Keeping Your Monitoring Program on Track with a Compliance Matrix
Among the many tools in your program's compliance monitoring toolkit is the Compliance Matrix. Like other grants monitoring tools, the Compliance Matrix (also called the “Monitoring Rubric”) contains a set of indicators—or standards—to be monitored, with the legal citation for each. But a Compliance Matrix goes further than most monitoring tools. Depending on the model used, it may include monitoring methodologies, evidence to support each finding, sample finding language, the role of questioned costs in fiscal reviews, sampling rules, and step-by-step directions for monitoring each indicator.
Central to the Compliance Matrix is the inclusion of descriptions for each monitoring requirement and the relevant legal citation. Whether you're using Excel or a robust grant monitoring software, we recommend the citation include hyperlinks to governing documents and that it be called out in a highly visible way. Displaying citations prominently makes Monitors' jobs easier and ensures this important component of the monitoring process is not overlooked.
The Compliance Matrix is not solely a training tool for Monitors. It also establishes expectations at the beginning of the monitoring season. Gaining buy-in on the Compliance Matrix from agency program leaders at the start should alleviate the need for confusing, time-consuming, and costly changes further along in the process.
Building Your Matrix
Let’s look at a sample model of a Compliance Matrix. In this model, indicators are divided into three categories:
Applicability refers to:
Grants being monitored
Type of Grantee e.g. charter school vs. district-operated school, day care center vs. home visiting program, non-profit vs. for profit organization
Type of Review e.g., site visit, desk review, videotaped observations
Monitor Instructions include:
The compliance question being asked.
Basic steps the monitor must undertake to answer the question.
Documents to review online and/or request from the grantee.
Whether the indicator requires a sampling of files, positions, purchase orders, or other transactions.
The sampling requirements (if sampling is required) i.e., the percentage of files, positions, or expenditures to review.
For fiscal reviews, whether the indicator may result in Questioned Costs. (That’s because grantee non-compliance results in Questioned Costs for some indicators, but not others. For example, an internal control weakness does not meet the definition of a Questioned Cost, but does result in a finding.)
This section contains a master library of content that monitors will use in the monitoring reports. In a highly prescriptive grants monitoring model, it contains:
The name of the report section.
The indicator title.
A description of the indicator.
The legal citation for the indicator.
A sample finding that can be edited by the monitor.
Typical evidence used to support the finding. If a chart is used, the Matrix provides the headings for each element of the chart.
A recommendation that aligns with the finding.
Sample language for a Corrective Action Plan.
Sample language for Technical Assistance to the grantee.
Using Your Matrix
Now that you’ve documented all this useful information, what’s the best way to use it?
1. To obtain leadership buy in and set expectations.
A shortened version of the Compliance Matrix can be used as a discussion document to gain buy-in from the leadership of the pass-through agency at the beginning of the program. Ensuring that leadership and the monitoring team are on the same page from the beginning saves time otherwise spent redoing reports to address unexpressed expectations later.
2. To provide a framework for conducting monitoring reviews and shape document requests.
A full working version of the Compliance Matrix gives monitors a framework for conducting their monitoring reviews and shapes document requests to grantees. By providing well-written sample findings, the Compliance Matrix—with its companion tool, the report template—enhances the quality of the review. But its true value arises in the thick of execution, a time when every monitoring program encounters obstacles not present during the inception of the program, including previously overlooked or recently changed nuances in interpretation or methodology.
Although changes should be kept to a minimum, some are unavoidable. For example, two monitors may access inventory data in a grantee’s Oracle financial system in different ways—and during staff discussions, they discover that one way is more efficient and informative. The wording of a regulation may change slightly, affecting what constitutes a finding. Monitors might learn that grantees received instructions about a matter that, once known to Monitors, changes their interpretation of the program requirements.
The Compliance Matrix provides a living document to accommodate these changes. It lays out a framework, then provides step-by-step instructions for each indicator that may be reviewed in your regularly scheduled meetings with the monitoring team. If you aren’t holding regular meetings, we highly encourage you to do so: this gives Monitors the opportunity to bring valuable information in from the field about where their instructions are vague and need more detail. It also provides a forum for suggesting efficiencies, debating grey areas of the law, and sharing technical assistance resources. These “mini lessons” can then be captured in the Matrix, providing an up-to-date, single source of truth for all parties to work from.
Ultimately, this example is only one of many models for developing a Compliance Matrix. Regardless of which one you use, the purpose of the Matrix remains the same: to ensure quality, efficiency, and consistency in monitoring methods and interpretations.
To learn more about how other grant management and monitoring professionals organize their Monitoring Rubrics, join the ongoing discussion in the Grants Oversight and Compliance industry group, available on both LinkedIn and Facebook.
For more resources on building your monitoring program or to engage expert help, please visit www.VanderWeeleGroup.com.