You are here:

Oversight and Monitoring

Oversight and Monitoring

Subgrantee Monitoring | Vendor Monitoring | Benefit Payment and Tracking

Proper oversight and monitoring of LIHEAP funds is important in order to ensure compliance with federal and state LIHEAP policies, procedures and law. Monitoring can also be important in identifying additional controls and procedures that could strengthen a particular agency or the LIHEAP program overall.

States are responsible for monitoring the fiscal and program performance of their subcontractors and vendors. (See Fiscal Management for more information.) The LIHEAP statute, Section 2605(b)(10), says they must:

"provide that such fiscal control and fund accounting procedures will be established as may be necessary to assure the proper disbursal of and accounting for Federal funds paid to the State under this title, including procedures for monitoring the assistance provided under this title, and provide that the State will comply with the provisions of chapter 75 of title 31, United States Code (commonly known as the 'Single Audit Act');"

Additionally, states must ensure their own compliance with federal and state policies because these are subject to periodic monitoring by federal staff, as outlined in the LIHEAP statute Section 2608(b(1):

"The Secretary shall conduct in several States in each fiscal year investigations of the use of funds received by the States under this title in order to evaluate compliance with the provisions of this title."

Monitoring procedures vary widely among the states. States may conduct annual on-site reviews of every local administrative agency, or they may schedule these for every 2-3 years, depending on their budget and the number of agencies. Some states do a risk assessment and review agencies determined to be at risk more often. In lieu of on-site reviews, states may conduct periodic desk reviews where they check agency data in a centralized database, if applicable, or check agency invoices, monthly reports, and other paperwork for inaccuracies and anomalies.

On the programmatic side, states may review subgrantee procedures in the following areas:

  • Eligibility determination
  • Benefit determination
  • Outreach and community relations
  • Intake process
  • Application processes (regular assistance and crisis)
  • Payment and payment tracking processes
  • Vendor and landlord transactions
  • Coordination with other programs
  • Confidentiality of client data

On the fiscal side, states may include the following in their review:

  • Financial status reports
  • Accounting policy and procedure manuals
  • Separation of duties and internal controls
  • Cash receipt files and deposit slips
  • Bank reconciliation with canceled checks
  • Samples of paid invoices, including signatures and check copies
  • Time cards, including signatures and payroll register
  • Purchase orders
  • Cost allocation plans
  • Insurance and bonding policies
  • Subcontracts
  • Computer/data security

States may provide the local agency a written report documenting findings of each visit or desk review. The report should identify agency strengths and weaknesses, and, if applicable, establish a corrective action plan for improvement.

Following are examples of states' monitoring policies and procedures:

Subgrantee Monitoring

Vendor Monitoring

Benefit Payment and Tracking

  • CO - LEAP Monitoring to Detect and Prevent Improper Payments(PDF)
  • CO - LEAP Fraud Prevention and Detection (PowerPoint)