Programmatic and Fiscal Accountability Administrative Overview Ryan White Part A

Transcription

1 Programmatic and Fiscal Accountability Administrative Overview Ryan White Part A June 13, 2011 Frances Hodge Project Officer Southern Services Branch Health Resources and Services Administration Department of Health and Human Services

2 Reporting Requirements and Conditions of Award Definitions of terms Why are they important? How are they used? How should they be completed? How are they submitted?

3 Definitions Conditions of Award: Conditions of Award (COA) is the term generally used to describe the entire universe of documents and expectations outline for grantees in the Notice of Grant Award (NGA) under the heading Terms and Conditions.

4 Definitions Terms and Conditions Include: Grant Specific Terms Program Terms and Reporting Requirements

5 Definitions (Continued) Reporting Requirements: Reporting requirements are specific documents grantees are required to submit to HRSA in order to document program planning, operations and outcomes. Specific reporting requirements are listed in the Notice of Grant Award.

6 Definitions (Continued) Reporting Requirements and Conditions Include: Federal Financial Reports (FFR) Annual Progress Reports Maintenance of Effort Reports Expenditure Reports Program Terms Report

7 Reporting Requirements and Conditions of Award Why Are They Important? They are the documents that the federal government uses to assess the progress of funded programs. They help determine the degree to which legislative mandates are met. They become are part of a program s history.

8 How Are They Used Reporting Requirements and Conditions are used in the following ways: Document program operations both fiscal and programmatic. Support planning and program development activities and Assess program success by HRSA and other federal agencies.

9 How Should They Be Completed Grantees are provided copies of the Reporting Requirement and Condition of Award forms along with the instructions in the Electronic Handbook (EHB). We will not cover each of the Reporting Requirements or COAs listed in the NGA but will cover the Program Terms Report and the FFR in detail.

10 Program Terms Report

11 Program Terms Report Components: Part A & MAI Planned Allocation Table FY 2010 Implementation Plan Consolidated List of Contractors (CLC) Contract Review Certification (CRC) Revised SF 424A and Budget Narrative

12 Allocations Table Purpose: Serves as a monitoring tool to track and monitor the use of Ryan White funds. The Allocations Report identifies: Categories of services that are being delivered Changes in the type of services being provided over time Trends in the amount of funds being used to deliver these services

13 Allocations Table An Allocations Table: Outlines the dollar amounts allocated for the RW program for the current fiscal year, including MAI amounts Accounts for prioritized funding set by the planning council/planning body with regard to the 75/25 rule and needs within EMA/TGA Accounts for administrative dollars and QM (where applicable)

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15 Implementation Plan Purpose: Serves as a monitoring tool to verify: Service priority Goals Objectives Unit of service Number of Clients to be served Total priority allocation planned for the grant year Note: Plan should include all service categories and priorities established and reflected in the planned Allocations Report

16 Implementation Plan An implementation plan should include: Objective(s): list objective that are required to implement a new or continue an existing service Service Unit Definition: provide the name and definition of the unit of service provided Quantity: provide the number of people to be served and service unit. Time Frame: indicate the estimated duration of the activity relating to the objectives Funds: provide the amount allocated for each service Outcomes: Select a minimum of two objective and list outcomes/indicators to be tracked

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18 Consolidated List of Contracts Purpose: Serves as a monitoring tool to identify ALL Part A and MAI service providers receiving funds for the current grant year

19 Consolidated List of Contracts For each service provider input: Identifying Information Tax Payer Identification # (EIN) Service Provider Code Contract Amount Minority Provider Status

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21 Contract Review Certification Purpose: Serves as a monitoring tool to certify all contracts administered by the grantee for the current grant year comply with OMB circulars and other Ryan White requirements

22 Contract Review Certification Denotes the total grant amount awarded in contracts for the current fiscal year Certifies that the procedures used by the grantee (or an administrative agent) to advertise and award funds meet the minimum standards required by the Office of Management and Budget (OMB) in applicable Circulars Certifies the budgeted costs in all contracts have been determined allowable according to principles and standards established by OMB in applicable Circulars Certifies that there are no mathematical errors in the budgets of all contracts

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24 SF-424A This form must be revised and submitted with the Final Part A Program Budget to reflect budget allocations based on the actual amount of funds awarded to the state with respect to the following:

25 SF-424A Administration HIV Services Clinical Quality Management MAI (where applicable)

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27 Budget A program budget must be submitted for each Part A award. It must be based on: Priorities established by the Planning Council Reflect the amount of Part A funds awarded Reflect legislative and programmatic cost requirements

28 Budget A budget and narrative must be included for funds allocated to: Grantee Administration: up to 10% MAI Quality Management: up to 5% no greater or $3 million, which ever is less

29 Budget Narrative Descriptive information used to explain and justify the amounts budgeted within each program budget category. It must include specific information about: Who? What? Where? When? Why?

