Annual Fiscal Monitoring Program

Annually, NHED conducts a risk assessment to ensure that risk indicators and weights reflect current risks that could lead to diversion of grant funds. Each subrecipient is allotted points based upon these criteria, and assigned a risk level of high, moderate/medium, or low based on the total number of points allotted. An organization's risk level will be used by NHED to determine subrecipient monitoring. 

Each year, the Bureau of Federal Compliance (BFC) selects subrecipients for fiscal monitoring, according to their risk levels. The higher an organization's risk level, the more likely it will be selected for monitoring. 

• FY 2024 Program Summary
• FY 2023 Program Summary
• FY 2022 Program Summary
• FY 2021 Program Summary

Subrecipient Monitoring Procedure (2019-2020)

Subrecipient monitoring for fiscal 2019-2020 was determined as a result of the FY21 Subrecipient Fiscal Risk Assessment. Subrecipients that were assigned a risk level of high were selected for monitoring, along with most subrecipients assigned a risk level of moderate/medium. 

Monitoring of the subrecipient must include a review of financial and performance reports, and follow-up to ensure the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity (NHED). 

The BFC's monitoring review includes:

• A review of federally required policies and procedures
• A review of activity reimbursement requests within the Grants Management System (GMS)

Required supporting documentation must be made available to review for each activity selected for review. The documentation supplied must, without a doubt, verify that the funds reimbursed to the non-federal entity from the federal award were spent on the goods or services as written within the GMS activity.

The results of each monitoring review are documented in a 'Draft Report' that is sent to the district/school contact that was part of the monitoring procedure. The district/school is given two weeks to respond to the 'Draft Report' with any comments, further supporting documentation, or corrections. Any comments, corrections, or further supporting documentation sent to the BFC is given consideration before the 'Final Report' is issued. If at the end of the two-week period, the district/school does not comment on the 'Draft Report', the 'Final Report' is sent to all applicable parties as written. The 'Final Report' is sent to the superintendent, business administrator/manager, monitoring contact (if not the business administrator/manager), and the school board.

If there are any documented findings (deficiencies) as a result of the BFC's monitoring review that are in the 'Final Report', then a corrective action plan (CAP) is required for each finding (deficiency). Corrective action plans are due back to the BFC within 30 days of the final report being issued. 

Below are the districts/schools monitored for fiscal year 2019-2020, within fiscal year 2021 and their subsequent 'Final Report' and 'Corrective Action Plan(s).'

2019-2020 Annual Fiscal Monitoring Reports and Corrective Action Plans