Transcript Monitoring - Texas A&M University

Monitoring & Oversight
Adult Education and Literacy (AEL) Programs
Brenda B. Williams
Project Manager
Texas Workforce Commission
Regulatory Integrity Division
Sub-recipient Monitoring
October 9, 2014
Authority
• Monitoring by TWC and the Grant recipient are a
requirement of the contract as noted in Section13:
o §13.3 The Grantee shall develop and maintain a Subcontractor
monitoring Center, acceptable to the Agency, covering any subcontract it awards from this grant award…
o §13.4 …The Agency retains the right to perform such monitoring
an evaluation studies that it determines necessary and will report
preliminary results to the Grantee and any Subcontractor before
the monitoring and evaluation is concluded and the final results
are made a matter of record.
Risk Assessment
• Before an entity is selected for a monitoring review
a risk assessment is conducted with input from the
AEL department.
• Project Managers (PM) are notified of the entities
selected. (usually occurs at the beginning of the
fiscal year and at the mid point).
• In FY15, 10 on-site reviews and 20 desk audits will be
conducted.
Selecting the Review Date
• The contact person listed on the contract is notified
of the potential dates for the monitoring review by
the PM.
• Once a date is selected, an Engagement Letter is
emailed to the contact. (Approximately 13 weeks
prior to the review)
• The Engagement Letter attachment should be
signed as acceptance of the dates and returned to
the PM.
Planning for the Review
• A preplanning meeting is held between the
monitoring team, contract manager, AEL and other
pertinent staff to share information and identify
concerns.
• Information obtained assists in identifying the
documents to be requested.
Document Request
• A document request letter is emailed approximately
8 weeks prior to the review (when possible).
• The document request letter will include the
contracts being monitored and the Project
Manager’s name and phone number.
• Date the documentation should be submitted.
• Format to submit documents.
Documents to be submitted:
Organization chart
Contracts, Non Financial Agreements and MOUs
Cost Allocation Plan/Indirect Cost Rate
General ledger and Check register for the review
scope
• Chart of Accounts with descriptions
• Property inventory report relating to the respective
contract with TWC (most current)
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Documents to be submitted:
• Formal procurements over $150k, sole source and
non- competitive procurements
• List of Bank Accounts, Bank Statements, Bank
Reconciliations and trial balances during the scope
• Monitoring reports, schedules and risk assessments
(if applicable)
Policies and Procedures
• Copies should be submitted in electronic format
where available for the following:
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Accounting/Budget
Financial Reporting
Determining Cash Needs
Personnel/Human Resources
Travel
Property
Procurement
Automation-Internal Controls
Personally Identifiable Information
(include controls for security of
physical & electronic data)
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Monitoring and Oversight
Contract Management
Fraud
Conflict of Interest
Service Delivery
Reporting/Performance Measures
Program Eligibility
Tracking Contract Deliverables
*Does not include all program information.
Desk Review
• Once the Document Request Packet (DRP) is
received the team will review the information during
the desk review and determine the level of risk for
the on-site visit.
• Any area of testing that can be completed during
the desk review will be conducted.
• Areas that require testing on-site or additional
follow-up will be brought to the field .
Desk Review – cont.
• One week prior to the review the PM will make
contact to finalize the entrance time and date.
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The PM will also notify the contact of any special
equipment or access needed while on-site.
• A list of documents/transactions to be tested on-site
will be sent two-three business days prior to the
entrance. (documents requested should be
available when the team arrives.)
Entrance Conference
• During the entrance the team will inform the
contractor of the areas to be reviewed and a
potential exit date and time.
• Contacts will be identified for both the contractor
and the monitoring team.
Field Review
• The PM establishes a time frame for reporting
information to the contact and/or Executive.
• Processes will be gathered and interviews
conducted while on-site.
• Potential issues will be discussed while on-site in
order to ensure understanding.
• A debriefing will be conducted with the Executive
or designee prior to the Exit.
Fiscal Testing Areas
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Disbursements
Cost Allocation/Indirect Rate
Cash Management
Financial Reporting
Procurements
Property
Disbursements Testing
• Costs incurred will be tested in compliance
with Financial Manual for Grants and Contracts
(FMGC) and relevant OMB Circulars.
• Attributes to be tested for the transactions
include:
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Allowable
Reasonable and Necessary
Adequately Documented
Correctly Allocated
Properly Classified and Recorded
Cost Allocation
Plan/Indirect Rate
• Review current dated copy of approved cost
allocation and/or indirect cost rate plan.
• Review the policy and procedures for how the
plan is developed and approved.
Cash Management Testing
• Review Cash Forecasting policies and
procedures. Walk through of cash forecasting
process.
• Review bank reconciliations including bank
statements, adjusting items and trial balances.
• Review any discrepancies between cash drawn
and expenditures reported.
• Compare cash drawn and cash on hand.
(Process for calculating the 3 day cash on hand)
Financial Reporting
• Trace expenditures reported in CDER to the
general ledger.
• Review accruals, obligations and unpaid
liabilities, if applicable.
Procurements
• Review competitive procurements over $150k, as
well, as any non-competitive or sole source
procurements.
• Micro purchases above $3k but less than $150k
threshold amount.
Property
• Review policy and procedures for tracking
computers and equipment purchased with grant
funds.
• Review property inventory report of any
equipment purchased with grant funds.
• Test a sample of property listed in the report during
an inventory walk through to test property controls
in place.
Security of Data
• Review policies and procedures in place for
securing data.
• Interview staff to document process.
• Review controls in place for securing both hard
copy and electronic documentation.
• Walk through of the facility where Personally
Identifiable Information (PII) is maintained.
Exit Conference
• An exit conference will be held to discuss potential
findings and/or observations.
• Issues that are resolved on-site will be listed on the
supplemental report.
• If additional issues are determined after the team
leaves the site the PM will contact the Executive.
After the Field Review
• Work papers will be completed once the team
returns to the office.
• Additional documentation to resolve issues must be
submitted within the time frame the PM indicates.
• Completed workpapers are submitted to the Field
Director for review and comments.
Draft Reports
• A “Draft report” is issued 7 weeks after the on-site
review.
• The Contractor will have 15 days from the date of
the transmittal to respond and concur or not concur
with the findings identified in the report.
• After the draft is returned it will be reviewed to
determine if it addresses the finding. The PM will
contact the Contractor, if clarification is needed.
Final Report
• The final report includes issues identified on-site that
remain unresolved after the draft report.
• The report also includes Contractor comments.
• If additional actions are required Audit Resolution
will work with the Contractor from that point
forward.
Questions