Ryan White Part A FY 2018 Provider Conference

Transcription

1 Ryan White Services Division Ryan White Part A FY 2018 Provider Conference Administrative Overview April 25, 2018

2 MANDATES HRSA Legislation Cost Principals Service Definitions Allowable Activities Standards of Care Contract Requirements Agency Monitoring Billing and Invoicing PRACTICE Ryan White Part A in the Boston EMA

3 Presentations 1.Boston EMA Service Categories and Allowable Activities Cheryl Brickey, Senior Program Coordinator 2. FY18 Fiscal Overview Frantzsou Balthazar-Toussaint, Fiscal Manager 3. Part A Monitoring Process Liz Rios, Senior Program Coordinator, and Maya Haynes, Program Coordinator

4 Boston EMA Service Categories and Allowable Activities

5 Learning Objectives 1. Summarize changes to service categories 2. Present allowable activities for currently funded services

6 Boston EMA Core Medical Service AIDS Drug Assistance Program The AIDS Drug Assistance Program (ADAP) provides FDA-approved medications to low- income clients with HIV disease who have no coverage or limited health care coverage. Medical Nutrition Therapy Provides nutrition education, supplements, and dietary counseling to PLWH. Goal Is to optimize immunity and prevent weight loss in PLWH. Oral Health Provides diagnostic and therapeutic dental care to PLWH. Goal is to prevent and treat oral diseases for PLWH. Medical Case Management Client-centered services to engage PLWH is treatment. Goal is to increase viral suppression and positive health outcomes. 6

7 Boston EMA Support Service Categories Medical Transportation Provides non-emergency transportation for PLWH to encourage retention in medical services. The goal is to assist PLWH to connect to core and support services that contribute to positive health outcomes. Housing Provision of short term or emergency housing for PLWH. Goal is to provide stability so a person can gain and maintain medical care. Psychosocial Support Defined as group or individual counseling sessions. Themes may include HIV support or behavioral health counseling. Goal is to decrease isolation for PLWH and provide space for peer engagement. 7

8 Boston EMA Support Service Categories Non- Medical Case Management Non-Medical Case Management Services (NMCM) provides guidance and assistance in accessing medical, social, community, legal, financial, and other needed services. The goal of non-medical case management services Non- Medical Case Management Services is to provide guidance and assistance in improving access to needed services. Substance Abuse Residential Provision of short term or emergency housing for PLWH. Goal is to provide stability so a person can gain and maintain medical care. Food/Home Delivered Meals Provision of food items, hot meals, vouchers, or personal hygiene products. The goal is to prevent hunger and assist PLWH to meet basic needs.. 8

9 HRSA Site Visit Findings Our most recent HRSA site visit found that Ryan White Part A is currently paying for unallowable activities as defined by HRSA Policy Clarification Notice

10 Service Category Review Our most recent review of currently funded Ryan White Part A Services found that the following categories are non-compliant with HRSA PCN 16-02: ADAP Food/Meals Medical Case Management Psychosocial Support

11 ADAP Allowable ADAPs may use program funds to purchase medication and/or health insurance for eligible clients. Unallowable Paying cost sharing on behalf of the client.

12 Psychosocial Support Allowable Group or individual support and counseling services to assist eligible people living with HIV to address behavioral and physical health concerns Unallowable Medical and Non Medical Case Management activities Education on risk reduction strategies Education on health care coverage options Health literacy Treatment adherence education Reengagement of people who know their status into Services

13 Food/ Hot Meals Allowable The purchase of actual food items, hot meals, or distribution of food vouchers. Unallowable The purchase of household appliances, pet foods, and other nonessential products Hot meals provided as a social activity or to individuals that have not had an assessment of need.

14 Medical Case Management Allowable A range of client-centered activities focused on improving health outcomes in support of the HIV care continuum Activities prescribed by an interdisciplinary team that includes other specialty care providers Unallowable Activities that solely focus of guiding and assisting clients in accessing, social, community, legal, financial, and other needed services

15 FY18 Contract Changes Scope of Services: All FY18 scope of services will be updated to include the service definition as defined by HRSA PCN Reporting: All programs must ensure that all program data is entered on a monthly basis.

