ST. TAMMANY PARISH GOVERNMENT CDBG-DR Compliance and Monitoring Guide

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1 INTRODUCTION St. Tammany Parish s Grants Management Office is the respnsible entity charged with administering all Cmmunity Develpment Blck Grant- Disaster Recvery (CDBG-DR) funds n behalf f St. Tammany Parish Gvernment (Grantee). This staff is respnsible fr ensuring all prjects and prgrams are administered efficiently and effectively, timely, and in accrdance with all applicable rules and regulatins. Grants Management Office Staff will wrk in cnjunctin with ther necessary Parish s Departments as needed and will cmpetitively prcure additinal services needed such as architects, as needed. This Mnitring and Cmpliance Guide is designed t assist St. Tammany Parish Grants Department in the mnitring f disaster recvery grants. This guide prvides infrmatin regarding the general CDBG-DR mnitring prcess as utlined by HUD. It is the respnsibility f each grantee t ensure that all federal rules and regulatins are cmplied with by each grantee. Grantees must als carry ut prper and efficient grant administrative practices. This guide will serve as a tl fr thse mnitring CDBG-DR prgrams implemented by St. Tammany Parish, its cntractrs, and sub-recipients. CDBG-DR grants are authrized by the United States Cngress and the President f the United States under supplemental apprpriatin laws. ( Supplemental Apprpriatins Acts authrize CDBG funding.) Specific requirements are typically included in the apprpriatin law adpted t cver a specific disaster. These requirements may mdify, r authrize HUD s Secretary t mdify, varius statutes and regulatins that culd impede the prmpt implementatin f disaster relief and assciated cmmunity develpment prgrams. Ntice f waivers and alternate requirements are published in the Federal Register). HUD s rle is t wrk with grantees t ensure the designs f the actin plans (and amendments) are acceptable; grant waivers f existing statutry requirements and the assciated implementatin regulatins; define alternate requirements when necessary; and, mnitr the grantee s implementatin activities. Actin plans, as amended, allcate and define the scpe f the funds apprpriated t the prgrams described. Grantees may chse t implement prgrams directly, thrugh prperly prcured cntractrs r delegate the respnsibility t subrecipients. This respnsibility is delegated via Interagency Agreements (IAs), Cperative Endeavr Agreements (CEAs), r subrecipient agreements. OVERVIEW OF MONITORING OBJECTIVES Mnitring is an integral management cntrl technique and CDBG standard. It is an nging prcess that assesses the quality f a prgram participant s perfrmance ver a perid f time. Mnitring prvides infrmatin abut prgram that is critical fr making infrmed judgments abut prgram effectiveness and management efficiency. It als helps in identifying instances f fraud, waste and abuse. The fllwing bjectives are accmplished thrugh the mnitring prcess. 1

2 T determine if a grantee/subrecipient is carrying ut its CDBG-DR prgram, and its individual activities as described in the Actin Plan fr CDBG-DR assistance and its related amendments; T determine if a grantee/subrecipient is carrying ut its activities in a timely manner, in accrdance with the schedule included in the cntractual agreement; T determine if a grantee/subrecipient is charging csts t the prject that are eligible under applicable laws and CDBG-DR regulatins and reasnable in light f the services r prducts delivered; T determine if a grantee/subrecipient is cnducting its activities with adequate cntrl ver prgram and financial perfrmance and in a way that minimizes pprtunities fr waste, mismanagement, fraud and abuse; T assess if the grantee/subrecipient has a cntinuing capacity t carry ut the apprved prject, as well as future grants fr which it may apply; T identify ptential prblem areas and t assist the grantee/subrecipients in cmplying with applicable laws and regulatins; T assist grantee/sub-recipients in reslving cmpliance prblems thrugh discussin, negtiatin, and the prvisin f Technical Assistance and training; T prvide adequate fllw-up measures t ensure that perfrmance and cmpliance deficiencies are crrected by grantee/subrecipients and nt repeated; T cmply with the Federal mnitring requirements f 24 CFR (b) and with 24 CFR and 85.40, as applicable; T determine if any cnflicts f interest exist in the peratin f the CDBG-DR prgram per 24 CFR ; and T ensure that required recrds are maintained t demnstrate cmpliance with applicable regulatins. ROLES AND RESPONSIBILITIES Department f Grants Directr: Respnsible fr versight f all cmpliance and mnitring activities; signs all relevant letters (e.g. nsite visit strategy letter and mnitring reprt letter); issues final decisins regarding findings and cncerns. Department f Grants Assistant Directr: Respnsible fr directing the day-t-day activities related t cmpliance and mnitring, including the cmpletin and maintenance f the risk assessment and mnitring schedule, editing and tracking letters t all entities, and ensuring the cmpliance and mnitring staff are prepared fr and are effectively carrying ut all tasks. CDBG-DR Prject Manager: Respnsible fr cmpleting desk mnitring, nsite mnitring visits, and technical assistance; drafting all relevant letters; cmpleting mnitring checklists; and dcument management. Finance Department: Respnsible fr ensuring that all csts incurred meet applicable lcal, state, and federal regulatins. Prcurement Department: Respnsible fr ensuring that all applicable lcal, state, and federal regulatins are fllwed in the prcurement f gds and services. 2

