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33 <br />I nstitutional Structure <br />1. Describe actions that will take place during the next year to develop institutional <br />structure. <br />Orange County HOME Consortium Response: <br />With the creation of the Community Home Trust, Orange County, Chapel Hill, <br />Carrboro and Hillsborough demonstrated the desire to cooperate among the several <br />jurisdictions to provide the best housing assistance that will serve the low- income <br />residents of Orange County. With respect to coordination of resources, funded <br />agencies will communicate with appropriate staff regarding projects in progress, <br />applications submitted to state and federal funding agencies, programs that are <br />particularly successful or troublesome, and other sharing of information and sources <br />of funds. <br />Monitoring <br />1. Describe actions that will take place during the next year to monitor its housing <br />and community development projects and ensure long -term compliance with <br />program requirements and comprehensive planning requirements. <br />Orange County HOME Consortium Response: <br />To insure that each recipient of HOME, CDBG, and other federal funds operates in <br />compliance with applicable federal laws and regulations, Orange County and the <br />Town will continue to implement a monitoring strategy that closely reviews <br />subrecipient activities and provides extensive technical assistance to prevent future <br />compliance issues. <br />The Orange County Consortium will implement a risk analysis matrix for monitoring <br />all appropriate CDBG /HOME subrecipients for each Fiscal Year (FY). This risk analysis <br />closely mirrors the Community Planning Development (CPD) Notice 04 -01, Issued <br />February 2, 2004 and CPD Notice 02 -11, which delineates the relevant factors to <br />monitor for determining the risk level for the Consortium or subrecipients. Once <br />projects have been approved and subrecipients have been issued subrecipient <br />agreements, the staff conducts a four page risk analysis worksheet that looks at <br />Financial Capacity; Management; Planning and National Objectives. <br />Each subrecipient is graded and its score is listed in one (1 ) of three categories: low <br />risk: 0 -30 points; moderate risk: 31 -50 points; and high risk: 51 -100 points. Based <br />on the scoring for each subrecipient, the Consortium determines its annual <br />monitoring schedule based on the number of moderate and high risk subrecipients. <br />As a general rule, the staff will monitor on -site all moderate and high risk <br />subrecipients on an annual basis, typically at the midway point of the Fiscal Year. <br />Conversely, the low -risk subrecipients are monitored on -site every other Fiscal Year <br />during the same timeframe, and desk reviews are conducted throughout the year. <br />When a subrecipient's risk assessment calls for an on -site monitoring, the following <br />procedures are followed: <br />• The PJ reviews its own files on the subrecipient to be monitored, particularly <br />quarterly reports, performance agreements, and payment requests. <br />• A visit is made to the subrecipient. PJ staff meets with subrecipient staff, <br />reviews financial and administrative management, and visits program sites. <br />FY 2014 -2015 Action Plan 28 <br />