16 Monitoring Changes Feedback from HRSA requires Part A site visits to include more compliance testing Monitoring visits will include both fiscal and programmatic elements Compliance testing will include time and effort, verification of required policies, and testing of Standards of Care 16

17 FY18 Reporting Timeline Submission Reporting Period Due Date 1 st Quarterly Report Mar 1 - May 31 June 15, nd Quarterly Report June 1 - Aug 31 Sept 15, rd Quarterly Report Sept 1 - Nov 30 Dec 15, th Quarterly Report Dec 1 - Feb 28 Mar 15, 2019

18 Questions?

19 FY18 Fiscal Overview 19

20 Learning objectives 1. Illustrate changes to Budget and Invoice format 2. Review general fiscal rules 20

21 FY 2018 Fiscal Changes New Budget Format Part A Administrative Cost No Contract Extension Packet Award Letter included new budget format to be implement as of March 1, 2018 New Part A budgets should have clear distinctions between Direct Care Cost vs. Administrative Cost No contract extension packet to be executed for FY18 Only Award Acknowledgement Form was needed for PO creation Full Contract Packet will be sent post full award receipt from HRSA New Invoice Format Invoice template must be revised to match new budget format Annual Site Visit Reintegration of Fiscal Monitoring with Program Monitoring

22 Budget changes Components: FY 2017 Budget Personnel (All Ryan White Part A paid staff) Below Line Items (Supplies, Travel, Training, etc.) HHS Indirect/Administrative Line (10%) FY 2018 Budget Components: Core/Support Direct Care Cost (All Ryan White Part A paid staff that provide direct services.) Other Direct Care Cost (Non Personnel Direct Care Costs, i.e. Supplies, Travel, Training, etc. ) Administrative Cost Itemized Administrative Cost 10% Cap; or HHS Indirect Approved Rate 10% Cap. 22

23 FY 2017 Budget Sample Budgets FY 2018 Budget ATTACHMENT C RYAN WHITE PART A: CFDA Boston Public Health Commission FY 2017 March 1, 2017 February 28, 2018 AGENCY NAME Psychosocial Support - Peer Support Item Personnel Salary FTE Months Annual Peer Support Coordinator B. Smith $32, $16,000 Peer Advocate K. Jones $28, $5,600 Peer Advocate J. Doe $28, $8,400 SUBTOTAL 1.0 $30,000 FRINGE 29.10% $8,730 PERSONNEL TOTAL $38,730 Staff Training $1,000 Staff Travel $200 Program Supplies $1,000 ATTACHMENT C RYAN WHITE PART A: CFDA Boston Public Health Commission FY 2018 March 1, 2018 February 28, 2019 AGENCY NAME Psychosocial Support Services Core/Support Service Direct Cost Personnel Salary FTE Months Annual Peer Support Coordinator B. Smith $32, $16,000 Peer Advocate K. Jones $28, $5,600 Peer Advocate J. Doe $28, $8,400 SUBTOTAL 1.0 $30,000 FRINGE 29.10% $8,730 PERSONNEL TOTAL $38,730 Other Direct Care Cost Staff Training $1,000 Staff Travel $200 Program Supplies $1,000 SUBTOTAL $2,200 DIRECT CARE TOTAL $40,930 HHS Indirect Approved Rate 40% Annual Ryan White Indirect Rate Cap 10% $4,093 EXPENSE TOTAL PROGRAM TOTAL HHS INDIRECT / ADMINISTRATIVE TOTAL AMOUNT $2,200 $40, % $4,093 $45,023 DIRECT CARE TOTAL $40,930 INDIRECT RATE CAP (10%) $4,093 SERVICE AWARD TOTAL $45,023

24 Are capped at 10% Administrative Costs Administrative Costs are usual and recognized administrative overhead activities (ref. PCN 15-01, FY18 Provider Manual) Subrecipient administrative expenses must meet legislative administrative definition Subrecipients are responsible for : - Tracking all administrative expenses - Providing expense reports as backup documentation for invoices Subrecipients administrative activities must be clearly labeled and itemized on Part A budgets (New!!!)