3 Legal Department: Respnsible fr drafting and reviewing all agreements, cntracts, and subcntracts fr adherence t applicable rules and regulatins and reviewing findings and cncerns resulting frm cmpliance and mnitring activities t determine if legal actin is required. RISK ASSESSMENT Cnsistent with HUD requirements detailed in the CPD Mnitring Handbk ( Rev-6 and updated in CPD-14-04) The Parish will cnduct a risk analysis n all entities being mnitred, including all prgrams, cntractrs, and sub-recipients in rder t identify thse entities and prgrams that are mst susceptible t fraud, abuse, r mismanagement. It is t be nted that thrugh the cmpetitive prcess fr prcuring vendrs, many if nt all f the risk assessment factrs are assessed. The risk analysis prvides critical infrmatin t effectively target resurces tward entities and prgrams that pse the greatest risk t the integrity f St. Tammany Parish s CDBG-DR funding, including identificatin f the grantees t be mnitred n-site and remtely, the prgram areas t be cvered, and the depth f the review. The selectin prcess results in identifying grantees and activities that represent the greatest vulnerability t fraud, waste, abuse, and mismanagement. This assessment will allw the parish t minimize ptential risk as it administers its CDBG-DR allcatin. The Parish may adjust the sample utlined belw t reflect new criteria r risk factrs as identified. St. Tammany Parish will make necessary adjustments in preparing the mnitring strategies and revising them based n new infrmatin, such as declining r imprvement in participant perfrmance, budget cnstraints, reprgramming f resurces r ther unanticipated events. St. Tammany Parish CDBG-DR Risk Assessment Sample Criteria Descriptin High Risk Medium Risk Funding Ttal Funds allcated t the Prject (including FEMA and ther federal and State funds) Over $1,000,000 $500,000- $1,000,000 Lw Risk $500,000 and belw Cmplexity The multiple types f resurces and activities assciated with the prject Cnstructin Prjects Demlitin nly; Lan r Grant Prgram Single surce funded prjects. Buyuts with withut Cnstructin 3

4 Implementatin Methd Relevant Experience Cmpliance Histry Prject Timeline The use f sub-recipients, vendrs, r internal staff t carry ut the prgrams/prject The experience f grantee/subrecipient/cntractr administering CDBG funds. The grantee s past cmpliance with federally funded prgrams. The prjected and defined timeline fr prject cmpletin, per the agreement. Subrecipient Grantee Staff with cntractr Prgram Management Cntractr N 1-3 years f 4+ years f Experience experience experience Past mnitring visits revealed severe deficiencies; r n evidence f any prir mnitring Evidence f prir mnitring; deficiencies nted, but nne severe mnths High Risk: Pints Medium Risk: Pints Lw Risk: Less than 18 Pints MONITORING Entities t be Mnitred Evidence f prir mnitring; n deficiencies nted 6-12 mnths Cmpletin in under 6 mnths Cntractrs/Vendrs Cntractrs/Vendrs are entities cmpetitively selected t prvide clearly-specified gds r services. The cntract price is established thrugh the prcurement prcess. CDBG-DR funds are paid t the cntractr as cmpensatin fr the satisfactry prvisin f the gds and services as specified in the cntract. The prcurement prcess prvides fr the initial review f cntractrs/vendrs as they are required t submit such dcumentatin as part f the bid dcument and qualificatins submissin. Hwever, ther than rules relating t bnding, insurance, prevailing wages and ther such prvisins, mst f the standard federal administrative and mnitring requirements (described in 24 CFR Parts 84 and 85, as applicable) including, but nt limited t prgram incme, financial management, allwable csts, recrd retentin, and cnflict f interest d nt apply t cntractrs, nce the prcurement prcess is cmplete. 4

