(1) Data Collection and Reporting
a. Spend Plans: After award, but before gaining access to funds, the grantees must submit a plan on how they will use their funds. Applicants will submit an amended FY 2008 Indian Housing Plan to their Area Office of Native American Programs (ONAP). Staff in the Office of Native American Programs will review these plans prior to making funds available for expenditure.
b. Financial Reports: HUD has two financial reports that will be generated and analyzed on a weekly basis. These include a Summary Financial Report that indicates the amount of funds for each program, and a Funding Notification Report, which shows the amount of funding by program for every jurisdiction, including local governments and some states.
c. Quarterly Recipient Reports: The cornerstone of HUD’s monitoring and evaluation system is the project and contract data collected from grantees. The Recovery Act specifically requires data collection fields for grantees and contractors. In addition to these data, HUD will also collect program-specific measures from grantees (e.g., number of units rehabilitated, etc.).
(2) Ongoing Grantee Management: HUD categorizes grantees by risk, then monitors and works with grantees to resolve performance issues, including providing training, technical assistance, and, if warranted, enforcement action. Findings of non-compliance will trigger the remedial process. High-risk grantees are those that are in the process of having remedies imposed. Both remote and on-site monitoring are available options, pursuant to NAHASDA and its implementing regulations. To ensure timely expenditure of funds, ONAP tracks disbursements through its systems. To ensure quality expenditure of funds, ONAP regularly monitors activities at the project level through the review of data and information submitted. Follow-up will occur on issues or matters of concern that are discovered. To ensure budget and cost compliance, the grantee will be monitored through its Annual Performance Report, comparing it against the Indian Housing Plan’s proposed affordable housing activities. Quarterly reports will be reviewed to verify expenditure and obligation rates. To ensure legal compliance and prevent fraud, all activities under this grant will be tracked for compliance with statutory, regulatory, and administrative requirements by the ONAP Headquarters Grants Evaluation staff through the use of on-site monitoring and regular risk assessment tools, as well as the use of the Annual Performance Report, Form HUD-272-I-Financial Status Report, and OMB Circular A-133 audits. If necessary, interventions will occur and categorical training and technical assistance will be offered to resolve specific problems. Actions for non-compliance include shutting down access to funds, letters of warning, notices of intent to impose remedies, and imposition of sanctions pursuant to 24 CFR § 1000.532 and 1000.538. Remedies can be triggered by substantial noncompliance with NAHASDA or its regulations, as defined at 24 CFR §1000.534. Grants will not be awarded to tribes with remedies currently imposed.