Safeguarding the CoC
By: Jennifer McEvilley, Compliance Director
The complex, often clinical nature of monitoring and compliance ensures two things:
1. that all our agencies are on track to fulfill their missions to end homelessness; and
2. that government funds and resources continue to be available, based on our ability to be as effective as possible.
Think of our Monitoring and Compliance team as the mechanics of the homeless system in Cincinnati, and our direct service providers as automobiles. We work with every Partner Agency (our cars) to ensure they’re running smoothly, identify any problems, and work to maintain the value of these programs so that people can get from Point A (homelessness) to Point B (housing).
Monitoring is a year-round process with many components that support efforts to ensure homelessness assistance and prevention projects are operated efficiently, effectively and in compliance with all applicable requirements. The Compliance staff at STEH works closely with a subcommittee of the Homeless Clearinghouse, and our Continuum’s CoC Board to:
– provide transparency to the process;
– assist in developing policies and procedures; and
– intervene when projects are not operating satisfactorily.
Each year, STEH conducts a “risk assessment” of every agency that receives federal or state funding through our organization in which we “check under the hood,” so to speak, of each agency. We measure risk by reviewing factors such as annual audits, performance outcomes, amount and types of funding, and more. Taking a close look at each agency allows STEH to measure each agency in comparison with each other. An additional risk assessment is completed before each site visit, allowing STEH to develop a unique monitoring strategy for each project that pays special attention to areas of potential vulnerability or areas requiring improvement.
Before monitoring on-site, STEH reviews written policies and procedures pertaining to an agency’s’ programmatic and financial management of their projects. This gives STEH the opportunity to:
1. carefully review the policies while considering the program requirements; and
2. learn how each agency should be functioning per their policies and procedures.
For instance, if our metaphorical car has a Check Engine light on, we need to calibrate our procedure so we don’t fix a Ferrari with the same tools needed to fix a Ford.
During each annual on-site monitoring, STEH interviews agency staff, and reviews participant records and expenditure documents. Each three-day monitoring assessment begins with an entrance conference in which STEH and the agency get to talk and collaborate about the condition of the policies and procedures and (most importantly) challenges the agency may be experiencing. By providing technical assistance, as appropriate, to each and every subrecipient year-round, STEH creates an environment where agencies can talk about struggles and work with us to explore options for solutions.
To conclude our on-site visit, STEH sits down for an exit conference, sort of like test driving a vehicle after servicing it. It’s our goal to have discussed every issue prior to or during the exit conference. This is done so that each agency understands any issues, is in agreement with those issues, and is enabled as an agency to begin corrective action as soon as possible with what is called a “subrecipient action plan,” which is created and reviewed so that our homelessness system can be run more effectively. That plan is sent back to STEH for any issues listed as a Concern, and then we follow up until all Concerns are resolved.
To make sure our efforts are reasonable, equitable and consistent, STEH partners with a Monitoring Subcommittee that reviews every Monitoring Letter that goes out and every Subrecipient Corrective Action Plan. They provide updates to the Homeless Clearinghouse, and meet with agencies regarding the resolution of issues of noncompliance.
Our mission, as always, is to lead a coordinated community effort to end homelessness in Greater Cincinnati.
Monitoring is a critical component all our collective efforts to end and prevent homelessness in Cincinnati and Hamilton County. Through this process, STEH and the Monitoring Subcommittee are able to demonstrate to our funders (HUD, the City of Cincinnati, and Hamilton County, among others) that STEH provides proper oversight to funded projects, provides needed technical assistance, and ensures improvement or correction where needed.
Our dedication to compliance is fueled by the belief that when these programs are operated in compliance with their requirements, not only will they be able to show the funders their effectiveness in better serving the homeless population, but that ultimately the participants these projects serve will receive the high-quality assistance they deserve.
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