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Designing an Effective Subrecipient Monitoring Fra ...
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Video Summary
Stacey Massey, Deputy Director of Grants and Financial Reporting for Ohio's Office of Budget and Management, shares extensive insights on designing effective subrecipient monitoring frameworks to ensure compliance and prevent grant mismanagement. Drawing on her 26 years of experience, she emphasizes the critical importance of monitoring as both a regulatory requirement (per 2 CFR 200-332) and a stewardship responsibility when passing federal funds to subrecipients like local governments and nonprofits. Stacey highlights the different funding relationship types—subrecipients, contractors, and beneficiaries—and stresses the need to clearly identify each, as responsibilities and oversight differ.<br /><br />She underscores key components for pass-through entities, including verifying subrecipients are not suspended or debarred, issuing compliant sub-award agreements, conducting risk assessments (including fraud risk), reviewing audits, and continuously monitoring financial and program performance. Stacey warns against common pitfalls such as overreliance on trust without verification, inadequate risk assessments, lack of independence in monitoring, and failure to follow up on findings.<br /><br />Through real case studies—such as a $26 million Homeland Security grant mismanaged by a not-for-profit with significant unsupported costs—she demonstrates consequences of poor oversight and stresses the importance of professional skepticism. She explains using a figure skating analogy how grantor and subrecipient must function collaboratively like a synchronized team to succeed.<br /><br />Her recommendations include diversified monitoring techniques (desk reviews, site visits, data analytics, social media checks), timely corrective action plans addressing root causes, and use of specific conditions to mitigate risk. Stacey closes by encouraging continuous reevaluation of monitoring plans and fostering strong partnerships to ensure subrecipients’ success, which ultimately supports responsible grant management and protects organizational reputation.
Keywords
subrecipient monitoring
grant compliance
federal funds management
2 CFR 200-332
risk assessment
fraud prevention
audit review
pass-through entities
financial reporting
corrective action plans
stakeholder collaboration
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