30 Budget Narrative A budget narrative is required for: Grantee Administration Formula and MAI Grantee Quality Management Formula and MAI Planning and Evaluation

31 Federal Financial Report The Federal Financial Report (FFR) SF-425 is used to report financial data and to verify amounts available for carry over requests The FFR should be completed by a an authorized fiscal official

32 Annual Progress Report Purpose: The Annual Progress Report is used to document the grantees success in meeting planned goals and objectives The Annual Progress Report highlights successes and challenges Reports on all program related activities

33 Annual Progress Report The Annual Progress Report includes the following components: Final Implementation Plan Planning Council Activities Early Identification of Individuals with HIV/AIDS (EIIHA) Update Administrative Final Expenditures

34 Final Progress Report Technical Assistance Certification of Aggregate Administrative Costs Women, Infants, Children and Youth (WICY) Expenditure Report

35 Maintenance of Effort Report Purpose: The Maintenance of Effort Report (MOE) documents that EMA/TGAs have maintained expenditures for HIV-related Core Medical Services and Support Services at a level equal to the one year period preceding the current fiscal year. Grantees report MOE using a table that identifies the MOE budget elements and

36 Maintenance of Effort The amount expenditures related to core medical services and support services A description of the process used to determine the amount of expenditures in the table

37 Expenditure Reports Purpose: Expenditure Reports are used to document the year to date expenditures of the program The Expenditure Report is a component of the Annual Progress Report

38 Contact Information Frances Hodge Project Officer, Southern Services Branch Telephone:

39 Administrative Overview Ryan White Part A & Part B Grantees Division of Financial Integrity (DFI) June 6 & June 13, 2011 Presented by Department of Health and Human Services Health Resources and Services Administration Office of Federal Assistance Management Division of Financial Integrity

40 Division of Financial Integrity (DFI) Presenters: Sandy Seaton, DFI, Acting Director Sherry Angwafo, Team Leader, Financial Analysis Wayne Bulls, Financial Analysis Team Bob Noethe, Financial Analysis Team

41 Division of Financial Integrity DFI. What do we do?

42 Division of Financial Integrity DFI serves as HRSA s focal point for reviewing HRSA grantee s financial integrity. Three major DFI Functions: Performing Financial Assessments (Pre award) In depth Reviews (Post award) Resolving A-133 Audit Findings (Post award)

43 Division of Financial Integrity (DFI) Financial Assessments (FAs) Presented by Wayne Bulls

44 Division of Financial Integrity (DFI) What is a Financial Assessment? A financial assessment is a pre-award review of an organization s financial condition to determine their suitability to manage and account for federal funds. Based on the FA, DFI provides funding (competitive and non competitiv recommendations to HRSA grant funding decision makers.

45 Division of Financial Integrity (DFI) When are Financial Assessments done? A Financial Assessment is done for new HRSA Grantees Financial Assessment are done once a year For the 2010 Calendar Year DFI prepared over 2,800 Financial Assessments!

46 Division of Financial Integrity (DFI) What is the Goal of a FAs? To Make a funding Recommendation to HRSA grant decision makers. DFI funding recommendations to HRSA grant decision makers should be updated annually for all grantees both new and existing; competitive and budget year funding.

47 Division of Financial Integrity (DFI) How are Financial Assessments Performed? DFI reviews five major areas: DUNS (CCR) Alerts (Excluded Parties, DFI Watch List, etc.) A-133 Audit Financial Statements/IRS 990 Form Other Financial Information (internet searches, press releases, etc.)

48 Division of Financial Integrity (DFI) Third Party Reimbursements What is a DUNS and why is it important? Any organization that does business with the Federal Government, including grantees, is required to have an active registration with the CCR (Central Contractor Registration) using their DUNS number. The CCR requires re-registration every year to remain in active status.

49 Division of Financial Integrity (DFI) DFI s Recommendations The following are the possible funding recommendations to HRSA grant funding decision makers: Fund without conditions or restrictions. This recommendation is used when the grantee s financial position is good. Fund with conditions or restrictions. For organizations that have had previous challenges managing federal funds this recommendation is used. Fund without restrictions or conditions; DFI will closely monitor. DFI closely monitors some organizations that have negative net assets or have financial results that have declined the past few years.

50 Division of Financial Integrity (DFI) The following are the possible recommendations (continued): Deferral of recommendation. DFI was unable to assess the grantee s financial position due to lack of information such as audits or financial statements. Also, if there is no valid DUNS number the organization will receive this recommendation until a valid DUNS number is obtained. Do Not Fund. Organizations that are bankrupt or has had significant allegations of fraud, misuse or abuse of funds will most likely receive this recommendation.

