Management's Response
The Management of Elevate Youth Services (EYS) acknowledges the importance of subrecipient
monitoring in accordance with program compliance regulations set forth in our grant agreements
with the U.S. Department of Housing and Urban Development (HUD). EYS further acknowledges
th...
Management's Response
The Management of Elevate Youth Services (EYS) acknowledges the importance of subrecipient
monitoring in accordance with program compliance regulations set forth in our grant agreements
with the U.S. Department of Housing and Urban Development (HUD). EYS further acknowledges
the compliance findings of Davis & Hodgdon Associates CPAs as detailed in Elevate's FY23
financial audit that subrecipient monitoring did not occur within the VCRHYP HUD Project as
required during the year under audit. The following context for, and plan to address, findings are
offered by management.
Context: As EYS continued to see the impact of the changes in the labor market stemming from
the pandemic, the VCRHYP team experienced ongoing turnover and subsequent slow hiring to
fill vacant positions. The resultant impact was a delay in the implementation of key
programmatic responsibilities - primarily subcontract recipient monitoring.
Toward the end of the FY22 audit year, a new VCRHYP Director was hired. Early work included
the codification of new program approaches and policies and the development of a preliminary
program monitoring tool. Additionally, the agency submitted a new technical assistance request
to HUD in January of 2023, to support the new staffing. A new TA provider was assigned to us in
February of 2024. While waiting for additional technical assistance, the VCRHYP team began
monitoring the existing programs.
Notifications of monitoring visits were sent out June 5th, 2023 and 7 out of 8 subrecipient
programs were visited by the end of July. The final site visit was delayed due to catastrophic
flooding witnessed by the State of VT on July 13th, 2023. Final reports generated by these site
visits has been delayed. However, VCRHYP staff will be preparing monitoring reports from those
visits and, further, will be iterating on current monitoring tools with the expectation that current
VCRHYP staffing will allow for annual monitoring visits per HU D's expectations, moving forward.
While we expect this tool to be further modified with input from our TA provider, VCRHYP's
current monitoring tool for the HUD projects includes:
• VCRHYP Client Checklist - This checklist is used by the VCRHYP Team during each site
monitoring visit to ensure compliance with HUD Program guidelines for: Housing
Navigation, Diversion, Joint: Transitional Housing Component, Joint: Rapid Rehousing
Component, and Rapid Rehousing. The VCRHYP client checklist also include clients served
by subgrantees under the Basic Center and Transitional Living Programs funding from the
Family and Youth Service Bureau.
• HR File Review - Personnel File Survey is used for VCRHYP's YHDP site monitoring to
ensure that staff are hired within the HUD guidelines and that items including background
checks, job description, hiring documentation and and performance evaluations are
included in employee personnel files.
• HUD Monitoring Exhibits 29-1 Guide for Review of Homeless and At-Risk
Determination/Recordkeeping Requirements, HUD Exhibit 29-4 Guide for Review of
Continuum of Care(CoC) Program Subrecipient Grant Management, and HUD Exhibit 29-
11 Guide for Review of CoC Match Requirements are also standard monitoring tools used
during site visits to ensure the Subrecipient is providing services to participants that meet
HUD's homelessness definition; to determine that the management of program is
maintained; and to ensure that the required expenditure match is being met in
accordance with the HUD's guidelines.
Ongoing mitigation:
Currently, the VCRHYP Program Director has a cohesive team. The VCRHYP Director is meeting
regularly with our assigned TA on a variety of program and procedural approaches to ensure that
ongoing compliance issues are being addressed. We anticipate having a new year of monitoring
visits initiated during the summer of 2024. All monitoring visits conducted in that time period
will be informed by TA support and will be accompanied by a written report shared with EYS
leadership and the subrecipient being monitored.
In addition to programmatic monitoring, EYS Management will develop protocols to include a
random desk audit of subrecipient financials to accompany the ongoing financial monitoring
currently occurring through the collection and analysis of submitted invoices. This financial
monitoring will be included in the program monitoring scheduled for the summer of 2024.
Elevate Youth Service's Data and Quality Assurance Manager will develop a tracking tool in the
agency's data system to record the status of individual subrecipient monitoring.
EYS acknowledges the challenging impact of staff shortages on program compliance. However,
we do feel that the staffing and support from HUD is already in place to ensure that we will be
able to bring this element of program compliance into regular conformity with expectations by
the end of the ist quarter of FY24.