Thinking Globally on Proper Monitoring

March 4, 2013 | By Jerry Ashworth | Post a Comment

Rather than taking the easy route and focusing on the gloom and doom of the sequestration again (which, at the rate we’re going, will be around for a while), I thought I’d look elsewhere in the grants world for this blog post. And when I say “world,” this time I’m actually talking international. (Heck, this topic even gave me a chance to use the globe picture again!)

A recent report by the Department of Health and Human Services Office of Inspector General found that the Centers for Disease Control and Prevention’s South Africa office failed to consistently monitor recipients’ use of the President’s Emergency Plan for AIDS Relief (PEPFAR) funds. Call me naïve, but am I the only one that didn’t realize that CDC had a South Africa office? Any guesses as to which city? Bet most of you wouldn’t have said Pretoria.

Anyway, CDC launched PEPFAR to work with health officials in more than 75 countries to combat HIV/AIDS by strengthening health systems and building sustainable HIV/AIDS programs. CDC South Africa oversees PEPFAR funds awarded to recipients in South Africa.

The OIG audit found that CDC South Africa did not always monitor recipients’ use of PEPFAR funds in accordance with HHS and other federal requirements. While CDC South Africa did conduct a certain level of monitoring, OIG found that most of the recipient cooperative agreement files did not include required documents or evidence that CDC South Africa had monitored all cooperative agreements.

To make matters worse, CDC South Africa did not have written policies and procedures to help ensure that it consistently monitored the cooperative agreements for recipients in accordance with HHS and other federal requirements, according to OIG. It recommended that CDC South Africa implement standard operating procedures for monitoring recipients’ use of PEPFAR funds.

Following the review, CDC South Africa has since drafted standard operating procedures for managing cooperative agreements, including monitoring. Let’s hope that this helps improve its oversight. There’s a lesson to be learned here, especially for pass-through entities that are monitoring subrecipients. Especially these days where every dollar spent will be highly scrutinized, having written procedures for monitoring funds is critical.

Let us know your thoughts on preparing written monitoring procedures and if you have any advice.

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