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32 <br /> <br />records, reporting, and refunding expenditures disallowed by audits, monitoring if acting as a pass- <br />through entity, other assessments and reviews, and ensuring overall compliance with the terms and <br />conditions of the award or subaward, as applicable, including the terms of 2 C.F.R. Part 200. <br /> <br />Financial Monitoring Overview and Approach <br />FEMA’s approach to financial monitoring provides a standard monitoring framework that promotes <br />consistent processes across all monitoring staff. There are four core components of the monitoring <br />process: <br /> <br />1. Monitoring Assessment: Monitoring staff measure each grant’s monitoring needs using a system <br />of pre-determined evaluation criteria. The criteria help assess the recipient and potential <br />challenges to the success of the grant award. <br /> <br />2. Monitoring Selection and Scheduling: Monitoring staff make selection and scheduling <br />decisions in accordance with applicable statutory requirements, such as the Homeland Security <br />Act of 2002, as amended (hereafter “HSA”), and consider the results of the monitoring assessment <br />process. <br /> <br />3. Monitoring Activities: Monitoring activities include cash analysis, desk reviews, and site visits. <br />Grants Management Specialists are responsible for conducting quarterly or semi-annual reviews <br />of all grants via cash analysis. Desk reviews and site visits are additional monitoring activities <br />conducted on grants where the monitoring assessment process identified the need for additional <br />monitoring and validated the use of FEMA resources for these activities. <br /> <br />4. Post-Monitoring Actions: Monitoring staff may follow up with recipients via post-monitoring <br />actions based on the outcomes of monitoring activities. Post-monitoring actions include <br />conducting additional monitoring; reviewing Corrective Action Plans (CAP) and monitoring the <br />progress of CAP deliverables; documenting the resolution of identified corrective actions and <br />issues; providing technical assistance and recipient training; and debt collection. <br /> <br />In addition to the monitoring guidance outlined above, section 2022(a)(2)(A) of the HSA mandates the <br />frequency of monitoring activities for applicable preparedness grants. The applicable section of the HSA <br />reads as follows: <br /> <br />Not less than once every 2 years, the Administrator shall conduct, for each state and high-risk <br />urban area receiving a grant administered by the Department, a programmatic and financial <br />review of all grants awarded by the Department to prevent, prepare for, protect against, or <br />respond to natural disasters, acts of terrorism, or other man-made disasters, excluding assistance <br />provided under section 203, title IV, or title V of the Robert T. Stafford Disaster Relief and <br />Emergency Assistance Act (42 U.S.C. 5133, 5170 et seq., and 5191 et seq.). <br /> <br />The following preparedness grant programs covered by this Manual are subject to HSA monitoring <br />requirements: <br /> <br />• HSGP <br />o SHSP <br />o UASI <br />o OPSG <br />• NSGP <br />• TSGP