|Revision Date||February 1, 2019|
Contract monitoring is an activity performed by contract staff within the DFPS contract management lifecycle. The objectives of contract monitoring are to ensure compliance with:
- Applicable state and federal regulations;
- DFPS policies, as applicable; and
- Terms and conditions of the contract.
Contract monitoring is distinct from general contract oversight, which is defined as routine contract management activities that have a structured emphasis on reviewing the operations and performance of a contractor.
DFPS requires a contractor to maintain financial, programmatic, and administrative records that adequately support goods and services provided in compliance with their contract terms and conditions. Significant or repeated noncompliance issues could indicate the contractor’s failure to provide adequate services, possible harm to clients, or inappropriate use of resources (see policy Contracor Noncompliance and Contract Remedies).
Contract staff must monitor the highest risk contracts as established by the Client Services and Administrative Specialized Monitoring Plans (SMP). In addition, contract staff are required to respond to contract events that may require an enhanced (see policy Review Reason) level of review. Contract staff must also respond to complaints (See policy Review Reason) against the contractor and follow-up (see policy Review Reason) on any unresolved systemic contract issues.
Monitoring Roles & Responsibilities
Contract Oversight and Support (COS) is responsible for:
- Coordinating annual review and maintenance of Risk Assessment Instruments (RAIs).
- Analyzing risk assessment data and publication of the Client Services and Administrative SMPs.
- Updating and maintaining monitoring policies in accordance with state and federal regulations.
- Training contract staff and providing technical assistance, as needed.
- Working with contract divisions to have enhanced monitoring events added to SCOR.
- Conducting quality assurance reviews on monitoring activities conducted by contract staff.
Contract Divisions are responsible for:
- Reviewing content and recommended modifications to the RAIs.
- Completing RAIs on all applicable contracts and data entry into SCOR of RAI data and related documentation.
- Completing monitoring activities on all contracts identified on the SMP (unless adjusted using the Form 9103 process) and ensuring all required monitoring documentation (see policy Reports and Documentation for Risk Based and Enhanced Monitoring) is uploaded into SCOR.
- Continually assessing risk of contracts and adjusting monitoring activities throughout the fiscal year, as needed.
- Adhering to all applicable DFPS monitoring policies.
- Developing monitoring tools based on the type and complexity of each contract.
- Documenting non-compliance and assessing and enforcing remedies.
- Communicating monitoring results and conducting applicable follow-up, as needed.
- Selecting in SCOR the monitoring reason (unless already identified via a risk based process and on the SMP), type , level and location as outlined below and in their respective policies.
Contract monitoring activities must be documented in SCOR, where monitoring is categorized by a review reason. Within SCOR, there are multiple reasons available for selection by contract staff, which are:
- Risk Based
Policy Review Reason provides details for each of the monitoring reasons.
For each monitoring event, contract staff must select a review type that can be determined by RAI scores (if applicable), performance analysis, and observations of the contractor. Contract divisions can focus on one or more of the following review types:
Policy Review Type details each of the monitoring types.
The monitoring level is determined by contract staff for each monitoring event and relates to the monitoring type and the depth of monitoring to be conducted. The options are as follows:
Policy Review Level details each of the monitoring levels.
The monitoring location is determined by contract staff. The options are as follows:
- Desk review
Policy Review Location details each of the monitoring locations.
Planning, Conducting, Concluding Monitoring
To complete a monitoring review, contract staff must prepare, perform, and conclude the monitoring review using applicable tools. Monitoring activities must be documented and a monitoring report is required to conclude a monitoring event.