Authority/Reference(s) Texas Human Resource Code, Title 2 § 40.058 (c); Uniform Grant Guidance (UGG) §200.302, §200.400; §200.303
Revision Date February 1, 2019

Policy

For each monitoring event, contract staff must determine the focus of review as programmatic, administrative, or fiscal. Selection of a monitoring review type should be determined by RAIs scores (if applicable) and performance analysis.

If the focus of the monitoring event is more than one review type, the “combined” option in SCOR must be selected.

Regardless of the selected review type, contract staff are required to use the current monitoring tools.

Programmatic Monitoring

Programmatic monitoring refers to the monitoring type that reviews the services that are being provided through the terms of the contract (e.g. client service, community based services). DFPS must identify goals and outcomes for the services provided to clients.  Human Resources Code §40.058 states:

“…A contract for the purchase of program-related client services must include: ….clearly defined goals and outcomes that can be measured to determine whether the objectives of the program are being achieved...”

Contract staff are required to monitor performance as outlined in the service description and requirements in the statement of work to ensure compliance with the contract.

Administrative Monitoring

Administrative Monitoring refers to the monitoring type that reviews the operations and contractors’ management of the DFPS contract. To assess adherence to contract requirements, administrative monitoring activities may include, but are not limited to:

  • Reviewing credentialing and personnel files to verify required training, background checks, qualifications, and licensure.
  • Reviewing governance structure, internal controls, required insurance, operating and business procedures, including subcontracting, if applicable.

Fiscal Monitoring

Fiscal Monitoring refers to the monitoring type that reviews contractor compliance with fiscal obligations. DFPS must identify the fiscal obligations of the contractor and ensure they are clearly specified in the contract. Human Resources Code §40.058 states:

“…A contract for the purchase of program-related client services must include: ….clearly specified accounting, reporting, and auditing requirements applicable to money received under the contract.”

Ongoing fiscal monitoring may include, but is not limited to:

  • Review of the contractor's financial management systems to test for:
      • Accountability and proper documentation for DFPS' dollars spent.
      • Sufficient cash on hand and procedures in place to sustain operations. The industry norm is 60-90 days operation without further funding.
      • Proper and standard financial management and accounting procedures in place and utilized.  These financial management and accounting procedures should adhere to the contract terms and conditions, the Uniform Grant Guidance (UGG) and Uniform Grant Management Standards (UGMS), and the Human Resources Code.
      • Sufficient internal controls as defined by §200.303 of the UGG in place and enforced.
      • Allowability of expenditures per UGG and UGMS.
  • Review and reconciliation of contractor's invoices submitted for payment (e.g. using billing review as outlined below).
  • Analysis of financial reports that assess the current financial viability of the organization, such as:
      • Financial statements.
      • Annual independent audit.
      • A single audit, when required.
  • Review of contractor's adherence to proper payment of subcontractors, when applicable.

Risk Based Fiscal Monitoring

When conducting risk-based fiscal monitoring, contract staff are responsible for identifying transactions to be tested and documenting the results using the fiscal monitoring tool developed by the Contract Division.

The process and requirements for fiscal monitoring are dependent on the payment type of the contract being monitored.

Billing Review

A Billing Review is an activity conducted by contract divisions that satisfies the requirements of fiscal monitoring when specific conditions are met.  Billing review refers to the regularly conducted review of contractors' billings.

Contract staff may monitor a contract using the billing review when all four of the following conditions are met:

  • The billing Invoices for the contract are routinely reviewed as a normal contract management practice, regardless of whether or not the contract has been scheduled for monitoring on the State Monitoring Plan (SMP).

To meet this condition, contract divisions should initiate the billing reviews with the first billing of the fiscal year and continue the billing reviews for the entire fiscal year.

  • The contractor submits all appropriate and necessary back-up documentation (e.g., receipts, invoices, etc.) to support expenditures with each billing, and there is no other supporting documentation to review on-site with the contractor.
  • The contractor provides a service for which on-site programmatic testing is not necessary or not possible.
  • There is an assigned DFPS staff responsible for certifying the delivery of service.
When the conditions above are met, a billing review is acceptable.