25 HHS-Approved Indirect Rate The Indirect line item may include administrative expenses not directly associated with a specific program, which are necessary for the management and operation of the whole agency (45 CFR 75, subpart E). Indirect Rate costs are capped at 10%. Per Federal Requirement: for subrecipients wishing to use an Indirect Rate, documentation of Certificate of Indirect Costs that is HHS-Approved, signed by an individual at a level no lower than Chief Financial Officer, must be provided. Subrecipients with an approved indirect rate do not need to submit indirect expenses backup. Subrecipients Indirect Rate cost must be clearly labeled on Part A on budgets (New!!!)

26 Contract Extension Packet No Contract Extension Packet for FY18 Only Award Acknowledgement Form was needed for PO creation Only 1 contract process this year (Full Contract Packet) Full Contract Packet will be sent out post full award receipt from HRSA

27 Invoice Changes Format Invoice Number Invoice PO number Invoice Activity number New invoice format must match new budget format Invoice number changes every fiscal year to match current fiscal year Invoice PO number is updated every fiscal year New POs are sent to subrecipient fiscal staff at the beginning of the fiscal year Invoice activity number changes every fiscal year

28 Invoice Coversheet BPHC Funding Source Example Cost Reimbursement M onthly Invoice Company Name: MUST WRITE OUT COMPLETE NAME OF AGENCY Category: ENTER CATEGORY HERE Address: ENTER AGENCY ADDRESS HERE Remit to Address: ENTER AGENCY ADDRESS HERE Date: ENTER DATE Boston Public Health Commission PO# Agency Invoice #: RW28 Enter new PO# [Insert M ONTH & CATEGORY abbrev.] Billing Period: Enter Billing Period Activity#: Bill To: Boston Public Health Commission Ship To: Accounts Payable Attn: Account Payable 1010 Massachusetts Ave. 6th Floor 1010 Massachusetts Avenue Boston, MA Boston, MA Program Component Budget Amount this Cumulative Remaining FTE Invoice Billing Balance (A) (B) (C) (D) DIRECT CARE STAFF - NAM E Program Director $0 $0 $0 $0 Medical Case Manager $0 $0 $0 $0 Medical Case Manager $0 $0 $0 $0 $0 $0 $0 $0 Sub-total 0.00 $0 $0 $0 $0 Fringe 30.00% $0 $0 $0 $0 Personnel Totals $0 $0 $0 $0 OTHER DIRECT CARE COST Local Travel $0 $0 $0 $0 Staff Training $0 $0 $0 $0 Program Supplies $0 $0 $0 $0 $0 $0 $0 $0 Sub-total $0 $0 $0 $0 DIRECT CARE TOTAL $0 $0 $0 $0

29 Invoice Coversheet ADM INISTRATIVE COST (10% Cap) Program Director 0.00 $0 $0 $0 $0 Program Rent 0% $0 $0 $0 $0 ADM INISTRATIVE COST TOTAL 10.00% $0 $0 $0 $0 TOTALS EXPENSE $0 $0 $0 $0 M ONTH TOTAL Please Pay This Amount $0 FOR INFECTIOUS DISEASE BUREAU USE ONLY I certify that the actual bills and payroll documentation attached USE APPROVED FOR PAYM ENT are expenditures solely associated with Community Based Prevention or Ryan White Part A contracts AMOUNT: ACTIVITY: Please sign in blue ink. PO #: Program Director/Financial Authorization DATE: Prepared by (Please print): Phone: Contact Name & phone Number: SIGN:

30 Invoice Requirements Reminder Invoices must always match the most current approved budget EXACTLY PO # should be the CORRECT and CURRENT Fiscal Year PO # (FY18 PO # as of March 1, 2018) Invoice # must be unique for each billing month, have less than 20 characters, and must be legible Invoice # should not be hand written BPHC template must be used to avoid mistakes Sufficient and proper back up documentation must be submitted for each invoice every month