51 Division of Financial Integrity (DFI) In Depth Reviews by Sherry Angwafo

52 Division of Financial Integrity (DFI) In Depth Reviews: At Risk Grantees Potentially At Risk Grantees (PII)

53 Division of Financial Integrity (DFI) What is an At Risk Grantees? At Risk Grantees are grantees with reported financial issues such as: OIG Hotline Complaints Potential Misuse of grant funds (embezzlement, drawing downs) In adequate financial management system (no internal controls, accounting system, inadequate timekeeping)

54 Division of Financial Integrity (DFI) Potentially At Risk Grantees (PII) Potentially At Risk Grantees are grantees whose financial position is negative or trending negative. HRSA has established Program Integrity Initiative (PII) work group to mine for grantees with potential financial issues not yet discovered.

55 Division of Financial Integrity (DFI) How does DFI identify Potentially At Risk Grantees? Through HHS Program Integrity Initiative (PII), HRSA has set up a data mining work group. This work group uses attributes financial markers from the Federal Audit Clearinghouse (FAC) along with HRSA s internal database to select grantees that may be in financial trouble or heading in that direction. Once identify, HRSA may assist the grantee with technical assistance (TA) or a site visit.

56 Division of Financial Integrity (DFI) A-133 Audit What to Expect? By Sandy Seaton

57 What is an A-133 Audit? OMB Circular A-133 Audits are required for non-federal entities that expend $500,000 or more of federal award funds in their fiscal year. Auditors publish an opinion on financial statements and federal programs: Unqualified means that the auditor does not qualify his opinion that the financial statements and programs accurately reflect the financial position or expenditures reported. Qualified means that the auditor qualifies his opinion that the financial statements and programs accurately reflect the financial position or expenditures reported. Adverse means that the auditor does not agree that the financial statements and programs accurately reflect the financial position or expenditures reported. Disclaimer means that the auditor cannot form an opinion on the financial statements or federal programs due to missing or incomplete data or documents.

58 Division of Financial Integrity (DFI) What is an A133 audit? An A-133 audit sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-federal entities expending Federal awards. OMB Circular A Financial Statement Audit (OMB Circular A (b) Internal Controls (OMB Circular A (c) Compliance Audit (Federal Programs) (OMB Circular A (d)

59 Division of Financial Integrity (DFI) What are some of the A133 requirements? (OMB Circular A (a) Shall be conducted in accordance with GAGAS Shall cover the entire operations Shall cover the financial statements and schedule of expenditures of federal awards (SEFA) The financial statements and SEFA shall be for the same fiscal year

60 Division of Financial Integrity (DFI) Financial Statement (FS) Audit (OMB Circular A (b) Auditor shall determine if FS are presented fairly in accordance with Generally Accepted Accounting Principles (GAAP) Auditor shall determine if the SEFA is presented fairly in relationship to the auditees financial statements

61 Division of Financial Integrity (DFI) What should be prepared for the FS review? Prepare financial statements (OMB Circular A (a) Prepare a SEFA for the same period covered by grantees financial statements (OMB Circular A (b)

62 Division of Financial Integrity (DFI) Internal Controls (IC) (OMB Circular A (C) Auditor shall perform procedures to obtain an understanding of IC over federal programs Auditor shall obtain sufficient understanding over IC to plan the audit

63 Division of Financial Integrity (DFI) What is the most important item to prepare for the IC review? As part of a adequate Financial Management System (45 CFR 74.21), a grantee should have written policies and procedures to assist the auditors in gaining an understanding of internal controls of applicable compliance requirements. Written policies and procedures are the auditors roadmap to how you comply with the various compliance requirements applicable to your major federal programs.

64 Division of Financial Integrity (DFI) Compliance Audit OMB Circular A (d) Auditor shall determine if the auditee has compiled with laws, regulations, and grant terms and conditions that may have a direct and material effect on each major programs. The principle compliance requirements for most Federal program are included in the compliance supplement Compliance testing shall include tests of transactions (transaction testing)

65 Division of Financial Integrity (DFI) What should prepared for the Compliance review? (OMB Circular.300) For compliance testing, the most important activity, the grantee must have supporting documentation available for the auditor to review. Supporting documentation includes, but not limited to, invoices, vouchers, checks, agreements, contractors, consultant work product, timesheets, paystubs, procuring files, etc. Other financial documents general ledger, chart of accounts, Federal Financial Reporting, grant agreements, etc.

66 Division of Financial Integrity (DFI) Other A133 Audit Grantee Responsibility Audit Finding Follow up (OMB Circular A (a)) Summary Schedule of prior audit findings (OMB Circular A (b)) The auditee shall prepare a summary schedule of prior audit findings Corrective Action Plan (CAP) (OMB Circular A (c)) At completion of audit, the auditee shall prepare a CAP to address each audit findings Report submission (OMB Circular A ) Data collection form and reporting package

67 A-133 Audit If a grantee has good Federal Financial Management Systems in place and has followed the Federal Cost Principles then the A-133 audit should go well.

68 Contact Information Health Resources and Services Administration U.S. Department of Health and Human Services 5600 Fishers Lane Rockville, MD