In September 2014, the Government Accountability Office (GAO), an oversight arm of Congress, published a report (Action Taken to Train and Oversee Grantee Monitoring Staff, But Certain Guidance Could Be Improved) in which it found that despite efforts by HRSA to increase and improve its guidance and training related to monitoring grantees, key components of grantee monitoring are not included in the Standard Operating Procedures of certain individual HRSA bureaus. This lack of detailed policies is inconsistent with federal standards for internal controls and. According to the GAO, puts HRSA at risk for incomplete or ineffective grantee monitoring, which could jeopardize the stewardship of federal dollars.

The GAO report assessed the four HRSA bureaus with the largest number of project officers, largest number of active grants and greatest amount of grant awards in FY2013: the Bureau of Primary Health Care, Bureau of Health Professions, HIV/AIDS Bureau and the Maternal and Child Health Bureaus. The GAO examined:

1. The extent to which HRSA has developed guidance for staff responsible for monitoring grantees;
2. The extent to which HRSA has implemented training for its staff responsible for monitoring grantees;
3. HRSA’s oversight of its staff responsible for monitoring grantees; and
4. What practices, if any, HRSA has in place to ensure that the contractors conducting grantee monitoring activities are qualified and carry out their work as appropriate.

The GAO report found that HRSA has increased and improved its guidance and training related to monitoring grantees, including implementation of new training programs for key staff responsible for grantee monitoring and development of SOPs for staff at the agency and bureau level.

To assist in the development of SOPs by individual bureaus, HRSA provided a template outlining the key components of grantee monitoring. The key components included three main categories—communication, reviewing grantee reports and conducting site visits—each with specific components. While the report did not provide detailed findings by bureau, the GAO generally found that the bureau-level SOPs did not address all of the key components of grantee monitoring specified in the template. Of the SOPs reviewed, the GAO found that the components related to communication were most thoroughly addressed and those related to conducting site visits were least thoroughly addressed.

The GAO recommended that HRSA develop a process at either the agency or bureau level to ensure that bureaus’ SOPs address all of the key components of grantee monitoring. In response, HRSA stated that it has begun a process to ensure that specific bureau and office SOPs address the key components and that going forward, HHS policy will direct bureaus and offices to annually review and update their SOPs to reflect changes in legislation, policy, or program operations. HRSA is also establishing an annual process to discuss with the bureaus and offices post-award monitoring activities, best practices, and implementation of agency and government-wide changes.