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<br />Preparedness Grants Manual <br />In terms of overall award management, recipient and subrecipient responsibilities include—but are <br />not limited to—accounting of receipts and expenditures, cash management, maintaining adequate <br />financial records, reporting, and refunding expenditures disallowed by audits, monitoring if acting as <br />a pass-through entity, other assessments and reviews, and ensuring overall compliance with the <br />terms and conditions of the award or subaward, as applicable, including the terms of 2 C.F.R. Part <br />200. <br />6.1.2. 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 />1. Monitoring Assessment: Monitoring staff measure each grant’s monitoring needs using a <br />system of pre-determined evaluation criteria. The criteria help assess the recipient and <br />potential challenges to the success of the grant award. <br />2. Monitoring Selection and Scheduling: Monitoring staff make selection and scheduling <br />decisions in accordance with applicable statutory requirements, such as the Homeland <br />Security Act of 2002, as amended (hereafter “HSA”) and consider the results of the <br />monitoring assessment process. <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 <br />reviews of all grants via cash analysis. Desk reviews and site visits are additional monitoring <br />activities conducted on grants where the monitoring assessment process identified the need <br />for additional monitoring and validated the use of FEMA resources for these activities. <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 TA and recipient training; and debt collection. <br />In addition to the monitoring guidance outlined above, section 2022(a)(2)(A) of the HSA mandates <br />the frequency of monitoring activities for applicable preparedness grants. The applicable section of <br />the HSA reads as follows: <br />Not less than once every 2 years, the Administrator shall conduct, for each state and high- <br />risk urban area receiving a grant administered by the Department, a programmatic and <br />financial review of all grants awarded by the Department to prevent, prepare for, protect <br />against, or respond to natural disasters, acts of terrorism, or other man-made disasters, <br />excluding assistance provided under section 203, title IV, or title V of the Robert T. Stafford <br />Disaster Relief and Emergency Assistance Act (42 U.S.C. 5133, 5170 et seq., and 5191 et <br />seq.). <br />HSGP (including SHSP, UASI, and OPSG), NSGP, TSGP, PSGP, and the EMPG Program are subject to <br />HSA monitoring requirements. The IPR Program, IBSGP, and THSGP are not subject to HSA <br />monitoring requirements. <br />6.1.3. STANDARD MONITORING ACTIVITY: CASH ANALYSIS <br />Through cash analysis, a Grants Management Specialist assesses and reports on the recipients’ <br />cash-on-hand, expenditures, and unliquidated obligations; gauges potential cost share shortfalls and <br />cash on hand issues; and monitors spend down activities within the POP. The analysis reconciles <br />37