 |
 |

Developing a Monitoring Plan
|
 |
|
|
|
An annual monitoring plan should identify the PJ's monitoring goals
and strategies, highlighting areas that staff wants to pay special
attention to during the monitoring year.
A PJ's monitoring efforts should be guided by both its responsibilities
under the HOME Program
and its affordable housing goals for the community. These monitoring
efforts may include:
|
Identifying
and tracking program and project results; |
|
Identifying
technical assistance needs of PJ, CHDO, and sub recipient staff; |
|
Ensuring
timely expenditure of HOME funds; |
|
Documenting
compliance with Program rules; |
|
Preventing
fraud and abuse; and |
|
Identifying
innovative tools and techniques that support affordable housing
goals. |
While
all of these objectives are important, the emphasis on one or more
of them may shift from year to year. For example, HOME monitoring
staff may wish to give special attention to the technical assistance
needs of CHDOs and other non-profit housing development organizations.
Often, it will be necessary for PJs to prioritize monitoring goals
based on the availability of staff and resources.
Well-designed
monitoring strategies help PJ staff use the appropriate level of
effort to ensure performance and compliance in each focus area.
In general, a comprehensive HOME monitoring strategy involves a
two-pronged approach.
Ongoing Monitoring
A
sufficient level of monitoring should be built into the PJ's service
delivery system and be performed throughout the year. This will
involve an examination of both routine and special reports from
HOME program staff, housing owners/developers/sponsors, sub recipients,
state recipients, and contractors. This information enables the
monitor to assess performance and identify any compliance problems.
The annual monitoring plan should identify the format and frequency
with which internal and external staff will prepare project or program-related
reports.
Based
on the data submitted, monitoring staff may generate internal reports
on the status of every HOME-funded activity. Program-wide data,
such as the number of units developed, number of families assisted,
and the ongoing expenditure amounts of HOME funds, should also be
tracked. If questions or concerns arise, monitoring staff should
request additional information from the appropriate source.
Monitoring
In
addition to the ongoing monitoring they perform for all activities,
PJs usually select certain HOME program areas or organizations for
in-depth monitoring each year. On-site monitoring involves a visit
to the program or project to gather specific information and observe
actual program elements. On-site monitoring is especially appropriate
if there is a strong likelihood of problems, or if a lengthy time
period has elapsed since the last visit. During an on-site review,
monitors evaluate overall performance and determine if compliance
problems exist. Site visits often enable the monitor to identify
aspects of the program or project that is contributing to a problematic
situation. Monitoring staff must prepare and distribute a report
summarizing the results of the review, and describe any required
follow-up activity.
By
using this two-pronged approach, PJs can define the scope of their
monitoring based on the circumstances of individual HOME activities
or partners. The oversight performed as part of its ongoing monitoring
can identify potential problems early, prevent compliance violations
and help improve performance. On-site monitoring usually provides
the most comprehensive review because it allows access to actual
project records, staff, and clients.
Use Risk Factors to Set Priorities
With
limited staff and time resources, most PJs cannot perform on-site
reviews of all HOME-funded activities or partners. Therefore, it
is critical to carefully determine which organizations and program
areas should receive the investment of staff time and attention
required by an on-site review. A sound basis for making this decision
is a risk assessment, in which program and monitoring staff evaluate
the likelihood that a project, program or entity has violated HOME
regulations, failed to comply with program requirements, or is open
to fraud and abuse. This evaluation may also focus on activities
that carry performance risk, such as poor housing unit production;
a low number of residents assisted, or slow expenditures.
To learn more about how organizational and program risk can be used
to help develop the annual monitoring plan, click on the following
links:
|