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Risk Level Tool & Assessment

Financial Risk Designation
Programmatic Risk Designation
Appeal Process

The CVAD Risk Assessment Tool assesses both financial and programmatic risk for CVAD subrecipients. The results from the risk assessment dictates appropriate financial and programmatic monitoring for each agency and/or funded project.
At the beginning of each grant cycle, CVAD staff (community specialists and accountants) will complete a financial risk assessment for each CVAD funded agency and complete a programmatic risk assessment for each CVAD funded program/project. 
Agencies will be notified of their risk designation. If an agency does not agree with CVAD’s risk assessment designations, there is an appeal process. For more information, please refer to the Appeal Process section of this Chapter.


Financial Risk Designations

An agency’s financial risk designation will stay in place for the entire 3-year grant cycle. For consistency, when CVAD assigns the financial risk designation to an agency, the claim submission rules apply to ALL of the agency’s CVAD funded programs/projects, even if the agency has CVAD funded programs that are not VOCA funded programs/projects. CVAD reserves the right to raise any risk designation should new information be discovered; however, the risk designation will not be lowered.
The following are some of the factors considered when assessing financial risk:

  1. Total award amount
  2. Percentage of CVAD funding for agency budget
  3. Percentage of award reversions
  4. Late submission of invoices
  5. Previous grant award experience
  6. Oversight by other agencies
  7. Budget revision history
  8. Significant findings or other concerns from prior audit(s)

Each question in the CVAD Risk Assessment Tool is worth a certain number of points. Based on the total points scored, the agency is designated as either high risk, medium risk or low risk. The higher the score, the higher the assumed financial risk. 

Risk Designation and Resulting Monitoring

HIGH RISK: Agencies designated as high financial risk will be required to comply with the following for all of their CVAD funded programs: 

  • Provide 100% supporting documentation for the following expenses with every claim:
    • Payroll and benefits 
    • Client assistance expenses   
    • Sensitive minor equipment with an individual cost greater than $500 (equipment includes computers, calculators, copiers, etc.) 
    • Match 
  • Agency will receive at least one desk review each fiscal year, to review at least two months of all reimbursements and/or an in-depth review of up to 50 individual line item costs, with all supporting documentation for each method. CVAD staff will not ask to review documentation they already reviewed. 
    • Agency will receive at least one on-site financial monitoring visit every two years. 

MEDIUM RISK: Agencies designated as medium financial risk will be required to comply with the following for all of their CVAD funded programs: 

  • Provide 100% supporting documentation for the following expenses:  
    • Payroll 
    • Client assistance expenses 
    • Match 
  • Agency will receive a minimum of one desk review each fiscal year to review at least one full month of all reimbursements and/or an in-depth review of at least 25 line item costs with supporting documentation for each method. CVAD staff will not ask to review documentation they already reviewed. 
    • Agency will receive a minimum of one financial on-site monitoring visit every two years. 

LOW RISK: Agencies designated as low financial risk will be required to comply with the following for all of their CVAD funded programs: 

  • Provide 100% supporting documentation for the following expenses:  
    • Client assistance expenses 
  • Agency will receive at least one desk review each fiscal year to review at least one full month’s reimbursement or an in-depth review of at least 25 individual line item costs with supporting documentation. 
    • Agency will receive at least one on-site monitoring review every three years. 

The risk category an agency is assigned, guides the frequency and intensity of its financial monitoring. Staff will use their professional judgment and experience working with an agency to determine the frequency and intensity of additional monitoring. 


Programmatic Risk Designations

An agency’s programmatic risk designation will stay in place for the entire 3-year grant cycle. CVAD reserves the right to raise any risk designation should new information be discovered; however, the risk designation will not be lowered.
Programmatic risk assessment scores determine if programs within agencies are considered high, medium or low programmatic risk. Agency programs are evaluated based on programmatic risk assessment questions in the CVAD Risk Assessment Tool. CVAD staff assess points for each question. Based on the total points scored each agency is designated as high risk, medium risk or low risk. Some of the risk factors considered when assessing risk are:

  1. Administrative capacity
  2. Programmatic goals
  3. Reduction in clients served
  4. Quality of service
  5. Other programmatic concerns

Risk Designation and Resulting Monitoring

HIGH RISK: Programs designated as high programmatic risk will be required to comply with the following: 
• Participate in mandatory hands-on or specifically designed training and technical assistance that addresses a program’s deficiencies as designated by CVAD staff. 
• Participate in annual on-site programmatic monitoring to monitor activities to ensure the subaward is used for authorized purposes and is in compliance with federal statutes, regulations and the terms and conditions of the subaward and subaward performance goals are achieved. 
• Work with CVAD staff to develop an agreed upon management plan to increase programmatic outcomes and goals 
• Work with CVAD staff to follow up and report on the management plan and its successful progression. 
MEDIUM RISK: Programs designated as medium programmatic risk will be required to comply with the following: 
• Work with CVAD staff to determine how training and technical assistance could improve programmatic deficiencies. 
• Participate in an on-site monitoring visit every two years to monitor activities to ensure the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward and subaward performance goals are achieved. 
• Work with CVAD staff to develop an agreed upon management plan to increase programmatic outcomes and goals. 
• Work with CVAD staff to follow up and report on the management plan and its successful progression. 
LOW RISK: Programs designated as low programmatic risk will be required to comply with the following: 
• Participate in an on-site monitoring visit every three years to monitor activities to ensure the subaward is used for authorized purposes, in compliance with federal statues, regulations and the terms and conditions of the subaward and subaward performance goals are achieved. 
The risk category an agency is assigned, guides the frequency and intensity of its financial monitoring. Staff will use their professional judgment and experience working with an agency to determine the frequency and intensity of additional monitoring. 

Appeal Process

Agencies have the right to appeal their risk assessment decision. To file an appeal, the agency’s authorized official must send an email to the VSS administrator outlining a request to appeal the risk assessment decision. 
The agency’s authorizing official must detail reasons for the appeal as well as provide additional documentation to substantiate the reason for the appeal. 

Agencies must appeal within 7 business days of receipt of notice of risk assessment designation. The VSS administrator, in conjunction with the CVAD director will accept, reject or negotiate the appeal and will respond within 7 business days. 

  • If the appeal is accepted, CVAD will complete a new risk assessment and offer a revised risk assessment designation and subsequent monitoring plan. 
  • If the appeal is rejected, CVAD will notify the agency and will work with the agency to address its concerns as outlined in the appeal. 
  • If the appeal is negotiated, CVAD and the agency will work together to potentially change some issues outlined in the appeal, while holding firm other issues/concerns from the agency. 

Each risk assessment decision and each appeal is to be considered on a case-by-case basis, while maintaining integrity and fairness throughout the process. The determination of the CVAD director/VSS administrator constitutes final agency action.
 

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