31 Invoice Coversheet Company Name: MUST WRITE OUT COMPLETE NAME OF AGENCY Category: ENTER CATEGORY HERE Address: ENTER AGENCY ADDRESS HERE Date: ENTER DATE BPHC Funding Source Example Cost Reimbursement M onthly Invoice Remit to Address: 20 characters Must be Unique Must be specific to each billing month RW28Mar-CM RW28April-HSNG (see abbreviation cheat sheet) ENTER AGENCY ADDRESS HERE Boston Public Health Commission PO# Agency Invoice #: RW28 Enter new PO# [Insert M ONTH & CATEGORY abbrev.] Billing Period: Enter Billing Period Activity#: Bill To: Boston Public Health Commission Ship To: Accounts Payable Attn: Account Payable 1010 Massachusetts Ave. 6th Floor 1010 Massachusetts Avenue Boston, MA Boston, MA Program Component Budget Amount this Cumulative Remaining FTE Invoice Billing Balance (A) (B) (C) (D) DIRECT CARE STAFF - NAM E Program Director $0 $0 $0 $0 Medical Case Manager $0 $0 $0 $0 Medical Case Manager $0 $0 $0 $0 $0 $0 $0 $0 Sub-total 0.00 $0 $0 $0 $0 Fringe 30.00% $0 $0 $0 $0 Personnel Totals $0 $0 $0 $0 OTHER DIRECT CARE COST Local Travel $0 $0 $0 $0 Staff Training $0 $0 $0 $0 Program Supplies $0 $0 $0 $0 $0 $0 $0 $0 Sub-total $0 $0 $0 $0 DIRECT CARE TOTAL $0 $0 $0 $0

32 Abbreviation Cheat Sheet Invoice Category Abbreviation Cheat Sheet Drug Reimbursement Medical Case Management Minority AIDS Initiative Medical Case Management Case Management Non Medical MAI Case Management Non Medical Housing Services Oral Health Care (Dental) Psychosocial Support Peer Support Psychosocial Support Mental Health Psychosocial Support Substance Abuse Minority AIDS Initiative - Psychosocial Support Substance Abuse - Residential Transportation Meals Medical Nutrition Therapy DR CM CM MAI - CM NMCM MAI-NMCM HSNG Dent PS PS-MH PS-SA MAI-PS SA TN MLS MNT

33 Invoice Submission Invoices must be sent via Mail or Boston Public Health Commission ATTN: Accounts Payable 1010 Massachusetts Avenue, 2 nd Floor Boston, MA Or The Preferred METHOD: accountspayable@bphc.org Cc: fbalthazar@bphc.org sramdhanie@bphc.org maraujo@bphc.org Invoices must be submitted by the 15th of every month and are paid within 30 days of receipt. Subrecipients will receive a reminder on the 16 th if invoices are not received by the 15 th.

34 Invoice Payment Processes It is important that invoices are double checked for accuracy as it can create a delay in payment if elements are missing or are wrong. ed/mailed invoices are scanned into an electronic payment system called Workplace by Accounts Payable Accounts Payable then forwards invoices to RW Fiscal Coordinators for approval. Monthly invoices containing all required information are paid within 30 days of receipt. Invoices are paid via ACH direct deposit only.

35 Fiscal Monitoring Processes Monthly Monitoring To ensure monthly invoices are submitted on time To keep agency s management staff informed of monthly invoice compliance status To track where invoices are, if there are pending budget revisions, and to pinpoint issues that might need to be addressed Annual Site Visit To ensure contract terms as explained in the fiscal rules are being followed and are met To verify that that fiscal standards are being met To identify fiscal technical assistance needs Fiscal site visits will be scheduled and conducted jointly with programmatic site visits (New!!!)