5 Subrecipients Subrecipients can be Gvernmental Agencies, Private Nn Prfits, Private Fr-Prfits (under the prvisins f 24 CFR (), Cmmunity Based Develpment Organizatins (CBDOs) wh are selected by the grantee t carry ut agreed upn eligible activities n behalf f the grantee. Because grantees are acting n behalf f the subrecipients, all administrative requirements which are required f the grantee are transferred t the sub-recipient causing the administrative and mnitring requirements t be greater fr sub-recipients. Grantee Implemented Prgrams The grantee may als chse t implement prgrams directly. In these circumstances, the grantee s mnitring and cmpliance department must mnitr these prgrams t ensure that the prgram is perating in a cmpliant manner accrding t all CDBG-DR requirements, federal, state and lcal laws. Areas t be Mnitred Prgram Review Prgram Review fcuses n the review f specific prgram activities. Prgram staff is asked t define the prgram and the mnitring staff shuld review CDBG-DR eligibility, natinal bjective cmpliance, and duplicatin f benefits. Prgram mnitring shuld ensure that the prgram is fllwing all f their written plicies and prcedures. A review f the verall management f the prgram is als apprpriate in this categry. Financial Review Financial Review fcuses n making the cnnectin between the prgram budget, expenditures and actual beneficiaries assisted, including evidence f case managers time in client files, reviewing payrll dcuments fr the perid applicants are reprted, determining eligibility f applicants based n incme dcumentatin in client files, the general relatinship between the cntents f the client files and benefit data reprted by the sub-recipient n the same applicants. Prgram Applicant Files When applicable, prgram applicant files shuld be reviewed thrugh the frmal mnitring prcess. This is different than regular Quality Assurance /Quality Cntrl prcess (QA/QC) which shuld be a regular part f the prgrammatic prcedures. When cmpleting a mnitring f prgram applicant files, the mnitring staff shuld randmly select a sample set f review and nrmally a set that fcus n and reflects apprximately 10% f the ttal applicants served in the prgram, r mre if there appears t be any systemic issues t address. Invices A sample f submitted invices are randmly selected fr review and traced back frm CDBG- DR reimbursements t the riginal rganizatin's expenditure and client(s) assisted (if apprpriate). Fr example, tracking if exact dllars billed fr service by a subcntractr can be traced directly t ne cntractr. Cnversely, a different review mdel is required when dllars billed prvided services and materials frm multiple subcntractrs n different jb sites. It is expected that the mnitring staff wuld review riginal invices, cancelled checks, and ther 5

6 dcumentatin evidencing the dllar expenditure, the relatinship t the CDBG-DR prgram bjective, the apprpriate prprtin f CDBG-DR expenditure in cmparisn t ther funding included in the prject budget, and accunting receipt f the federal grant funds. Sampling methdlgy: Select 10% f invices fr review. If mre than 5% f the invices in the sample are fund t have errrs, expand sample t an additinal 10%. If mre than 5% f the secnd sample are fund t have errrs, expand sample t 25% f all invices (excluding thse already reviewed). If mre than 5% f the third sample are fund t have errrs, review 100% f the invices. Types f Mnitring Desk Review The Desk Review is a limited review f prgrams, subrecipients and cntractrs/vendrs and is cnducted pre-determined basis (quarterly, annually, twice a year). The standard desk review can ccur quarterly and can cincide with submissin f any quarterly reprting required per the cntract r sub-recipient agreement. (Ex. DRGR reprting). The gal f a Desk Review is t prvide clarificatin t a specific unknwn that cannt be determined frm the subrecipient r cntractr/vendr reprts, and t identify areas f technical assistance needed. Additinally, desk reviews are an integral part f the initial steps fr n-site mnitring as they shw an insight int the prgram. Vendrs/Cntractrs During the Desk Review, cntract terms and cnditins are reviewed by the CDBG-DR Prject Manager. Cntractrs and vendrs are required t submit as part f their initial respnse and review such dcuments as: Cpies f Insurance dcumentatins, i.e., liability and prfessinal liability; Cpies f Bnding dcumentatin; Sectin 3 Plan; EEO Utilizatin Plan; and Financial Statement f Cnditin. Additinally, the desk review can be used t review reprts dcumenting prgress n the verall prject as well as mre specific reprts n prgram cmpnents such as Sectin 3, Davis-Bacn and EEO which are submitted t the grantee. 6

