Reviewing Program Performance and Compliance
Reviewing Program Performance and Compliance
Performance measurement is an organized process for gathering information to determine how well programs and projects are meeting needs, and then using that information to improve performance and better target resources.
It is important for jurisdictions to periodically review their programs to ensure production and accountability, and to ensure compliance with HOME, CDBG, and other Federal requirements. In addition, reviewing program performance is not a one-time event; jurisdictions should conduct a thorough review of their programs at least annually to make sure the programs remain an effective source of services for low-income households.
There are several reasons jurisdictions should consider using performance measurement as a tool to better manage their programs. These reasons include:
- Much of the data needed to improve performance is already being collected by staff members or through computerized systems such as IDIS.
- The jurisdiction’s capacity to utilize program funds more effectively will make it possible to stretch HOME and CDBG dollars to assist more low-income households.
- Having good information and being able to demonstrate success allows jurisdictions to promote and defend their programs to elected officials and the public in general.
- Reviewing program performance can allow for better informed long-range planning, and it may generate data that will simplify preparation of the Consolidated Plan and annual reports.
- Reviewing program performance helps jurisdictions detect and address errors or problems, which can otherwise be both costly and frustrating.
One way that jurisdictions can demonstrate program effectiveness is to establish a system to formally monitor their programs and track progress. There are two ways to conduct a program monitoring review— desk review and on-site review.
Desk Reviews. Desk reviews are a key component of basic monitoring activities. They involve examining information and materials provided to jurisdictions by funding recipients, as a means to track performance and identify potential problem areas.
Staff performing desk reviews should examine progress reports, compliance reports and financial information, to adequately assess performance and look for indicators of performance or compliance problems. If questions or concerns arise from the review, staff should gather additional information through telephone calls or additional documents and other written materials.
On-Site Reviews. There are three steps that comprise the basic framework of conducting an on-site program monitoring review. Jurisdictions should use these steps as guidance when undertaking on-site reviews, including reviews of subrecipients.
- Step 1: Prepare for the Monitoring Visit. Before the monitoring visit, jurisdictions should make sure staff is adequately trained for this task. Staff should be thoroughly familiar with the applicable program rules and the established monitoring protocol. In addition, staff should review the following types of in-house data prior to the visit:
- Application for funding;
- Written agreement;
- Progress reports;
- Draw-down requests;
- IDIS reports;
- Previous monitoring reviews; and
- Copies of audits.
- Step 2: Conduct the Monitoring Visit. There are four basic elements to conducting an on-site monitoring visit:
- Notification—jurisdictions should call funding recipients to explain the purpose of the visit and to agree upon dates for the visit. A formal notification letter should follow at least several weeks before the planned visit.
- Entrance conference—jurisdictions should hold an entrance conference at the beginning of the site visit with the top official of the organization to make sure everyone has a clear understanding of the purpose, scope, and schedule for the visit.
- Documentation, data gathering and analysis— jurisdictions should keep a clear record of information reviewed and conversations held with staff during the visit.
- Exit conference—jurisdictions should meet again with the top official of the organization at the end of the visit to present any preliminary results and to secure any additional information to clarify or support the programs that were reviewed.
- Step 3: Follow-Up. At the end of the process, jurisdictions should provide the funding recipient with formal written notification of the results of the monitoring review. This letter should both point out problem areas and recognize successes.
Corrective Actions. Jurisdictions are responsible for taking appropriate actions when performance problems arise. Written agreements should be the primary mechanism for enforcement in situations of noncompliance.
There are three increasingly serious stages of intervention. A jurisdiction’s response to monitoring findings will depend upon the seriousness of the performance problem.
- Stage 1: Low-level Intervention. At this stage, jurisdictions should clearly identify problem areas and required corrective actions; plan a strategy with the funding recipient that includes any training or technical assistance that may help address identified problems; require more frequent or more thorough reporting; or conduct more frequent monitoring reviews.
- Stage 2: Moderate-level Intervention. Jurisdictions may need to take increasingly tougher steps such as restrict payment requests; disallow certain expenses or require repayment of funding provided for certain expenses; or impose probationary status.
- Stage 3: High-level Intervention. Jurisdictions must take the most serious actions to put an end to performance problems. Suggested steps during this stage include: temporarily suspend the organization from participation in either the HOME or CDBG program; do not renew the organization or activity for the next program year; terminate the organization or activity from the current program year; or initiate legal action.
Incorporating Training and Technical Assistance. As stated earlier, reviewing program performance should not be a one-time event. To be an effective tool for avoiding problems and improving performance, monitoring should be an ongoing process of planning, implementation and follow-up.
In order to avoid future problems with funding recipients, training and technical assistance should be an ongoing feature of jurisdiction programs. There are three basic approaches, that taken together, focus on enhancing performance and reducing common problems among funding recipients.
- Orientation sessions, typically held at the beginning of a funding cycle, provide a forum for discussing basic requirements and procedures, and to discuss expectations about performance.
- Training, typically aimed at larger audiences, focuses on specific issues and provides sufficient technical detail necessary for funding recipients to understand and implement program requirements. Training should be held throughout the year, and should enhance performance and long-term capacity of funding recipients.
Technical assistance, typically provided in a one-on-one or small group setting on-site, is designed to correct a specific weakness or to improve the quality or performance of a specific program already underway.
Consulting Services We Provide
- Review public works preconstruction contracts
- Monitor DIR contractor/subcontractor certified payrolls
- Audit labor classification for each worker employed
- Review DIR pre-DAS 140/142 submissions
- Review CAC training fund contributions form CAC-2
- Review DIR Fringe Benefits Statement PW-26
- Monitor DIR wage determinations
- Audit fringe benefits allowances
- Review DIR holiday payment requirements
- Audit DIR travel & subsistence requirements
- Caltrans Labor Compliance
- County of Sacramento Labor Compliance
- City of Los Angeles Labor Compliance
- Los Angeles Unified School District Labor Compliance
- Federal Davis-Bacon Project Monitoring
- Federal DBE Implementation & Review
- Federal FAA AIP Goal Setting
- DIR & Davis-Bacon Training
- DIR Civil Wage Penalty Review
- Local-Hire Review (e.g., San Francisco)
- Skilled and Trained Workforce
Give us a call to discuss your labor compliance requirements.
This email is intended for general information purposes only and should not be construed as legal advice
or legal opinions on any specific facts or circumstances.