Overview of Comprehensive Monitoring

Monitoring provides the U.S. Department of Education (Department) an opportunity to identify effective practices and fulfill its role as an advisor and partner by providing technical assistance on grant administration issues and challenges. It is done to assess grantees' performance outcomes and ensure the Department meets its fiduciary responsibility to hold grantees accountable for Federal funds through risk-based monitoring strategies that ensure that grantees have the capacity to manage grant funds consistent with Federal requirements.

Monitoring evaluates the administration and financial processes of Federal grants to ensure compliance with all programmatic requirements and related regulations. The goal of effective monitoring is to build evidence about effective approaches, establish productive relationships with grantees that support results- oriented approaches to program management that demonstrate excellence, accountability, and successful performance outcomes. Effective monitoring also identifies potential or actual weaknesses and helps to find constructive ways to address those weaknesses and bring grantees into compliance.

Purpose of Monitoring

Monitoring is intended to ensure that grantees are meeting the goals and objectives established in their approved grant applications and complying with statutory and regulatory requirements. Active discretionary grants are monitored with a focus on technical assistance (TA), continuous improvement, and attaining promised results. In addition, Department program offices monitor for protection against waste, fraud, and abuse.

The purpose of monitoring for the Comprehensive Literacy State Development (CLSD) program is to ensure that implementation of the project is consistent with the program's authorizing legislation, sections 2221–2224 and 2301 of Elementary and Secondary Education Act, as amended (ESEA). Monitoring also ensures compliance with applicable regulations including the Education Department General Administrative Requirements (EDGAR) and the fiscal and administrative requirements contained in the Office of Management and Budget (OMB) Guidance for Federal Financial Assistance in 2 CFR part 200.

In addition, CLSD program monitoring helps the Department to identify grantees' promising or outstanding practices and innovative tools or techniques that improve student outcomes, and help them meet their goals, objectives, and performance measures.

Monitoring Process

The following steps provide a general overview of the monitoring process. Specific dates and activities will be determined in collaboration with your program officer.

• Step 1 — Notification Letter — This communication will be sent via G5 to both the project director and authorized representative on the grant. The notification will be sent approximately four months prior to the proposed monitoring dates.
• Step 2 — Pre-planning Meeting — This meeting will be held to review the key parts of monitoring including a review of the monitoring indicators, overview of how to complete the document inventory and analysis, types of acceptable documentation, discussion of key personnel involved in preparation and execution of monitoring presentations, and proposed schedule.
• Step 3 — Submission of the Document Inventory and Analysis (DIA) — The completed DIA will be submitted to your program officer by the agreed upon deadline. ED staff will review it to determine if the proposed documentation is aligned with the indicator. A follow-up call may be scheduled to provide clarification around any outstanding information.
• Step 4 — Submission of Documentation — Once the DIA is approved, documentation will be submitted by the agreed upon deadline, generally 60 days prior to the scheduled monitoring.
• Step 5 — Review of Documentation — ED staff will review the submitted documentation to determine if it sufficiently meets the indicator(s). If necessary, additional documentation may be submitted.
• Step 6 — Pre-monitoring Meeting — A final preparatory meeting will be held. The purpose of this meeting is to discuss the logistics, finalize the monitoring schedule, and pose any additional questions related to the documentation.
• Step 7 — Monitoring Visit — The monitoring visit will take place over two days. The visit will consist of presentations from SEA staff aligned with the CLSD indicators. Following the presentations, time will be allotted for questions.
• Step 8 — Monitoring Report — Following the monitoring visit, program staff will draft a report summarizing how the grantee addressed each of the indicators. The draft will be shared with the grantee for feedback. Once feedback is received, the report will be finalized and shared via G5.

Monitoring Indicators

CLSD grantees will be monitored on the following indicators:

Indicator 1.1 The grantee awarded subgrants through a competitive process and in accordance with the statute.

