Policy – Subgrantee Monitoring

The Corps Network (TCN) recognizes and accepts responsibility to provide oversight to its AmeriCorps Subgrantees and monitoring is an essential ingredient of carrying out that responsibility. It is the policy of The Corps Network to provide monitoring that is guided by careful analysis of risk associated with each Subgrantee.

The purpose of monitoring Subgrantees is twofold:

To ensure compliance with the legal and funding requirements of AmeriCorps , the Agency and The Corps Network; and
To stimulate continuous improvement of program quality.

TCN utilizes a variety of monitoring processes and tools to conduct programmatic oversight of its Subgrantees. The processes listed below include the different programmatic monitoring options that TCN staff may use to monitor its Subgrantees. Some elements are required for all Subgrantees, while other components may be used for others depending on type of grant, identified problem areas, scope, and/or risk factors.

Subgrantee Monitoring

The Corps Network will monitor all Subgrantees through the following processes:

Program document review
AmeriCorps Progress Report (APR) review (mid‐year)
FFR (financial) review for funded Subgrantees (mid‐year)
APR review (year‐end)
FFR review for funded Subgrantees (year‐end)

Additionally, TCN may monitor Subgrantees through the following processes:

Site visits
Desk Audits
Member and Host Site interviews
Random Sampling (member files to ensure compliance with eligibility, Criminal History Checks, etc.)

PROCESS	COMPONENTS	WHO RECEIVES IT
Program Document Review And Interview	Ensure that the Subgrantee has compliant member documents including member service agreements and position description	REQUIRED All funded Subgrantees receive a Program Document Review over the three‐year grant cycle EAP Subgrantees assessed and schedule determined during the grant cycle
AmeriCorps Progress Report (APR) REVIEW (Mid‐ year)	Review progress to date on performance measures Review member enrollment and retention rate to date Review member enrollment and exit approval cycle times Review and discuss any programmatic challenges and successes	REQUIRED All Subgrantees are required to submit an APR at the end of April for Oct 1 – March 31
APR Review (Year End/Final)	Review final data on performance measures (met/unmet targets) Review final member enrollment and retention rate Review member enrollment and exit approval cycle times Review training and development activities Review program accomplishments, challenges, community partnerships, as applicable Review Impact Snapshots Review and discuss any programmatic challenges and successes	REQUIRED All Subgrantees are required to submit an APR at the end of October for the full program year October 1 – September 30
Member And Host/service Site Interviews	Member and Host Site interviews may take place as part of an on‐site visit or via phone or a combination Member and host site interviews are conducted by TCN staff using a specific Program Monitoring Tool (based on CNCS example). Subgrantees will receive a copy of this tool in advance of a site visit. Members and site(s) are selected based on availability Member and host site interview questions may be general or targeted dependent on scope and reasons for the interviews (i.e. part of a routine site visit vs. responding to a member complaint) reasons for the interviews (i.e. part of a routine site visit vs. responding to a member complaint)	Member and Host Site* interviews will take place during scheduled on‐site visits *if applicable and accessible during the visit
Site Visits	Pre‐visit questions and documents may be requested of the Subgrantee including Policies and Procedures documents Pre‐visit‐TCN sends Monitoring Tool to Subgrantee for completion of designated sections. Subgrantees returns document to TCN to be discussed during actual visit Staff interviews to understand systems and other issues as applicable to the grantee Includes Member File Review to check for compliance (Eligibility, Criminal History Checks, timesheets, evaluations, etc.) Member and host site interviews (see above) Specific issue investigation (as applicable) Site visits may also be conducted remotely through a desk audit	All funded Subgrantees will receive an on‐site visit during the 3‐year grant cycle. If a Subgrantee is in multiple TCN grants, all grants are subject to review. At least 3 EAP site visits will be conducted annually. Others may monitored remotely through desk audits.
Random Sampling	Staff may use any of the above processes to conduct testing on Subgrantees Examples include – sampling member position descriptions, member eligibility documentation, criminal history check documentation, etc. The random sampling can be completed on-site or via desk-based methods	Any funded Subgrantees not receiving an audit in a particular program year may be required to submit samples of member files for review.

Site Visits/Desk Audits

All Subgrantees in funded grants will receive an on‐site visit at least once during the 3‐year grant cycle. If a Subgrantee is involved in multiple TCN grants, all grant program files will be audited on‐site.

EAP only programs also may be monitored remotely through desk audits. EAP sites are chosen for site visits and desk audits based on the date of their last audit and level of compliance throughout the year. Those showing the most risk will be audited first.

Prior to the TCN in‐person Site Visit or Desk Audit:

TCN will send the Subgrantee an email outlining the visit protocol and timeline. Subgrantee should pull the requested documents for the in‐person visit or mail them to TCN one‐two weeks prior to a “desk audit”. These include but are not limited to:

Site Agreement with The Corps Network (we need to see your copy but do not need to take it back with us from a site visit as we have our copy on file)
Full Members Files for specified members – all member files must include all documents noted on the Member File Checklist (Member Service Agreement, Position Description, Timesheets, etc.)
Organizational Chart
Member Disciplinary Action Policy
Member and Staff Handbooks
Staff Timesheets and other financials (not required for EAP)

During the Site Visit

In Person – The Corps Network staff will:

Tour the Corps facility
Speak with the A*C Program Administrator, staff responsible for eGrants and other appropriate staff
Visit crews and speak with Supervisors and Members (and Host Sites if applicable)
Discuss any compliance issues regarding program management with appropriate staff

Check Individual Member Files – names of members will not be provided in advance so make sure all required documents are in the individual member files and compliant. If criminal history check results are kept in a different location have those available as well.

Feedback and Follow‐up

Within 30 days of the visit, The Corps Network staff conducting the visit will send a letter to the Subgrantee identifying any compliance issues and suggest ways to remedy them. Subgrantees will then have 30 days to respond to the visit/audit feedback and submit any missing items or revised materials/documents as noted in the letter.

Note: Subgrantees should conduct their own document/file reviews throughout the program year to ensure compliance. Self‐reporting any Criminal History Check findings to TCN in advance of a site visit/desk audit will result in a lower disallowance cost. Once a Subgrantee is notified of an upcoming visit/audit, reporting non‐compliance is no longer considered “self‐reporting”.

AmeriCorps Monitoring

AmeriCorps, the Agency regularly conducts a sampling of participant information for validation purposes related to agency Trust obligations and liabilities. The information will be used for the required Trust susceptibility analysis under the Payment Integrity Information Act of 2019. Generally only a few members from EAP and OYSI will be randomly selected for this review One or more of your participants has been randomly selected for this review.

The Office of Monitoring and/or the Office of Inspector General (OIG) also audits grantees each year so always be prepared to submit all requested programmatic, financial and member records upon request. They may accompany TCN staff on site visits. TCN staff will contact Subgrantees in advance regarding any visits or desk audits/requests for files.