Welcome to Grants Management – Monitoring Division
Required by federal and state mandates, Cal OES Grants Management Monitoring Division assesses Grant Subaward programs to verify that expenditures submitted for reimbursement are allowable, reasonable, benefit the Grant Subaward, and have been appropriately charged to the correct cost category. We also verify adequate policies, procedures, and systems are in place to manage Grant Subawards effectively.
Cal OES’ monitoring process assesses compliance with federal and state regulations and requirements and includes both office based and onsite activities. Monitoring focuses on providing technical assistance and guidance to validate or improve administrative and fiscal efficiencies in managing award funds. IF a misunderstanding of, or noncompliance with, federal or state regulations is discovered, assisting with a plan for corrective action to comply with the terms and conditions of the Grant Subaward is another function of the monitoring process.
Monitoring Process Overview
The Monitoring Division provides fiscal and administrative oversight of all Cal OES Grant Subawards through a review of an organization’s policies and procedures to ensure compliance with the rules, laws, and guidelines governing Grant Subawards. Cal OES accomplishes this oversight function through “monitoring.” The information below is provided to give you an idea of what monitoring is and how to prepare for a desk or onsite compliance assessment.
Desk Compliance Assessment
The desk compliance assessment focuses on all or part of a reimbursement request and involves a review of all related transactions and processes to verify that Grant Subaward funds were expended in compliance with federal and state regulations and the terms and conditions of the Subaward. The review is conducted via phone, mail, and/or email, although any equipment inspections that cannot be accomplished with photographic or other means of inspecting remotely, may require an abbreviated onsite visit. If a desk assessment identifies inaccurate expenditure reporting or misunderstanding of, or noncompliance with, federal or state requirements, the Program Monitor follows up with the Subrecipient to provide assistance in correcting any inefficiencies, errors, or policies/procedures. A Corrective Action Plan (CAP) is required for each finding. See below for more information on the CAP process. See below for more information on the CAP process.
Onsite Compliance Assessment
The onsite compliance assessment is the most comprehensive monitoring activity, focusing on one or more reimbursement requests, or expenditures across multiple reimbursement requests, in which Cal OES assesses the capability, performance, and compliance of subrecipients against applicable administrative and fiscal grant regulations and requirements. Onsite assessments are conducted by one or more Program Monitors and may be performed in conjunction with Cal OES Program staff. These assessments are not considered to be an audit. The goal of Cal OES’s onsite assessment process is to ensure the Subrecipient is aware of, and in compliance with, Grant Subaward requirements. Like desk compliance assessments, Cal OES works with Subrecipients to correct any inefficiencies, errors, or noncompliance with federal or state regulations. A Corrective Action Plan (CAP) is required for each finding. See below for more information on the CAP process.
Schedule (Questionnaire) Review
Periodically, a self-certification Schedule Review, consisting of a two-three page questionnaire, may be mailed out for Subrecipients to complete and return to Cal OES with requested supporting documentation. These questionnaire focus on a particular topic or topics related to policies, procedures and/or payments. If a response indicates a potential deficiency or noncompliance, the monitoring staff will follow-up with the Subrecipient to provide or request additional information, or to assist with any necessary corrections or changes. A Corrective Action Plan (CAP) may be required during this process.
The Monitoring Division does not monitor Subrecipients’ programmatic activities, or meeting goals or objectives of the Grant Subaward. This oversight and technical assistance are provided by Cal OES’s program administrators. Please visit the appropriate Grants Management area of the Cal OES website for further information.
Audit Requirements and Review
The Monitoring Division routinely monitors Single Audit reports for Subrecipients expending $750,000 or more in federal award funds during an organization’s fiscal year. We also review audited Financial Statements and Grant-Specific Audit reports for Subrecipients receiving less than $750,000.
These reports cover an independent auditor’s assessment of a Subrecipient’s fiscal processes and compliance with federal grant guidelines. If the auditor suggests there are areas for improvement or noncompliance with grant requirements, the monitoring staff will follow up with the Subrecipient to ensure that corrective actions are being taken.
For Subrecipients expending $750,000 or more in federal funds annually, a Single Audit report must be prepared and submitted within nine months after the end of an organization’s fiscal year.
Nonprofit organizations should send their Single Audits or any audited Financial Statements or Grant-Specific Audit reports electronically to Cal OES at: GMD@caloes.ca.gov
Audits can also be mailed to the address shown below:
Grants Management – Monitoring Division
California Governor’s Office of Emergency Services
3650 Schriever Avenue
Mather, CA 95655
Local Government and Indian Tribes should submit their Single audits to:
State Controller’s Office
Division of Audits
Financial Audits Bureau/Single Audits Unit
PO Box 942850
Sacramento, CA 94250-5874
Audit requirements may be found in 2 CFR Part 200 – Subpart F Audit Requirements
Process Documents, Forms and Checklists
There are different types of reviews performed by Cal OES monitoring staff to validate compliance, using a training and technical assistance approach. The document links below for each review type listed provide additional information.
Common Compliance Assessment Findings
- Lack of segregation of duties for smaller nonprofit organizations
- Inadequate policies for victim petty cash/financial assistance
- Single audit findings, audit reports submitted late, lack of required audits
- Inadequate monitoring of second tier subrecipients
- Improper/inadequate tracking and recording of Subaward costs
- Costs not allocated properly and/or Inadequate cost allocation plan
- Overcharging of office facility rent or indirect costs
- Inadequate/unsupported/unallowable required match
- Match not recorded or not identified in accounting records as match
- Match not claimed on reimbursement request as occurred
- Reimbursement requests not submitted timely
- Functional timesheets not used for Subaward Personnel costs
- Fringe benefit costs claimed in incorrect cost category
- Unsupported/unallowable Personnel costs
- Unsupported volunteer in-kind match claimed on reimbursement request
- Unsupported/unallowable operating cost items
- Lack of proof of payment of cost item(s)
- Cost claimed on reimbursement request prior to expending money
- Equipment inventory records missing required information
- Disposal data and information missing from records
- Physical equipment inventory/record reconciliation not performed
- Missing or unidentifiable equipment (onsite equipment inspections)
- Lack of written procurement procedures
- Lack of written code of conduct covering conflicts of interest in procurements
- Improper procurement
- Non-competitive procurement not justified/approved
- Procurement documentation not maintained
- Suspension/debarment not checked prior to awarding contract
- Competition requirements not met (quotes, bids, proposals)
- No cost/price analysis
- Lack of negotiating profit/discount when required
- Contracts/purchase orders do not contain all required provisions
Corrective Action Plans
As part of our monitoring activities, we may identify findings that require a Corrective Action Plan (CAP) to correct a deficiency in the way you are managing your Grant Subaward. A letter is sent detailing the finding(s) and asking for a CAP to be completed and implemented in a specific time frame. Subrecipients may elect to use Cal OES’ CAP form or a similar format of their own, provided that format includes the same information requested on the Cal OES form. You can download the CAP procedures and form below.
Grants Monitoring Brochure
Fraud Policy – You Should Have One
As part of effective internal controls, you should have an internal fraud policy that indicates the fight against fraud is endorsed and supported at the most senior level of your organization. It needs to be communicated to all employees (irrespective of grade, position, or length of service), contractors, and suppliers.