Finding: Subrreceipient Monitoring Assistance Listing Number: 10.698 - State and Private Forestry Cooperative Fire Assistance Cause: Management indicated that documentation supporting completion of monitoring activities and related communications could not be located due to turnover of personnel res...
Finding: Subrreceipient Monitoring Assistance Listing Number: 10.698 - State and Private Forestry Cooperative Fire Assistance Cause: Management indicated that documentation supporting completion of monitoring activities and related communications could not be located due to turnover of personnel responsible for administering and documenting subrecipient monitoring procedures. Auditor Recommendation: We recommend management strengthen procedures for retaining subrecipient monitoring documentation and establish controls to ensure monitoring activities are consistently documented and maintained, including during personnel transitions. Management's Views: Management agrees with the finding and has implemented the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Jessica Martinez, Deputy Director Julia Marsili, Associate Director, Wildfire Programs & Grants Contact Person: Jessica Martinez Corrective Action Taken: California Fire Safe Council (CFSC) agrees with the finding and recommendation. Since the audit period, CFSC has significantly strengthened its organizational structure, subrecipient monitoring and compliance procedures, and the documentation and retention of monitoring activities. CFSC began increasing management capacity within its Programs and Grants team in 2025 through the addition of two dedicated Program Manager positions, hired in June and July 2025. One Program Manager provides oversight of federal and private grant programs, while the other is responsible for the oversight of state-funded grant programs. These positions increased management-level capacity for programmatic oversight, grant administration, compliance and subrecipient monitoring. In July 2025, all CFSC grant staff participated in a Subrecipient Monitoring Training, which reinforced subrecipient monitoring best practices, required forms, documentation standards, and file retention requirements. CFSC also built and adopted a Grants and Programs System (GAPS) subgrant monitoring tool in August 2026. This tool allows grant staff to track all communication touchpoints with subrecipients and receive automated reminders for monitoring actions and deadlines for subrecipient requests. CFSC’s Subrecipient Monitoring policy establishes formal responsibility and procedures for subrecipient monitoring, including pre-award risk assessment, ongoing review of programmatic and financial performance, review of required reports and deliverables, expense to budget monitoring, documentation of monitoring activities, and follow up on identified compliance concerns. CFSC has also implemented standardized controls to support these monitoring procedures. The Subrecipient Invoice Review Checklist requires grant staff to review relevant risk assessment and monitoring information prior to processing payment; verify the subaward period of performance and available funding; review expenditures against the approved budget; verify indirect costs, cost share, and supporting documentation; assess whether expenditures are reasonable and consistent with program activities; and hold payment and seek management direction when information is insufficient. CFSC’s Subaward Agreement Policy & Procedures further requires subaward agreements to establish applicable reporting requirements, performance monitoring expectations, compliance requirements, and audit requirements at the outset of each subaward. In September 2026, CFSC further strengthened the Programs and Grants organizational structure by elevating the senior grants leadership (formerly the Senior Wildfire Programs & Grants Manager) to the Associate Director level and assigning Program Managers formal supervisory responsibility for Grants staff. These changes provide clearer accountability and increased management capacity for ensuring required subrecipient monitoring activities are completed, appropriately documented, reviewed, and maintained within organizational grant records. CFSC has also strengthened its compliance and monitoring protocols and documentation practices, as described in CFSC’s Subrecipient Monitoring Policy, last updated in September 2025. Subrecipient monitoring documentation and related communications are maintained within CFSC's organizational grant records in SharePoint file and within each subrecipient’s profile within ZoomGrants. This reduces reliance on individual staff’s records or institutional knowledge. Together, these changes provide greater continuity, oversight, and accountability and help ensure that required monitoring documentation remains complete and accessible during personnel transitions. Additionally, records are retained in accordance with CFSC’s Records Retention, Access and Privacy Policy, which establishes records-retention requirements applicable to CFSC’s finance and program records and includes specific requirements governing federal awards and subrecipient records. CFSC retains financial records, supporting documentation, program documents, and other records pertinent to federal grant awards for the required retention period of at least three years following the date of submission of CFSC’s final financial report for any particular grant, or longer when required to due audits, claims, litigation, award requirements, or other applicable Exceptions. CFSC believes these actions address the condition and underlying cause identified in Finding 2025-001 by strengthening management oversight and accountability, formalizing subrecipient monitoring training and tools, and reducing reliance on individual staff members for institutional knowledge and recordkeeping. Corrective Action Status: Implemented Completion Date: September 2026