Grants & Monitoring

The primary purpose of the Metro Denver Continuum of Care (CoC) is to carry out the responsibilities of a CoC as defined by the CoC Program Interim Rule (24 CFR 578). The Metro Denver Homeless Initiative (MDHI) is the board-appointed Collaborative Applicant and HMIS Lead Agency of the CoC. A significant part of these responsibilities is the creation and implementation of a Monitoring Plan for monitoring the performance of recipients and sub-recipients of CoC Program funding. This plan strives to improve outcomes for persons experiencing homelessness who are receiving assistance through these projects and achieve MDHI’s vision for everyone in the Metro Denver region to have a safe, stable place to call home.

The MDHI CoC must consult with recipients and sub-recipients of CoC and ESG [LH1][SH2] Program funding operating within the boundaries of the CoC (hereafter referred to as ‘grantees’) to establish performance targets, monitor recipient and sub-recipient performance, evaluate outcomes and act against poor performers. The Monitoring Plan will provide the necessary structure to comply with regulatory requirements and advance the Metro Denver CoC’s efforts to end homelessness across the region.

• Quarterly Monitoring: There will be quarterly monitoring that will focus on program drawdowns, HMIS data quality, narratives on program progress, etc.

• Program Monitoring: This type of monitoring will generally occur annually.

Monitoring results are kept on file for each project by the CoC. Results of monitoring are used to improve project and system performance, contribute data for CoC federal grant applications, and inform CoC funding eligibility and awards at federal, state and regional levels (i.e. CoC Notice of Funding Opportunity (NOFO) process).

Monitoring collectively provides CoCs the opportunity to see performance at a system-level, making it possible to see overall progress toward making homelessness rare, brief and one-time, as well as specific areas where performance improvement can enhance the CoC’s efforts.

MDHI will work with the Grantee to set a timeline for monitoring. Any onsite monitoring will be scheduled with advance notice. For any on-site visits, project staff should be ready to provide physical space and internet connection for MDHI staff, have participant files and financial documents (including back-up) readily accessible, and have relevant staff on-site to answer questions. Monitoring will happen over a four-month period:

• Starting Date:

  • Email Notification of Monitoring sent by MDHI, including what to expect and deadlines for submission of materials.

• Days 1-45:

  • Points of Contact will be identified.

  • Documents will be requested via the MDHI Monitoring Agency Response Form and deadlines for submission identified.

  • Requested Documents (include, but are not limited to)

    • The recipient/sub-recipient agency contract with HUD, relating to the project

    • Any prior HUD monitoring findings from the past 5 years

    • Financial records prepared for monitoring

    • A sample client intake packet

    • Up to 3 random client files [Encrypted, MDHI will send HMIS Unique Identifiers for files]

    • Appropriate Client file documentation

    • Agency Policies & Procedures

    • Any project policies and procedures (Standard Operating Procedures, etc.)

    • Example Tenant Leases

    • Tenant Selection Plans that document client eligibility, including Background Check Criteria

  • Other Requests of Grantee/Agency (include, but are not limited to)

    • Completed/Up-to-Date HMIS (or comparable database) data entry

    • Familiarization with HUD Exhibits noted on monitoring notification

• Days 46-75:

  • MDHI Reviews submitted materials and answers questions in CoC Monitoring Tool.

  • MDHI will schedule an on-site meeting with the agency and answer any remaining questions.

  • Once Monitoring is complete MDHI will provide any preliminary findings to the grantee to potentially resolve the findings before the final report.

• Days 76-100:

  • Grantees will have 15 days to respond to the findings and potentially resolve them.

• Days 100-115:

  • MDHI will prepare a Performance Improvement Plan (PIP) for any remaining findings.

  • MDHI will provide the Monitoring results to grantee along with the PIP.

All grantees are required to prepare and submit quarterly reports to MDHI via the CoC Monitoring email, cocmonitoring@mdhi.org. For CoC programs, we request one quarterly report for each CoC program. We do not require your subrecipients to report separately. Grantees should work with their subrecipients to ensure complete and accurate reporting. The content for quarterly reports is established by the CoC and includes, but is not limited to the following:

• Grantees will provide:

  • Quarterly reports of eLOCCS drawdowns grantees have submitted to HUD

  • Most recent APR (Annual Performance Report) by program

  • Current average caseload size for program

  • Monitoring narrative on program progress

• MDHI will pull:

  • HMIS Data Quality Report

  • OneHome ‘Housing Denial Report’ submitted for the quarter and will reach out with any questions/requests

Please review the Quarterly Report Instructions to understand how we want the data to be submitted and formatted. You can utilize the Quarterly Report Template to ensure full compliance with this request.

Submission Schedule: Metro Denver CoC Quarterly Reporting Periods

Please note: Reports and other information should only cover the most recently completed quarter as outlined in the Submission Schedule (see below). MDHI may require additional reports as determined by the MDHI Board of Directors, staff, and Continuum Performance Committee (CPC). Written notification for additional quarterly reporting requirements will be communicated to the agency executive director or their designee no later than thirty days before the start of the reporting period. Information submitted by grantees in quarterly reports will be used as part of the annual NOFO/NOFA review process. It may also be used to determine the monitoring schedule for grantees.

Grantees/Fiscal Agents are responsible for monitoring subgrantees. If you are a fiscal agent and have questions on how to monitor subrecipients quarterly, please email cocmonitoring@mdhi.org for further support.

If the grantee disagrees with monitoring results, they may complete an appeal, which will be reviewed by CoC staff and the Continuum Performance Committee (CPC). Appeals must be submitted no more than 30 days following receipt of monitoring results. The CoC Monitoring Appeals Form must be included, and the grantee may include other supporting documentation.

• Appeals will be submitted to the CPC for review. Grantees must continue to abide by any corrective action plan that is in place unless notified in writing by the CoC. Grantees will be notified in writing regarding the results of their appeal within 30-45 days.

• Regular check-ins will occur until the items identified in the Performance Improvement Plan (PIP) are resolved.

• CoC Program Law, Regulations, and Notices

• CPD Monitoring Guide (Chapter 28: ESG Program, Chapter 29: CoC Program)

• 2 CFR Part 200: Overview for Grantees

• Homeless Definition Recordkeeping Requirements and Criteria

• CoC Rapid Rehousing Standards for Denver CoC and ESG

• HUD Exchange