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Tennessee Housing Development Agency 2025 LIHEAP Policy Manual for Regular and Crisis Assistance 52

5. Monitoring and Enforcement • THDA will monitor expenditure rates monthly and review compliance against the spend down calendar above. • Subgrantees who fail to meet spend down expectations may be subject to fund recapture, or additional allocations will be suspended. • Recaptured funds will be redistributed to higher-performing subgrantees meeting or exceeding benchmarks. • THDA staff will engage with subgrantees regularly to review progress, address expenditure challenges, and coordinate any reallocations. • A final, detailed funding release and monitoring schedule will be issued once contracts are executed.

7.3 Contract and Amendments Subgrantees must comply with all terms and conditions outlined in their current contract, as well as any subsequent amendments. All submitted expenditures will be reviewed in accordance with the approved budget. Subgrantees that do not meet their spend down timelines will face the risk of having their funds withdrawn and reallocated to subgrantees who are meeting or exceeding these benchmarks.

7.4 Budget and Budget Amendments All LIHEAP budgets and budget amendments must be submitted for review and approval through SmartSimple software system. The initial budget for a new allocation must be submitted prior to the contract and the Authorized Signature Form. Budgets must be approved prior to any expenditure of funds. • Budget revisions must be submitted if expenditures for any one-line item exceed the allocated amount. • A budget revision is needed when expenditure exceeds a line item in an invoice. THDA through SmartSimple will reject the invoice until the budget is revised. • All LIHEAP budgets/amendments and invoices must be signed by the individual on the Authorized Signature Form. If the authorized signatory changes (e.g., staff turnover or updated authorization), an updated Authorized Signature Form must be submitted.