7 Subrecipients During a desk review f a subrecipient, the CDBG-DR Prject Manager can review the status f subrecipient agreements, and ther dcuments r areas including but nt limited t the fllwing: Subrecipients Prgrammatic Plicies and Prcedures Subrecipients accunting system and dcumentatin f financial transactins; Previus invices submitted t the grantee Prcurement plicies and prcedures Reprting prcesses; Grant/subrecipient agreement terms; Reprting and supprting dcuments such as insurance, certificatins and ther dcumentatin required by the grantee Grantee Implemented Prgrams During a desk review, the CDBG-DR Prject Manager will take the time t review the fllwing items and assess if there are areas where the prgram needs additinal assistance. Additinally, if there are ther areas in the prgram which need assistance, the Prject Manager shuld review thse as well. Prgram Plicies and Prcedures Prgram Quarterly reprts Technical Assistance The Parish, may als peridically cnduct Technical Assistance (TA) sessins with subrecipients, cntractrs/vendrs, and/r direct beneficiaries t enable them t understand expectatins fr prgram cmpliance and prepare fr mnitring and define. The Parish may prvide technical assistance thrughut the life f a CDBG-DR grant n numerus tpics as it relates t the implementatin f CDBG DR funded prjects. Technical Assistance can cme in numerus different frms such as: Verbal r written advice; Frmal training; and/r, Dcumentatin and guidance. Very cmmnly, Technical Assistance can be fr new subrecipients/vendrs t intrduce them t the requirements f CDBG-DR. Hwever Technical Assistance can als include ther mre technical areas which are tailred t ne specific prgram, subrecipient r vendr r t all entities wh have a rle in administering the CBDG-DR dllars. As part f Technical Assistance visits, mnitring and cmpliance staff will answer any questins and prvide guidance n the mnitring and cmpliance prcess. Grantees shuld visit the risk assessment, desk mnitring and nsite mnitring t determine the Technical Assistance need f a prgram, vendr/cntractr, r grantee. Areas cmmnly cvered thrugh Technical Assistance: Prgram Eligibility Criteria CDBG-DR requirements including but nt limited t 7

8 CDBG-DR eligible activities CDBG-DR natinal bjectives Financial Management Requirements and timely expenditure f funds Labr Requirements ( Davis Bacn) Sectin 3 Requirements Envirnmental Review Requirements FHEO (LEP, Equal Emplyment Opprtunities, Fair Husing, ADA, Sectin 3, Sectin 504) Mnitring and Cmpliance Recrdkeeping Clseut Onsite Mnitring At least ne nsite review shuld be cnducted f all prjects prir t clseut. This review shuld ccur early enugh in the prject life cycle t allw time fr technical assistance and/r the reslutin f any crrective actins that may be identified. Prjects requiring fllw-up activities and/r crrective actins shuld take precedence ver thse nt requiring such actins. The prject risk shuld als be taken int accunt when scheduling additinal reviews. The Department f Grants Assistant Directr, r her designee will use the fllwing criteria t define the scpe and fcus f nsite mnitring effrts. Identificatin f the fllwing ccurs: The prgrams/areas/functins t be reviewed; Data r infrmatin t be submitted by the prgram participant prir t mnitring (if any); The names f any participant staff members wh will need t be cnsulted during the mnitring; Anticipated staff wh will cnduct the mnitring; Clearly defined areas f respnsibilities fr each reviewer (t avid duplicatin) if mre than ne staff persn will be cnducting the mnitring; A schedule fr carrying ut the mnitring tasks and the anticipated time frames; and Required resurces. Preparing fr a Review Mnitring Strategy Letter Prir t an nsite mnitring visit, the STPG Department f Grants will send a Mnitring Strategy letter at least 30 day prir t the mnitring visit. The letter discusses the mnitring schedule and identifies the areas t be reviewed and the names and titles f the individuals wh will be cnducting the mnitring. It als requests that the necessary entity staff, if applicable, be available during the mnitring. The letter cnfirms the need fr any required services (e.g., cnference rms, telephnes, and cmputers). 8