• Sub-indicator 1.1a The grantee should provide evidence that shows that subgrants birth–kindergarten entry were awarded on a competitive basis.
• Sub-indicator 1.1b The grantee should provide evidence that shows that subgrants for K–5 and grades 6–12 were awarded on a competitive basis.

Indicator 1.2 The grantee has demonstrated that all subgrants were made to eligible entities as defined in statute.

• Sub-indicator 1.2a The grantee should provide evidence that it awarded subgrants to local educational agencies (LEAs) that serve a high percentage of high-need schools.
• Sub-indicator 1.2b The grantee should provide evidence that it awarded subgrants to early childhood programs serving low–income or otherwise disadvantaged children. The evidence should also show that the entity has a record of providing comprehensive literacy instruction.
• Sub-indicator 1.2 c If the grantee awarded subgrants to a consortium, the consortium should have provided evidence that it has a demonstrated record of effectiveness in improving literacy achievement of children from birth through grade 12 and providing professional development in comprehensive literacy instruction.

Indicator 1.3 The subgrant application process includes the requirements and priorities for subgrants.

• Sub-indicator 1.3a The grantee should provide evidence that the birth–kindergarten application process asked applicants to provide an analysis of data that support the proposed use of funds and explain how the funds would be used to enhance the language and literacy development and school readiness of children in this age band.
• Sub-indicator 1.3b The grantee should provide evidence that the birth–kindergarten entry application process requires applicants to explain how subgrant funds would be used to prepare and provide ongoing assistance to staff members through high–quality professional development.
• Sub-indicator 1.3c The grantee should provide evidence that the birth–kindergarten entry application process required applicants to explain how the activities would be coordinated with literacy instruction in K–12.
• Sub-indicator 1.3d The grantee should provide evidence that the birth–kindergarten entry application process required applicants to explain how the success of the activities would be evaluated.
• Sub-indicator 1.3e The grantee should provide evidence that shows how the application process for birth–K prioritized awarding grants to entities that would implement strong, moderate, or promising evidence-based activities.
• Sub-indicator 1.3f The grantee should provide evidence that shows how the application process for birth–k prioritized awarding grants to entities that serve children from birth through age 5 who are from families with income levels at or below 200 percent of the Federal poverty line.
• Sub-indicator 1.3g The grantee should provide evidence that K–12 application process required a description of the eligible entity's needs assessment.
• Sub-indicator 1.3h The grantee should provide evidence that the K–12 application process required a description of the eligible entity's ongoing high-quality professional development.
• Sub-indicator 1.3i The grantee should provide evidence that the K–12 application process required identification of children in need of interventions or support.
• Sub-indicator 1.3j The grantee should provide evidence that the K–12 application process required they describe how comprehensive literacy instruction will be integrated in the school(s) served.
• Sub-indicator 1.3k The grantee should provide evidence that the K–12 application process required the subgrantee to coordinate with early childhood and after-school programs in the area served by the subgrantee.
• Sub-indicator 1.3l The grantee should provide evidence that shows how the application process for K–12 prioritized awarding grants to entities serving grades K-5 or 6-12, or both, that would implement strong, moderate, or promising evidence-based activities.

Indicator 2.1 The SEA is making subgrants to early childhood entities in accordance with the statute.

• Sub-indicator 2.1a The grantee should provide evidence that the birth–K subgrant awards were no more than 5 years.
• Sub-indicator 2.1b The grantee should provide evidence that the birth–K subgrant award amounts were sufficient to carry out high-quality comprehensive literacy instruction for the children being served.
• Sub-indicator 2.1c The grantee should provide evidence that it has consulted with the agency responsible for administering early childhood education programs.
• Sub-indicator 2.1d The grantee should highlight where the following can be found in the requested subgrant applications: how the subgrant funds would be used to improve school readiness for birth–kindergarten entry (including an analysis of data that supports the use of subgrant funds); provide ongoing support to staff members; coordinate with K–12 on comprehensive literacy instruction; and how they will evaluate success of the activities in enhancing early language and literacy development.
• Sub-indicator 2.1e The grantee should provide evidence that the birth–K subgrantee selected for monitoring is implementing high-quality professional development, training staff members to administer evidence–based (strong, moderate, or promising) literacy initiatives, and coordinating literacy activities among families, staff members, principals, other school leaders, and teachers in literacy development of the children served by the subgrant.

