(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. DHHL will submit an amended Native Hawaiian Housing Plan containing, by eligible affordable housing activity, its proposed accomplishments. Office of Native American Programs (ONAP) reviews the Plan for compliance and issues a grant agreement.
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: ONAP does not categorize DHHL as a high-risk grantee. However, ONAP will follow its procedures and monitor this grantee accordingly. Both remote and on-site monitoring are available options, pursuant to NAHASDA and its implementing regulations. This involves reviewing program files, and on-site program examinations. To ensure timely expenditure of funds, ONAP will track disbursements through its systems. To ensure quality expenditure of funds, ONAP will assign its Native Hawaiian Program Specialist, located in Honolulu, to regularly monitor activities at the project level through the review of data and information submitted. Follow-up on issues or matters of concern that are discovered will occur, and the Native Hawaiian Program Specialist is available to go on-site to assess DHHL’s activities at any time with no additional travel resources needed. To ensure budget and cost compliance, all disbursements will be monitored against DHHL’s Native Hawaiian Housing Plan`s proposed affordable housing activities. 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 Annual Performance Report, Form HUD 272I- Financial Status Report, OMB Circular A-133 audits, and procedures outlined in ONAP’s Grants Evaluation Handbook. 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 section 818 of NAHASDA and 24 CFR 1006.430 and .440.
(3) Longer Term Evaluation and Research: There is no planned long-term evaluation of this program.