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(2) RECOMMENDATION A problem was identified in this area of the review which is not a matter of compliance but is based on the monitors’ observations of program structure suggestions, procedural designs or other information and suggestions by the state.

(3) REQUIREMENT

A problem was identified which is a matter of compliance with the legal, regulatory or contractual obligations of the sub grantee. Requirements must cite a source for the statements by the monitor. Sources may include the sub grantee’s contract, the State Plan, federal or state laws and other regulations.

The monitoring report section listing issues in each major review area is then followed by a listing of each case file reviewed. The list of case files, identified only by case number, should state “No issue” or detail the specific deficiency of issue found in the case. Finally, the report should state the due date of the sub grantee’s response, 30 days following the issuance of the report. 705. SUBGRANTEE MONITORING The sub grantee will also have responsibility to ensure that the energy assistance benefits are issued accurately to eligible households and that the circumstances of the case are fully documented. The sub grantee should implement a system in which a percentage of cases are immediately reviewed by a second party, prior to the issuance of the benefit, as a means of continuous quality improvement in their program. The review of the case should be conducted by an intake supervisor trained in policy rules. The second-party review is specifically to check for: - the completeness and accuracy of the application, - the verifications of the household information given, - the accurate determination of eligibility, - computations and documentation of income, - the accuracy of the computation of benefits, and - the general completeness of the case file. The second-party review should be noted in the case file for future monitoring.