Indicator 2.2 The SEA is making subgrants to eligible entities in support of K–12 literacy in accordance with the statute.

• Sub-indicator 2.2a The grantee should provide evidence that the subgrant awards were no more than 5 years.
• Sub-indicator 2.2b The grantee should provide evidence that the subgrant award amounts were of sufficient amounts to carry out high–quality comprehensive literacy instruction for each grade level being served by the grantee.
• Sub-indicator 2.2c The grantee should indicate, in the grades K–5 and 6–12 subgrant applications (that were submitted) where the following information can be found: each school to be served; a description of the needs assessment to guide how funds would be used to improve literacy instruction; how ongoing high–quality professional development would be provided to all staff members and administrators; how the school would identify children in need of literacy interventions or other supports; how the school would integrate comprehensive literacy instruction into a well–rounded education; and how the school would coordinate literacy instruction with early childhood education programs and after–school programs.
• Sub-indicator 2.2d The grantee should provide evidence that shows the k–5 subgrantees are developing and implementing comprehensive literacy instruction plans that serve all students and provide intensive interventions. The evidence should also show that subgrantees are training school staff members to support, develop, administer, and evaluate high-quality literacy instruction; providing time for teachers to meet to plan evidence-based literacy instruction; coordinating the involvement of early childhood educators in the literacy development of children; and engaging families and encouraging family literacy experiences.
• Sub-indicator 2.2e The grantee should provide evidence that shows the 6–12 subgrantees are developing and implementing comprehensive literacy instruction plans; training school staff members to support, develop, administer, and evaluate high–quality literacy instruction; assessing the quality of adolescent literacy instruction; providing time for teachers to meet to plan evidence-based adolescent literacy instruction; and coordinating the involvement of school staff members in the literacy development of children.

Indicator 2.3 The SEA has a process in place to assess subgrantee risk; a systematic monitoring process that assesses subgrantee progress in meeting programmatic components outlined in the subgrant application; a systematic monitoring process that assesses subgrantee financial procedures and use of funds; and subgrantee monitoring includes effective follow-up or corrective action plans for identified deficiencies.

• Indicator 2.3a The grantee should provide evidence of the risk-based process to select subgrantees to be monitored.
• Indicator 2.3b The grantee should provide evidence that shows they are monitoring select subgrantees for compliance and performance.
• Indicator 2.3c The grantee should provide evidence that subgrantees are monitored on their fiscal activities. The grantee should also provide evidence related to how subgrantee expenditures are reviewed and approved.
• Indicator 2.3d If applicable, the grantee should provide documentation for selected subgrantees showing any deficiencies identified and the corresponding corrective action plan(s).

Indicator 3.1 The SEA has either developed, is in the process of developing, revised, or in the process of revising its state literacy plan (SLP) and is implementing activities according to the implementation plan included in the approved application (or approved modifications).

• Sub-indicator 3.1a The grantee should provide evidence of the activities related to the status of the state literacy plan.
• Sub-indicator 3.1b The grantee should provide evidence related to the status of the activities listed in the implementation plan.

Indicator 3.2 The grantee complies with grant conditions and demonstrates adherence to restrictions (if applicable). The grantee works to resolve instances of noncompliance, including issues identified from prior monitoring. The grantee demonstrates an adequate system for maintaining all financial and programmatic records, including subgrantee and performance records.

