St. Joseph County Housing Consortium

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VIII. Award Monitoring Subrecipients are expected to make available all participant level, financial and program records for periodic review on a schedule to be established by the City. In addition, subrecipients will maintain participant files in compliance with the standard set by the City. Significant deficiencies in file content or quality will result in required Plans of Corrective Action,with possible loss of funds upon discovery of continuing deficiencies. Program compliance and HMIS usage and data integrity will also be subject to regular and random monitoring by the City staff.Monitoring of subrecipients may be conducted by the City, local HUD Office of Community Planning and Development, HUD's Office of Special Needs Assistance Programs, HUD's Office of Inspector General, HUD's Office of Fair Housing and Equal Opportunity, or another Federal agency to determine whether the subrecipient complied with the requirements of this program. Each subrecipient that will be subject to on-site or remote monitoring by the City will receive at least 5 days notification prior to the visit confirming the date and time of the monitoring and a monitoring checklist. The checklist contains a list of areas that will be reviewed and documents that will need to be made available at the time of monitoring. Upon completion of the review,the City will send a letter detailing all concerns and findings discovered during the monitoring visit. The letter will be sent within 30 days of the monitoring visit unless an investigation of findings requires more time. If there are findings or concerns discovered,the letter will request the agency to submit a specific resolution or correction within a certain period of time. Additionally, the City staff may be available throughout the program year to conduct interim monitoring to help new subrecipients or agencies with new staff ensure continued compliance with the ESG program. Please contact the City staff to schedule an interim monitoring or Technical Assistance visit. The City is responsible for ensuring that the ESG requirements are met. The City will maintain staff that will be responsible for continuous monitoring of all ESG agency activities. The City will desktop-monitor subrecipients multiple times throughout the year by reviewing each claim for reimbursement that is submitted by the subrecipients. The City will conduct site visits to agencies and review of grant activities and reports. On-site monitoring will be conducted a minimum of every two years to review subrecipients' internal systems and ensure compliance with applicable requirements. Any new City of South Bend - ESG Policies and Procedures Manual 43