Accurate Financial and Service <br /> Delivery Records <br /> Maintaining accurate records is an important aspect of management of ESG projects. <br /> Measurement of project performance relies on the tracking of information about services <br /> and activities. Sufficient records must be established and maintained to enable the <br /> subrecipient to show that ESG requirements are being met.Therefore, it is important that <br /> accurate information and documentation regarding program activities and services <br /> provided with ESG funds is gathered and maintained. The City requires consistent <br /> reporting on expenditure of funds, program activities, and measurable outcomes. In order <br /> to report fully on program outcomes and activities, subrecipients should consistently <br /> gather demographic information on the population being served by the ESG program and <br /> consistently report the types of activities being provided to participants. <br /> Subrecipients that utilize ESG funds under the Essential Services category for Case <br /> Management activities are required to enter all relevant client-level data including case <br /> notes into HMIS or DV Client Track(if it is a victim services provider) on a consistent basis. <br /> ESG regulations require that records be maintained for a period of at least five years after <br /> the end of the grant term. <br /> Subrecipients must have policies and procedures to ensure the requirements are met.The <br /> policies and procedures must be established in writing and implemented by the recipient <br /> and its subrecipients to ensure that ESG funds are used in accordance with the <br /> requirements. In addition,sufficient records must be established and maintained to enable <br /> the recipient and HUD to determine whether the following ESG requirements are being <br /> met. <br /> Examples of sufficient record keeping documents: <br /> r Homeless status -Faith-based activities <br /> ➢ Determination of ineligibility -Other Federal requirements <br /> y Annual income - Financial records <br /> y Program participant records -Contractors <br /> y Centralized or coordinated assessment -Matching <br /> systems and procedures - HMIS <br /> , Rental assistance agreements and payments -Homeless Participation <br /> y Utility allowance -Conflicts of interest <br /> y Habitability form - Lead safe housing <br /> r> Emergency shelter facilities - Rent reasonableness <br /> r• Coordination with the Continuum of Care and <br /> other programs <br /> City of South Bend - ESG Policies and Procedures Manual 8 <br />