• Sub-indicator 3.2a The grantee should provide evidence that it is meeting a specific condition or conditions. (This is only applicable if the grantee had a specific condition included in its GAN.)
• Sub-indicator 3.2b The grantee should provide documentation that it has requested, and received, prior approval for changes to key personnel.
• Sub-indicator 3.2c The grantee should provide evidence that it is addressing any issues of noncompliance and has remedied the issue(s) or is working toward remedying the issue(s). (This is only applicable if the Department has identified an area of CLSD noncompliance.)
• Sub-indicator 3.2d The grantee should provide evidence that it is tracking and maintaining records for: the amount of funds awarded under the grant; how the grantee uses the funds; the total cost of the project; the share of costs provided from other sources (if applicable); grant performance; and subgrantee records.

Indicator 3.3 The SEA ensures that Federal funds are allowable, allocable, reasonable, and expended within the period of availability. The SEA is on track to make subgrants to eligible entities in accordance with the required age/grade band allocations and the project budget reflects the grantee is on track to subgrant at least 95% of the total grant award. The grantee’s State-level activities do not exceed 5% of the total grant award and are allowable by statute. The grantee adheres to the supplement-not-supplant provision.

• Sub-indicator 3.3a The grantee–completed expenditure chart and attached documentation shows that expended grant funds are allowable, allocable, and reasonable under the program statute and expended within the period of availability.
• Sub-indicator 3.3b The grantee should provide evidence of how it is tracking the distribution of subgrant funds over the life of the grant. The grantee should also provide documentation around any changes in subgrantees that necessitated a redistribution of funds.
• Sub-indicator 3.3c The grantee should provide evidence that shows how it is tracking the funds over the life of the grant and shows that it is on–track to subgrant at least 95% of the funds.
• Sub-indicator 3.3d The grantee-completed expenditure chart and attached documentation should support that the SEA has allocated not more than 5% of grant funds for state-level activities aligned with the program statute.
• Sub-indicator 3.3e The grantee should provide evidence of the processes and procedures in place to ensure supplanting is not occurring. If applicable the grantee should also provide the supplement not supplant guidance shared with subrecipients for other Department funding — i.e. Title I, Title II, etc.

Indicator 3.4 The SEA administers the CLSD funds to ensure the proper disbursement, accounting, competitive bidding and contracting, and use of Federal funds. The grantee adheres to audit requirements, and any findings are resolved.

• Sub-indicator 3.4a The grantee provides evidence of the standard operating procedures related to the processes for approval and the drawing down of funds; manuals related to the process; the checks and balances used to approve payments and drawdowns; explanations and examples of the accounting system; and competitive contracting and bidding.
• Sub-indicator 3.4b If the grantee's most recent single audit has any key findings that would affect the CLSD project, the grantee should highlight those findings and provide evidence of how they are being addressed.

Resources

• Monitoring Handbook — coming soon
• Sample monitoring notification letter — coming soon
• Sample monitoring timeline — coming soon
• Sample monitoring schedule — coming soon
• Document Inventory and Analysis file — coming soon
• Sections 2221–2225 and 2301 of the Elementary and Secondary Education Act, as amended (ESEA)
• Education Department General Administrative Regulations (EDGAR)
• OMB Guidance for Federal Financial Assistance (2 CFR 200)

Subgrantee Administration and Oversight

CLSD grantees must subgrant, through a competitive process, at least 95% of the funds over the life of the grant. The OMB Guidance for Federal Financial Assistance, also known as 2 CFR 200, includes regulations related to the administration and oversight of subgrantees.

In 2 CFR § 200.331 and 2 CFR § 200.332 a pass-through entity (SEA) must:

(a) Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds.

(b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes:

