Fiscal & Administrative Review Assistance for IDHS Providers: IDHS Subrecipient Monitoring

Fiscal Administrative Reviews IDHS Subrecipient Monitoring N-9/22

Providers funded by the Illinois Department of Human Services (IDHS) may subcontract with other providers (subrecipients) to meet the terms of the Uniform Grant Agreement (UGA). All subcontracts must reflect the standard contract language included in the IDHS Uniform Grant Agreement and the Funding and Service Level form in connection with the Program Plan. Subcontracts must have IDHS approval.

The provider's written procedures for subrecipient awards should include procedures that describe the monitoring requirements and document compliance of their subrecipients (2 CFR 200.331(a)).

The provider is required to assess risk of subrecipients and impose special conditions to mitigate certain risks. The protocol for risk assessment should address the following:

  • The grantee should have developed and documented procedures that provide for a risk assessment of all subrecipients
  • Specific conditions to mitigate risk factors identified in the risk assessment process

Providers are responsible for monitoring the subrecipient agency to assure meeting both Funding and Service Level. The grantee's documented subrecipient policies and procedures should include details of the subrecipient monitoring requirements, including type of monitoring required and due dates. These requirements must match the requirement imposed on the grantee. The following should be included in the protocol regarding subrecipient monitoring requirements:

  • Grantee's Subrecipient Policy and Procedure
  • Evidence of subrecipient monitoring and desk review of monitoring
  • Risk assessment tool
  • Frequency of monitoring
  • Qualifications of personnel conducting monitoring activities
  • Monitoring report issuance and administrative decisions made
  • Repayment of disallowed expenditures
  • Corrective Action Plan(s), implementation, and follow up

The provider is required to have documented protocols for monitoring that should include both programmatic as well as fiscal/administrative monitoring. It must ensure that deliverables are being met and the overall viability of the organization. Elements of the Review Protocol should address the following:

  • Issues identified through the monitoring must communicated with the subrecipient through a report
  • Issues identified should require a Corrective Action Plan for all reported findings
  • Issues identified should be tracked to assure the CAP implementation