Finding Text
Finding Type:
Compliance – Subrecipient Monitoring
Information on the Federal Program:
Program Name: Continuum of Care Program
Federal Awards: VT0081Y1T002102, VT0082Y1T002102, VT0083Y1T002102, VT0084Y1T002102,
VT0085Y1T002102
Federal Agency: U.S. Department of Housing and Urban Development
Criteria:
Elevate Youth Services, Inc. has the responsibility to monitor the programmatic and financial
components of any Federal grant funds that it passes through to another organization. Monitoring
activities include and are not limited to the following:
1) Establishing formal policies and procedures regarding Elevate’s approach to subrecipient
monitoring and creating tools to track and document subrecipient programmatic and financial
performance under the award.
2) Performing risk assessments of subrecipients throughout the year to identify areas of risk or
identify changes with subrecipients that could trigger compliance risks.
3) Review of programmatic and financial activities related to the awards through site visits or
desk review.
4) Formal communication to subrecipients as it relates to the results of site visits or desk
reviews and the process for necessary corrective action, when necessary.
Condition Found and Context:
Elevate did not perform complete subrecipient site visits or desk reviews at either the programmatic
and financial performance level during the year under audit, however the program staff developed its
approach to site visits and created tools to initiate site visits. One site visit occurred on June 29, 2023
and the remaining were done in July 2023. While the initial work was performed, the results of the
visits have not been formally documented or communicated to the subgrantees or to Elevate’s
management.
Cause and Effect:
Elevate experienced significant staffing challenges in managing this award from the program’s
inception. While Elevate has a long experience of providing subgrants to partner organizations, the
personnel responsible for the management of this program turned over frequently enough that a
formal and consistent practice of subrecipient monitoring has not been able to be established.
This result of not performing consistent site visits and monitoring, and formally communicating the
results can result in delays in identifying noncompliance, or not identifying noncompliance at all.
Questioned Costs:
None
Repeat Finding:
No
Recommendation:
Management should prioritize the completion in formalizing its policies and procedures as it relates to
subrecipient monitoring for this program and these procedures should be consistent with other
organizational monitoring programs. These procedures should include the process in which results
will be communicated with the subgrantees and internally.
Elevate must also complete its documentation on the site visits completed and communicate the
results of the visits as soon as possible.
Views of Responsible Official and Corrective Action Plan
Management acknowledges and understands this finding. A response to the finding is noted in the
Corrective Action Plan on pages 24 - 25.