9 Advance Review In preparatin fr an nsite mnitring visit, the STPG Department f Grants shuld request relevant plicies and prcedures, manuals, and guidelines frm the entity t be mnitred, including dcuments pertaining t financial management, prcurement, cntracting, mnitring, and civil rights cmpliance. T the greatest extent feasible, these dcuments shuld be reviewed prir t the nsite visit in rder t maximize the time available fr reviewing prject dcuments while nsite. Perfrming a Review Entrance Cnference The purpse f the entrance cnference is t: Explain hw the mnitring will be cnducted; Identify/cnfirm key entity staff that will assist during the mnitring; Set up r cnfirm meeting r interview times (including any staff r persnnel wh may be interviewed) and, if applicable, schedule physical inspectins; and Verify the prgrams/activities t be reviewed and, if n-site, hw access t files and wrk areas will be granted (sme prgrams files can be sensitive; sme wrk areas can be hazardus). Mnitring Prcess Based n the areas utlined in the mnitring strategy, STPG staff will utilize dcuments which the parish has created as well as the HUD Mnitring Checklists fr the area being mnitred. In general the mnitring prcesses seeks t answer the fllwing questins: Is the prgram purpse being accmplished? Are the prgram beneficiaries being served as intended? Are prgram requirements being met? Is the prgram adhering t federal CDBG-DR, state and lcal requirements? D the prgram files dcument all f the prgram pieces frm award t clseut HUD has prvided all grantees such as STPG with access t The HUD Cmmunity Planning and Develpment (CPD) Mnitring Handbk This handbk prvides exhibits which HUD utilizes in their mnitring f grantees. These exhibits shuld be utilized in St. Tammany Parish s mnitring f prgrams run internally, sub-recipients, and vendrs/cntractrs. These exhibits can be accessed n HUD s website. Fr each prject where STPG is using CDBG-DR funds fr prject funding, the grantee (parish), subrecipient, r vendr/cntractr must maintain adequate recrds which cmply with 24 CFR (a)(1). Therefre, when mnitring, the first step is t review the prgram files based n the mnitring strategy. STPG has utlined its Recrds Management plicies in sectin 13 f Cmmunity Develpment Blck Grant Disaster Recvery Administrative Manual. The plicies utlined in this manual shuld be utilized as the basis fr mnitring the recrds fr each prgram and ultimately the entire CDBG-DR grant. 9

10 Fr the implementatin f grants, STPG has utlined a lengthy Grant Implementatin Checklist in sectin 12.0 f the Cmmunity Develpment Blck Grant Disaster Recvery Administrative Manual. This tl exemplifies the prcess and the dcumentatin which is needed fr each Grant. This shuld be utilized as the basis fr mnitring each grant which is given t a subrecipient r which is implemented by the Grants Management Office. Fr cnstructin prjects, STPG has als utlined the prcess fr managing and mnitring cnstructin prjects which are funded with CDBG-DR in f the Cmmunity Develpment Blck Grant Disaster Recvery Administrative Manual Sectin. STPG shuld utilize these cdified prcedures in the mnitring f cnstructin prjects. Thrughut the nsite mnitring, STPG staff will maintain an nging dialgue with the entity being mnitred. Such cmmunicatin keeps the entity infrmed as t hw the mnitring is prgressing, enables discussins f any prblem areas encuntered and prvides the entity an pprtunity t make n-the-spt adjustments r crrectins r present additinal infrmatin t help the STPG staff respnsible fr mnitring. It als minimizes the ptential fr surprises t the entity when the exit cnference is held as well as when the mnitring results are frmally cmmunicated in writing. Best practices fr mnitring suggest a randm sampling f 10-15% f prgram files (if there are applicant r multiple prjects in ne prgram) fr each prgram activity being mnitred. If financial files r invices are being mnitred, then a similar sample maybe sampled. Fr nn-randm samples, STPG mnitring staff shall give cnsideratin t the areas utlined in the mnitring strategy as well as unreslved prblems remaining frm previus mnitring, any new types f activities being undertaken and/r the extent f any activities cnsidered high risk. Any sample review r spt-check f the entity recrds that raises questins cncerning the accuracy f the data indicates the need fr further fllw-up. Exit Cnference After cmpletin f the mnitring review, the STPG staff nsite cnducts an exit cnference with the apprpriate prgram fficials r staff t discuss preliminary cnclusins. In part, this serves t cnfirm the accuracy and cmpleteness f the infrmatin used t frm the basis fr the mnitring cnclusins. It may als highlight areas f disagreement between STPG and the entity being mnitred. All cnclusins psitive r negative must be supprtable, defensible, and adequately dcumented. As a result f mnitring, STPG may reach ne r mre cnclusins that: Perfrmance was adequate r exemplary; Significant achievements were made; Specific cncerns need t be brught t the entity's attentin; Technical assistance was prvided r is needed; and/r Findings will require crrective actins. 10