• (1) Federal award identification.
  • (i) Subrecipient's name (must match the name associated with its unique entity identifier);
  • (ii) Subrecipient's unique entity identifier;
  • (iii) Federal Award Identification Number (FAIN);
  • (iv) Federal Award Date;
  • (v) Subaward Period of Performance Start and End Date;
  • (vi) Subaward Budget Period Start and End Date;
  • (vii) Amount of Federal Funds Obligated in the subaward;
  • (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation;
  • (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
  • (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA);
  • (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity;
  • (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement;
  • (xiii) Identification of whether the Federal award is for research and development; and
  • (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414).
• (2) All requirements of the subaward, including requirements imposed by Federal statutes, regulations, and the terms and conditions of the Federal award;
• (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency;
• (4) Indirect cost rate:
  • (i) An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. The indirect cost rate may be either:
    • (A) An indirect cost rate negotiated between the pass-through entity and the subrecipient. These rates may be based on a prior negotiated rate between a different pass-through entity and the subrecipient, in which case the pass-through entity is not required to collect information justifying the rate but may elect to do so; or
    • (B) The de minimis indirect cost rate.
  • (ii) The pass-through entity must not require the use of the de minimis indirect cost rate if the subrecipient has an approved indirect cost rate negotiated with the Federal Government. Subrecipients may elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d).
• (5) A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements; and
• (6) Appropriate terms and conditions concerning the closeout of the subaward.

Subgrantee Monitoring and Risk Assessment

The OMB Guidance for Federal Financial Assistance includes regulations related to risk assessment and monitoring. This information can be found in 2 CFR § 200.331 and 2 CFR 200.

A pass-through entity (SEA) must:

• (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following:
  • (1) The subrecipient's prior experience with the same or similar subawards;
  • (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program;
  • (3) Whether the subrecipient has new personnel or new or substantially changed systems; and
  • (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).
• (d) If appropriate, consider implementing specific conditions in a subaward as described in § 200.208 and notify the Federal agency of the specific conditions.
• (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must:
  • (1) Review financial and performance reports.
  • (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation.
  • (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521.
  • (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.
• (f) Depending upon the pass-through entity's assessment of the risk posed by the subrecipient (as described in paragraph (c) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:
  • (1) Providing subrecipients with training and technical assistance on program-related matters;
  • (2) Performing site visits to review the subrecipient's program operations; and
  • (3) Arranging for agreed-upon-procedures engagements as described in § 200.425.
• (g) Verify that a subrecipient is audited as required by subpart F of this part.
• (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records.
• (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations.

Subgrantee Closeout

The OMB Guidance for Federal Financial Assistance includes regulations related to subgrantee closeout. This information can be found in 2 CFR § 200.344.

• 1.   Subrecipients must submit to the grantee, no later than 90 calendar days (or an earlier date as agreed upon by the grantee and its subrecipients) after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award and subaward.
  • a. Grantees with respect to their subrecipients, may approve extensions when requested and justified.
  • b. Subrecipients must liquidate all financial obligations incurred under the subaward no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the subaward.
  • c. Subrecipients must promptly refund any balances of unobligated cash that the grantees, with respect to subrecipients, paid in advance or paid and that are not authorized to be retained by the subrecipient for use in other projects. See 2 C.F.R. § 200.346, Part D of the General Education Provisions Act, and EDGAR part 81 for requirements regarding unreturned amounts that become delinquent debts.

Resources

Subrecipient Monitoring

This course is under maintenance due to updates to 2 CFR Part 200. Please review the disclaimer to identify key regulatory reviews before taking the course.

Course Description: This 60-minute course provides a high-level overview of monitoring subrecipients and is intended for grantees that make subawards. It is designed into four modules which cover related key information and processes, regulatory requirements, subrecipient monitoring plans, as well as a risk-based monitoring approach. At the end of each module, participants are asked questions that will check their understanding, but no score or grade will be given.

Course Objective:

After completing this course, you should be able to:

• Recall key definitions that apply to Department grant programs.
• Outline the characteristics of a subrecipient versus a contractor.
• Define pre-award activities.
• Explain the components of a subaward agreement.
• Describe the purpose of monitoring subrecipients.
• Identify the key attributes of effective monitoring.
• Outline Department and grantee monitoring roles and responsibilities.
• Identify regulations and requirements for monitoring subrecipients.
• Describe the purpose of a subrecipient monitoring plan.
• Identify the components of a subrecipient monitoring plan.
• Describe a risk-based approach to subrecipient monitoring.
• Describe a risk rubric and how it is used.