(1) Data Collection and Reporting
a. Spend Plans: An eligible applicant must submit an application in response to a Notice of Funding Available. The applications contain information on their proposed project including timeframes for project implementation. The Area Office of Native American Programs (ONAP) will rate and rank the application. If funded, but before gaining access to funds, the grantees must execute a grant agreement with special conditions related to the Recovery Act.
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.).
d. Sample Survey of Outcomes: There is no planned survey of outcomes for this program.
(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 actions. 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 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 grantees submit to regular audits. 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 regular risk assessment tools, such as the use of the Annual Status and Evaluation Report, Form SF-272-Federal Cash Transaction Report, and OMB Circular A-133 audits. If necessary, enforcement actions will occur and categorical training and technical assistance will be offered to resolve specific problems. Enforcement 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 § 1003.701, 1003.702, 1003.703. Remedies can be triggered if HUD determines that the grantee has not complied with the statute or regulations, has not carried out the activities as described in its applications, has not made substantial progress on the funded project, or has not shown the continuing capacity to carry out its approved activities. Grants will not be awarded to tribes with remedies currently imposed.
(3) Longer Term Evaluation and Research: There is no planned long-term evaluation of this program.