TITLE 44: GOVERNMENTAL CONTRACTS, GRANTMAKING, PROCUREMENT AND PROPERTY MANAGEMENT
SUBTITLE F: GRANTMAKING
CHAPTER I: GOVERNOR'S OFFICE OF MANAGEMENT AND BUDGET
PART 7000 GRANT ACCOUNTABILITY AND TRANSPARENCY ACT
SECTION 7000.340 GRANTEE RISK ASSESSMENTS – FINANCIAL AND ADMINISTRATIVE (ICQ) AND PROGRAMMATIC


 

Section 7000.340  Grantee Risk Assessments – Financial and Administrative (ICQ) and Programmatic

 

a)         Risk Posed by Applicants

 

1)         Review of Existing Recipient Information

 

A)        For a grant applicant who is a prior awardee, the State agency shall review available information on the awardee's prior performance. 

 

B)        The State agency shall look for information that demonstrates a satisfactory record of executing programs or activities under federal and/or State awards, Cooperative Agreements, or procurement awards, as well as integrity and business ethics.

 

C)        With written GATU approval, the State agency may issue a grant to an awardee that does not fully meet these standards if it determines that the nonattainment is not relevant to the current State grant under consideration or there are specific conditions that can appropriately mitigate the effects of the applicant's risk.

 

2)         In evaluating risks posed by applicants, the State agency must use a risk-based approach that considers, at a minimum, the following criteria:

 

A)        Financial stability;

 

B)        Quality of management systems;

 

C)        History of performance. The applicant's record in managing State grants or federal awards, including timeliness of compliance with applicable reporting requirements, conformance to the terms and conditions of previous grants/awards, and, if applicable, the extent to which any previous amounts will be expended prior to future grants;

 

D)        Reports and findings from audits performed on prior grants/awards;

 

E)        The applicant's ability to effectively implement statutory, regulatory or other requirements imposed on awardees; and

 

F)         Other information. The State agency must also evaluate the risks posed by applicants discerned during the application process.

 

3)         If the State agency determines that a State award will be issued notwithstanding the risks posed, the agency shall establish in the Grant Agreement specific conditions, corresponding to the degree of risk assessed, that reduce this risk. The program rules for the specific grant shall list the specific risk assessment criteria to be used. The grant announcement shall cross-reference this information.

 

b)         The UR identifies that the risk assessment as a pre-award requirement best practice. 

 

c)         Formula-funded, federally mandated and legislatively mandated awards are subject to risk assessment unless the terms of funding explicitly exclude a risk assessment.  A risk assessment exception must be approved by GATU and recorded in the CSFA pursuant to Section 7000.60.

 

d)         There are 2 types of risk assessments: Financial and Administrative Risk Assessment and Programmatic Risk Assessment.

 

1)         Financial and Administrative Risk Assessment.  An automated Internal Control Questionnaire (ICQ) is used to review past performance of fiscal and administrative conditions on prior awards and the applicant's ability to conform with federal and State statutory requirements.  The ICQ centralizes the fiscal and administrative risk assessment.

 

A)        An entity is required to complete the ICQ once annually.  All State agencies utilize the ICQ results. 

 

B)        The ICQ is a pre-award requirement.  The timing of the ICQ is dependent on when the entity applies for State fiscal year funding. 

 

C)        The entity initiates the ICQ from the Grantee Portal (www.grants.illinois.gov/portal).

 

D)        ICQ automation scores the questionnaire and assigns suggested specific conditions in response to the risk profile. 

 

E)        The State Cognizant Agency approves the risk profile and the subsequent specific conditions.  All agencies issuing awards to the entity will apply the specific conditions resulting from the ICQ risk assessment.

 

F)         Local governmental agencies that register and prequalify separately from the controlling local government must complete the ICQ at the agency level.

 

i)          Governmental agencies must have a unique DUNS number but the same FEIN as the highest level of local government to be eligible to register separately. 

 

ii)         Separate ICQs may be appropriate if governmental agencies are independent in their fiscal and administrative responsibility and reporting structure.

 

iii)        Specific conditions described in subsection (e) would apply to each ICQ. 

 

2)         Programmatic Risk Assessment.  Program-specific risk assessments evaluate the entity's ability to successfully carry out the terms of a specific program.  The assessment is customized based on the NOFO terms and the unique requirements of the grant. 

 

A)        An entity is required to complete the programmatic risk assessment as part of the application process.

 

B)        The grantmaking agency distributes the customized programmatic risk assessment questionnaire to applicants that have met all other qualifications for an award. 

 

C)        The grantmaking agency scores the completed programmatic risk assessment questionnaire and applies the specific conditions in response to the risk profile.  

 

D)        The grantmaking agency approves the risk profile and the subsequent specific conditions.  The specific conditions are applied to the Grant Agreement.

 

e)         Specific Conditions

 

1)         Within the Grant Agreement, the State agency shall impose additional specific grant conditions when:

 

A)        It determines, pursuant to subsection (d), that the applicant presents a significant amount of risk resulting from a significant deficiency and/or material weakness identified by the pre-award process;

 

B)        An applicant or recipient has a history of failure to comply with the general or specific terms and conditions of a State grant or federal award;

 

C)        An applicant or recipient fails to meet expected performance goals described in the Grant Agreement; or

 

D)        An applicant or recipient is otherwise judged to be not responsible.

 

2)         Additional State grant conditions may include items such as the following:

 

A)        Requiring payments as reimbursements rather than advance payments;

 

B)        Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within any timeframes established by the Grant Agreement;

 

C)        Requiring additional, more detailed financial reports;

 

D)        Requiring additional project monitoring;

 

E)        Requiring the awardee to obtain technical or management assistance; or

 

F)         Establishing additional prior approvals.

 

3)         The State grantmaking agency or pass-through entity will utilize the NOSA to notify the applicant regarding specific conditions as follows: 

 

A)        The nature of the additional requirements;

 

B)        The reason why the additional requirements are being imposed;

 

C)        The nature of the action needed to remove the additional requirements, if applicable;

 

D)        The time allowed for completing the actions, if applicable; and

 

E)        The method for requesting reconsideration of the additional requirements imposed.

 

4)         Awardees should utilize the Grantee Request to Remove a Specific Condition form when corrective action has been fully implemented. This form is available from the GATA Resource Library (www.grants.illinois.gov).

 

5)         In response to the awardee's request to remove a specific condition via the Grantee Request to Remove a Specific Condition, the applicable State agency will remove any specific conditions promptly once the agency Director or designee determines that the issues have been corrected.

 

A)        If the specific condition pertains to the ICQ risk assessment, the request must be reviewed by the State Cognizant Agency. The State Cognizant Agency shall determine if the implemented corrective action is sufficient and shall utilize the State Staff Inquiry Screen to remove the condition, if applicable. 

 

B)        If the specific condition pertains to a programmatic risk assessment or the merit-based review, the request must be reviewed by the State agency that issued the condition. The agency that issued the condition will determine if the implemented corrective action is sufficient and utilize the State Staff Inquiry Screen to remove the condition, if applicable.