OCJP SUBRECIPIENT MONITORING
OCJP has the responsibility to assure that subrecipients funded with state and federal grant dollars are in compliance with state and federal grant and policy requirements. In an effort to determine compliance, OCJP has entered into an agreement with the Department of Finance and Administration, Office of Program Accountability Review (PAR) to provide a coordinated state monitoring approach in accordance with the Department of Finance and Administration’s Policy 22. Policy 22 establishes:
v A coordinated and centralized monitoring system for the State of Tennessee that defines subrecipient monitoring and the required core monitoring areas.
v Ensures monitoring of all State of Tennessee subrecipients, and
v Eliminates duplication of monitoring efforts.
1. The Office of Program Accountability Review provides monitoring services to:
a. Determine subrecipient compliance with the requirements of state and/or federal programs, applicable laws and regulations and stated results and outcomes.
b. Ascertain if internal control over financial management and accounting systems are adequate to account for program funds in accordance with state and federal requirements.
2. Subrecipient Agency Preparation for a Monitoring Visit:
a. OCJP subrecipients can expect at least one monitoring visit by the Office of Program Accountability Review (PAR) during every three-year grant contract period (some subrecipients will be monitored annually).
b. Subrecipient agencies are selected for monitoring based on their level of risk as determined by OCJP. Number of grants received from OCJP, amount of funding received, and previous areas of concern are risk factors in determining an agency’s level of risk. Based on the level of risk a subrecipient is assigned, monitoring can occur more than one time during any three-year contract period.
c. Prior to an on-site monitoring visit, subrecipients will receive notification from PAR detailing the date and time of the monitoring visit in addition to what information will be requested.
3. Disposition:
At the conclusion of the monitoring on-site visit, a monitoring report will be issued by Program Accountability Review (PAR) within fourteen (14) working days. The report will be issued to the subrecipient as well as to OCJP and other state agencies. This PAR report must be maintained on-site by the subrecipient as part of the subrecipient file.
Subrecipient Monitoring Reports may include three possible results: (a) No findings of Noncompliance, (b) Findings of Noncompliance, and/or (c) Observations.
a. No findings of Noncompliance: PAR does not identify and area(s), either programmatic of fiscal, that do not comply with specific criteria found in state or federal statutes, rules, and/or regulations, OCJP subrecipient contract(s), state departmental policy for the subrecipient program, or a good business practice.
1. If the PAR monitoring review results in no findings of noncompliance, no further action from the subrecipient is needed.
2. OCJP will follow up with a letter to the subrecipient recognizing that the report was indeed received and no findings were identified.
b. Findings of Noncompliance: Par identifies an area(s) that does not comply with specific criteria found in state or federal statutes, rules and/or regulations, OCJP subrecipient grant contract, state departmental policy for subrecipient programs, or good business practice.
1. If the PAR monitoring review identifies findings of noncompliance, the subrecipient will be allowed thirty (30) days from the issued date of the report to submit a corrective action plan to the Office of Criminal Justice Programs outlining how the agency plans to correct the findings.
2. The Corrective Action Plan should include: that
a. A statement of whether the subrecipient agency agrees with the finding or not.
b. A detailed plan of how the agency will correct each individual finding or justification for the subrecipient’s disagreement with the finding(s).
c. Attachment of any subrecipient documents, forms, policy changes, reports, accounting tools, time sheets, data collection forms, etc. that ensures the subrecipient has corrected the finding(s).
d. If the subrecipient disagrees with a finding(s) identified by PAR, detailed documentation must also be submitted to refute the questioned finding(s).
c. Observations: An observation does not generally result from noncompliance as a finding, but rather is a situation observed by a PAR monitor that is deemed to be a potential problem or of interest to the grantor agency, and therefore is reported.
1. If a PAR monitoring review identifies an observation, the subrecipient will be allowed thirty (30) days from the issued date of the report to submit a response explaining the observation and outlining how the agency plans to correct the observation.
2. The Observation Report should include:
a. A statement of whether the subrecipient agency agrees with the observation or not.
b. A detailed statement of how the agency will address each individual observation, if needed.
c. Attachment of any subrecipient documents, forms, policy changes, reports, accounting tools, time sheets, data collection forms, etc. that ensures the subrecipient has corrected the observation if needed.
d. If the subrecipient disagrees with an observation(s) identified by PAR, detailed documentation must be submitted to refute the questioned observation(s).
3. Corrective Action Plans and Observation Reports can be combined and submitted as one document.
4. Corrective Action Plans and/or Observation Reports should be submitted to:
Patricia Dishman, Director
Office of Criminal Justice Programs
312 8th Avenue North, Suite 1200
William R. Snodgrass Tennessee Tower
Nashville, TN 37243-1700
They should be submitted no later than 30 days after the date of the PAR Subrecipient Report.
5. OCJP Response:
a. Upon receipt of a Corrective Action Plan or Observation Report, OCJP will review and determine its adequacy. If found adequate, OCJP will issue a letter of approval. In the event concerns remain, OCJP will determine what additional steps are needed and relate those requirements to the subrecipient in writing with an expected date of response by the subrecipient.
b. All correspondence from OCJP to the subrecipient regarding the PAR report and subrecipient responses must be maintained on site by the subrecipient as part of the subrecipient file.
VOCA Administrative Manual 08/01