An annual monitoring plan should identify the PJ's monitoring goals and strategies, highlighting areas that staff wants to pay special attention to during the monitoring year.
A PJ's monitoring efforts should be guided by both its responsibilities under the HOME Program and its affordable housing goals for the community. These monitoring efforts may include:
- Identifying and tracking program and project results;
- Identifying technical assistance needs of PJ, CHDO, and sub recipient staff;
- Ensuring timely expenditure of HOME funds;
- Documenting compliance with Program rules;
- Preventing fraud and abuse; and
- Identifying innovative tools and techniques that support affordable housing goals.
While all of these objectives are important, the emphasis on one or more of them may shift from year to year. For example, HOME monitoring staff may wish to give special attention to the technical assistance needs of CHDOs and other non-profit housing development organizations. Often, it will be necessary for PJs to prioritize monitoring goals based on the availability of staff and resources.
Well-designed monitoring strategies help PJ staff use the appropriate level of effort to ensure performance and compliance in each focus area. In general, a comprehensive HOME monitoring strategy involves a two-pronged approach.
A sufficient level of monitoring should be built into the PJ's service delivery system and be performed throughout the year. This will involve an examination of both routine and special reports from HOME program staff, housing owners/developers/sponsors, sub recipients, state recipients, and contractors. This information enables the monitor to assess performance and identify any compliance problems. The annual monitoring plan should identify the format and frequency with which internal and external staff will prepare project or program-related reports.
Based on the data submitted, monitoring staff may generate internal reports on the status of every HOME-funded activity. Program-wide data, such as the number of units developed, number of families assisted, and the ongoing expenditure amounts of HOME funds, should also be tracked. If questions or concerns arise, monitoring staff should request additional information from the appropriate source.
In addition to the ongoing monitoring they perform for all activities, PJs usually select certain HOME program areas or organizations for in-depth monitoring each year. On-site monitoring involves a visit to the program or project to gather specific information and observe actual program elements. On-site monitoring is especially appropriate if there is a strong likelihood of problems, or if a lengthy time period has elapsed since the last visit. During an on-site review, monitors evaluate overall performance and determine if compliance problems exist. Site visits often enable the monitor to identify aspects of the program or project that is contributing to a problematic situation. Monitoring staff must prepare and distribute a report summarizing the results of the review, and describe any required follow-up activity.
By using this two-pronged approach, PJs can define the scope of their monitoring based on the circumstances of individual HOME activities or partners. The oversight performed as part of its ongoing monitoring can identify potential problems early, prevent compliance violations and help improve performance. On-site monitoring usually provides the most comprehensive review because it allows access to actual project records, staff, and clients.
Use Risk Factors to Set Priorities
With limited staff and time resources, most PJs cannot perform on-site reviews of all HOME-funded activities or partners. Therefore, it is critical to carefully determine which organizations and program areas should receive the investment of staff time and attention required by an on-site review. A sound basis for making this decision is a risk assessment, in which program and monitoring staff evaluate the likelihood that a project, program or entity has violated HOME regulations, failed to comply with program requirements, or is open to fraud and abuse. This evaluation may also focus on activities that carry performance risk, such as poor housing unit production; a low number of residents assisted, or slow expenditures.
To learn more about how organizational and program risk can be used to help develop the annual monitoring plan, click on the following links: