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Strengthen existing controls over the grant program process, including testing State policies and/or processes during onsite reviews to ensure all States monitor their SCBGP projects.
Obtain an Office of the General Counsel opinion regarding whether matching funds should be reported, based on Federal regulations and the Agricultural Marketing Service (AMS) Grants Division General Terms and Conditions (AMS Terms and Conditions) and take the appropriate actions based on the advice received.
Ensure all States create and implement policies and procedures for performing risk assessments and conducting reviews of subrecipients, and provide guidance on the information that must be included. Specifically, the process should include ensuring funds are used in accordance with Federal regulations and AMS’ terms and conditions.
Communicate to States the benefits of expending their administrative funds to conduct the necessary monitoring.