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Monitoring is accomplished utilizing various methods including desk monitoring and on-site visits. There are two primary areas reviewed during monitoring activities - financial and programmatic monitoring. Financial monitoring primarily focuses on statutory and regulatory compliance with administrative grant requirements. It involves the review of records associated with the purchase and disposition of property, projects and contracts. Programmatic monitoring seeks to validate and assist in the grant progress, targeting issues that may be hindering project goals and ensuring compliance with the purpose of the grant and overall grant program. Programmatic monitoring involves the observation of equipment purchased, protocols and other associated records. Various levels of financial and programmatic review may be accomplished during the monitoring process. Pursuant to 2 C.F.R. § 200.337, the Division has the right, at all reasonable times, to make site visits or conduct desk reviews to review project accomplishments and management control systems to review award progress and to provide any required technical assistance. During site visits or desk reviews, The Division shall review recipients' files related to the award. As part of any monitoring and program evaluation activities, recipients shall permit the Division, upon reasonable notice, to review grant -related records and to interview the organization's staff and contractors regarding the program. Recipients shall respond in a timely and accurate manner to the Division's requests for information relating to the award. Monitoring Selection and Scheduling: Each year the Division shall conduct monitoring based on a "Risk Assessment". The risk assessment tool is used to help in determining the priority of Sub -Recipients that should be reviewed and the level of monitoring that should be performed. Note that although a given grant may be closed, it is still subject to either desk or on-site monitoring for a five (5) year period following closure. Areas that shall be examined inc • Management and administrative procedures; • Grant folder maintenance; Equipment accountability and sub -hand receipt procedures; • Program for obsolescence; Status of equipment purchases; Status of training for purchased equipment; • Status and number of response trainings conducted to include number trained; • Status and number of exercises; Status of planning activity; Anticipated projected completion; • Difficulties encountered in completing projects; • Agency NIMS/ICS compliance documentation; • Equal Employment Opportunity (EEO Status); • Procurement Policy The Division may request additional monitoring/information of the activity, or lack thereof, generates questions from the region, the sponsoring agency or the Division's leadership. The method of gathering this information shall be determined on a case-by-case basis. Monitoring Activities: Desk reviews and site visits are two forms of monitoring. Desk monitoring is the review of projects, financial activity and technical assistance between the Division and the applicant via e-mail and telephone. On-site monitoring are actual visits to the Sub -Recipient agencies by Division representatives who examines records, procedures and equipment. Desk monitoring is an on-going process. Sub -Recipients shall be required to participate in desk top monitoring as determined by the Division. This contact shall provide an opportunity to identify the need 111