11 Mnitring Reprt Within 30 days after cmpletin f mnitring, The Department f Grants Assistant Directr, r her designee, will draft and send the Mnitring Reprt t the subrecipient and/r cntractr/vendr describing the results in sufficient detail t clearly describe the areas that were cvered and the basis fr the cnclusins. The mnitring reprt shuld utline all findings, cncerns and bservatins frm the mnitring visit. Observatin: An area where the STPG staff bserves sme prgrammatic files r decisins which culd lead t a cncern r finding if nt addressed, but there is nt enugh evidence at the time f the mnitring that wuld warrant a cncern r finding. Areas where bservatins are nted likely result in Technical Assistance which can remedy the Observatin. Cncern: A deficiency in prgram perfrmance nt based n a statutry, regulatry r ther prgram requirement. Sanctins r crrective actins are nt authrized fr cncerns. Hwever, STPG shuld bring the cncern t the prgram s attentin and, if apprpriate, may recmmend (but cannt require) actins t address cncerns and/r prvide technical assistance. Finding: A deficiency in prgram perfrmance based n a statutry, regulatry r prgram requirement fr which sanctins r ther crrective actins are authrized. Where an identified deficiency results in a finding, the finding must include the cnditin, criteria, cause, effect, and required crrective actin. The cnditin describes what was wrng r what the prblem was. The criteria cite the regulatry r statutry requirements that were nt met. The cause explains why the cnditin ccurred. The effect describes what happened because f the cnditin. The crrective actin identifies the actin(s) needed t reslve the prblem and, unless inapplicable r there are extenuating circumstances, shuld include the time frame by which the participant is t respnd t the finding Each Mnitring Reprt is t include: The prgram, prject r entity mnitred; The dates f the mnitring; The name(s) and title(s) f the STPG staff that perfrmed the mnitring review; A listing f the prgram/prject/activity areas reviewed (which, in mst cases, will repeat the areas utlined in the ntificatin letter t the participant); If applicable, a brief explanatin f the reasns why an area specified in the ntificatin letter was nt mnitred (e.g., time cnstraints, unanticipated prblems arising in anther area); Mnitring cnclusins; If applicable, clearly labeled findings and cncerns; 11

12 If there are findings, an pprtunity fr the sub-recipient and/r cntractr/vendr t demnstrate, within a time prescribed by STPG, that the sub-recipient and/r cntractr/vendr has, in fact, cmplied with the requirements; Respnse time frames, if needed; An ffer f Technical Assistance, if needed r a descriptin f Technical Assistance prvided during the mnitring. Generally, the tne f the mnitring letter is psitive, in recgnitin f the cmmn gal t respnsibly and effectively implement STPG s recvery prgrams. Significant accmplishments r psitive changes are included t establish and maintain cnstructive relatinships and t recgnize the dedicatin and cmmitment f the sub-recipient and/r cntractr/vendr staff t the prgram missins. Rather than brad, general statements, cnclusins dictated in the mnitring letter must be specific and defendable. Fr example, a statement such as the sub-recipient and/r cntractr/vendr cmplied with all applicable rules and regulatins is t vague. Rather, because mnitring reviews cver selected prgram r technical areas, a mre suitable statement is based upn the materials reviewed and the staff interviewed, the activity/area was fund t be in cmpliance with (specify requirements). Mnitring Respnse Once the subrecipient and/r cntractr/vendr has received the Mnitring Reprt, the entity will have 30 days t respnd t STPG. Thrugh this respnse, the sub-recipient and/r cntractr/vendr can prvide respnses t the findings and cncerns and can nte t STPG hw they are implementing any crrective actin which is recmmended in the Reprt. Mnitring Fllw Up Once a respnse is submitted by the sub-recipient r vendr/cntractr, then it will be the STPG s respnsibility t then cntinue dialgue and fllw up t ensure that the items which are clsed r where crrective actin is being implemented. Cntinued cnversatin and crrespndence via , letter r verbal cnversatins will cntinue t allw STPG t wrk with their sub-recipients and vendrs/cntractrs t ensure that prgrams cntinue t be cmpliant 12