36 Fiscal Rules Reminder Subrecipients are expected to spend 100% of their Part A award Subrecipients will only be reimbursed for items based on their Scope of Service, budget, and invoice back-up documentation Invoices without the required information or documentation will be returned to Subrecipients Subrecipients may request to revise their Scope of Service, and budget, but must first submit a proposal for revisions and approval by BPHC

37 Important FY 2018 Provider Manual References Fiscal Overview section Policies and Procedures section - Federal Monitoring Standards - HRSA PCN HRSA PCN HRSA PCN 16-02

38 Questions? 38

39 Part A Monitoring Process Recipient and Subrecipient Expectations and Obligations

40 Learning Objectives 1. Explain the recipient to subrecipient monitoring process 2. Illustrate the relationship between fiscal, contract, and site monitoring processes

41 Purpose of Monitoring The Role of the Grantee Pass through entities are required to monitor subrecipient award and compliance All Part A awards must follow federal, state, and local regulations Monitoring captures many activities conducted by the subrecipient Illustrates the relationship between service delivery, contract compliance and fiscal activities

42 FY17 Recap RWSD completed 30 site visits and reviewed 678 client records 43 citations issued compared with 97 in FY15 Cumulative Citations FY15-FY17 Initial Site Visits Files reviewed Citations Issued Agencies cited FY % FY % FY %

43 Successes and Challenges 1. Eligibility Recertification - Helpful tools include provider attestations to no changes 2. Internal Quality Assurance Develop systems appropriate for your program

44 Expectations and Standards Deliver services that are reasonable, allowable, and complaint Develop and implement policies and methodologies Maintain Part A as payer of last resort Programs will be distinct, but compliant

45 Monitoring has many forms Monthly Calls Monthly Invoicing Budget Revisions Annual Contract Renewal Annual Site Visits Quarterly Reports Monthly Data Entry Combination of data, fiscal, program and administrative responsibilities

46 Annual Site Visit Quality Assurance activity distinct from QI Collects information from client files Assesses information for allowability, compliance, and meeting standards Process of testing and verifying policies used by subrecipient agencies

47 Roles and Responsibilities Role of the Subrecipient Develop and implement policies to meet minimum standards Submit policies to BPHC Policies illustrate purposeful methodology that can be tested 47

48 Role of the Grantee Review and become familiar with subrecipient policies Match documentation of service delivery on site with standards, policies, and operating procedures On behalf of HRSA, evaluate subrecipient using Standards of Care, legislation, federal regulations, and other contract mandates Identify areas of non-compliance and offer assistance 48

49 Day of the Site Visit Chart review Reconciles data entered in e2boston Review of fiscal records to reconcile invoices Reflects work of staff on Part A budget Illustrates service delivery Verifies implementation of policy and procedure Adherence to Standards of Care Subrecipient Staff Interviews BPHC staff will interview agency Part A staff BPHC will verify time and effort with agency budget Test knowledge of Standards, Policies and Procedures 49

50 Example: Site Visit for Psychosocial Support Service Before the visit: Grantee sends PS Compliance Testing tool Pre site visit call: 2-3 weeks ahead of visit Grantee asks for Universal policies 50

51 Example: Site Visit for Psychosocial Support Service Day of the visit: BPHC fiscal and program staff are on site Sample interview question: How do you decide upon topics for individual sessions? Brief exit conference to discuss immediate findings 51

52 Example: Site Visit for Psychosocial Support Service After the visit: Subrecipient receives a single Letter of Findings with combined program and fiscal findings Findings can include: areas of strength, areas for improvement, and areas of non-compliance Letter will dictate if a Corrective Action Plan is necessary and next steps 52

53 Knowledge Check Allowable vs. Unallowable Activities Which of the following Psychosocial Support services are allowable? 1. Subrecipient hosts group and 1:1 sessions to offer support for PLWH who struggle with substance use. Facilitator is a former substance user, but not a PLWH. Meals and snacks are offered at weekly meetings. 2. Subrecipient hosts a kickboxing fitness group for PLWH that provides gym memberships and transportation to the gym. 3. Subrecipient hosts public events where they provide condoms, prevention education, and harm reduction counseling to people living with or at risk for HIV.

54 Allowable Activities Service categories and allowable activities are determined by HRSA Activity may be allowable, but require proper methodology Required back up for payment includes proof of purchase, cost per client, and methodology Part A staff must be familiar with objectives, scopes, goals of service categories, as well as cost principles

55 Preparing for a Monitoring Visit Utilize pre site visit call Communicate with site visit lead Respond to all requests for information Prepare Part A staff to be knowledgeable 55

56 Thank you to all Part A Providers! Any questions? 56