All Recovery Act programs will be assessed for risk and ensure that proper internal controls exist throughout the entire funding cycle. These assessments will be done consistent with statutory requirements of the Federal Manager’s Financial Integrity Act and the Improper Payments Information Act, as well as OMB’s circular A-123 “Management’s Responsibility for Internal Control.”
CDC’s oversight function for agency-wide Recovery Act Coordination (RAC) will oversee and coordinate all Recovery Act-funded activities. Quarterly reviews of Recovery Act programs will be conducted by RAC in collaboration with CDC’s Financial Management Office (FMO) and Procurement and Grant’s Office (PGO), as well as program managers. Potential risks associated with executing Recovery Act funds have been identified and appropriate mitigation strategies have been instituted to better ensure are achieved. In addition, assurance of adequate staffing levels within FMO, PGO, and within the program has been addressed for appropriate oversight and monitoring of recipient activity.
CDC will perform the following:
• coordinate with the Office of the Inspector General (OIG) to ensure that Recipient Capability Assessments are conducted on funded organizations as needed;
• ensure ongoing technical assistance is provided to contractors and grantees who need assistance in meeting administrative and program requirements;
• monitor the receipt of financial reports, and review those reports for the purpose of monitoring compliance with financial requirements;
• monitor the receipt of recipient progress reports, and review those reports for the purpose of monitoring compliance with program requirements;
• conduct vigorous post-award monitoring to include site visits to grantees;
• ensure the unique identification of Recovery Act funds in contractual and grant agreements, to include the use of unique Recovery Act CFDA numbers for grants;
• refer all known instances of suspected fraud, waste, or abuse to the OIG;
• ensure that timely enforcement actions are taken on any non-performing contractor or grantee;
• take appropriate enforcement action, such as the disallowance of costs, the recovery of funds, the referral of suspected fraud to the OIG, the implementation of administrative corrective actions by the contractor or grantee, or the termination of funding if CDC determines that a contractor or grantee has misused Recovery Act funds, CDC will; and
• support the oversight of the Recovery Accountability and Transparency Board, the OIG, and General Accounting Office, to include taking timely action on inquires and recommendations.
The Section 317 Immunization Grant Program staff will frequently communicate with grant and contract recipients, provide technical assistance via regular conference calls and conduct site visits. Recipients may be allowed to charge increased administrative costs to support the frequent and extensive reporting required by the Recovery Act. Allowable and unallowable expenditures will be clearly communicated to recipients and appropriate penalties for misappropriation or misuse of funds will be enforced. The Office of Management and Budget (OMB) Circular A-133, “Audits of States, Local Governments and Non profit Organizations” will set the administrative requirements for these entities. OMB Circular A-87, “Cost Principles for State, Local and Indian Tribal Governments” will set the Federal principles for determining allowable costs.
Development and submission of grantee plans and quarterly updates on progress towards specific economic and performance measures and targets will minimize risk, serve as an evaluation of progress, and allow for early/timely risk mitigation. Monthly and quarterly reporting by recipients will be monitored by project and contract officers and failures to adhere to performance measures will be elevated to supervisory authorities immediately for troubleshooting.