PIN Ohio Association of Community Health Centers October 22, Curt Degenfelder

Transcription

1 PIN Ohio Association of Community Health Centers October 22, 2013 Curt Degenfelder

2 The Latest From the Field OIG Report August 2013 the accounting records for the Section 330 and NAP grants did not separate expenditures related to the Federal grants from other funding sources The timesheets documented employee time worked but did not provide an after-the-fact determination of employee activities increased the salaries of chief financial officer but did not have documentation, such as a market survey, to support the increases (had done salary survey but did not keep results) Recommended to HRSA that HRSA require center to refund $, or work with center to determine if $ were allowable 1

3 Other OIG Considerations Audits of 330 fundees included in FFY 2013 work plan; FFY 2014 work plan not available until January s will be audited for ARRA Compliance in CY 13 fourth quarter Several findings on time and effort reporting Systems to track grant expenditures Giving patients gift cards to come in for screenings did not represent illegal inducement (payment was capitated) and was not distributed to general public No report included the phrase The OIG will ignore this violation because. - the health center is doing God s work - the HRSA Project Officer said it s OK Don t forget to properly account for O&E 2

4 Thoughts on Grant Budget vs. Total Budget Think of it as a step in the process: 1) Budget 2) Drawdown and spending 3) FFR Also note well that while Form 3 no longer requires the CHC to break charges down to net net revenue it also requires patients by payor category something to watch especially close with the 2014 Medicaid expansion. Also now include Medicaid managed care revenue on the Medicaid line (BPR instructions, similar to Page 2 of the old Form 3 Page 2, envision only Medicaid managed care capitated revenue; include Medicaid managed care fee-forservice revenue as well) 3

5 Is Already Here! FEDERAL OBJECT CLASS CATEGORIES Total Proposed Budget Section 330 Federal funding (from Total Federal - New or Revised Budget on Section A Budget Summary) Non-Federal funding (from Total Non-Federal - New or Revised Budget on Section A Budget Summary) Total Amount Budget Categories Object Class Category Federal Non Federal Total (from Section B Budget Categories) a. Personnel b. Fringe Benefits c. Travel d. Equipment e. Supplies f. Contractual g. Construction h. Other i. Total Direct Charges (sum of a- h) j. Indirect Charges k. Total Budget Specified in Section A - Budget Summary

6 Is Already Here! FORM 2 STAFFING PROFILE Administrative Staffing Positions Executive Director/CEO Finance Director (Fiscal Officer)/CFO Chief Operating Officer/COO Chief Information Officer/CIO Administrative Support Staff Medical Staffing Positions Medical/Clinical Director Family Physicians General Practitioners Internists OB/GYNs Total FTEs (a) Total FTEs (a) Average Annual Salary of Position (b) Average Annual Salary of Position (b) Total Salary (a*b) Total Salary (a*b) Total Federal Support Requested Total Federal Support Requested

7 Is Already Here! FORM 3 INCOME ANALYSIS Department of Health and Human Services For HRSA Use Only Health services and Resources Administration Applicant Name: Form 3: Income Analysis Grant Number: Application Tracking Number: Part 1: Patient Service Revenue - Program Income Line # Payer Category Patients Billable Visits Income Per Visit Projected Income Prior FY Income Mo/Yr: (a) (b) (c) (d) (e) 1 Medicaid 2 Medicare 3 Other Public 4 Private 5 Self Pay 6 Total (lines 1-5) Part 2: Other Income - Other Federal, State, Local and Other Income 7 Other Federal 8 State Government 9 Local Government 10 Private Grants/Contracts 11 Contributions 12 Other 13 Applicant (Retained Earnings) 14 Total Other (lines 7-13) Total Non-Federal (Non-section 330) Income (Program Income Plus Other) 15 Total Non-Federal (lines )

8 Budgeting Grant Funds HRSA will allow individual health centers discretion regarding how they propose to allocation the total budget between Section 330 and non-grant funds Grant funds should total the grant amount in your Notice Of Award, and total budget should also equal your most recent NOA (or for example, in the BPR the total Federal funding requested must match the prepopulated Recommended Federal Budget figure) Outreach and enrollment spending could be your base (same CFDA)?? Need to note budget period (SAC or BPR). Clarification still needed for Change In Scope, New Access Popints, and other expansions 7

9 Drawdown and Spending Funds need to be drawn down into an interest bearing account and spent within 3 days Spending needs to be consistent with budget Spending should be for in-scope activities Since most health centers do drawdown before payroll, drawdown amount should be les than total of in-scope, under salary cap ($179,700 as of August 2013) payroll (also note that fringe benefits for these individuals can be charged as a percentage of under-cap salary) Re-consider using the drawdown for anything other than payroll. Needs to be an allowable use of grant funds, and should not be used for assets (under any expensing threshhold, not just yours) This process should be documented with each drawdown 8

10 Tracking the Spending/Budget Need to track actual spending with budget. Very difficult to match actual spending with detail in budget (for example salaries for specific positions). Need to under rebudgeting rules as per 45 CFR and NOA: Cumulative transfers among direct budget categories for the current budget period exceed 25% of the total approved budget or $250,000, whichever is less Only responses to prior approval requests signed by the Grants Management Officer are considered valid. Grantees who take action on the basis of responses from other officials do so at their own risk Rebudget generates new NOA, recommended for approval by Project Officer but you need that NOA! 9

11 Time & Effort Reporting OIG seems to require time and effort reporting even if all of a grantee s activities are in-scope and personnel are not allocated to anything but the 330 grant No guidance yet on what would satisfy OIG Some thoughts: o What did you do for IDS? What are you doing for Outreach & Enrollment? o After the fact, and actual, not budget or scheduled o Who attests to time spent individual or supervisor? o Monthly Going too far: o Estimating % of time spent seeing uninsured (HRSA Site Review team comment) 10

12 Section V.B Health Center Non-Grant Funds Note: this section is open for public comment! non-grant funds should generally be used for allowable costs even though HRSA recognizes that section 330 authorizes an alternative use of non-grant funds Demonstrate that expenditures: 1. Increased services to health center patients 2. Services provided to an increased number of health center patients 3. Improved quality of services provided to health center patients Non-grant funds, as part of the total budget, may include items which are considered unallowable under Federal cost principles, are not subject to HHS salary limitations, or, under very limited circumstances, are procured in a manner which is inconsistent with the rules defined in 45 CFR Part

13 Section V.B Permissible Uses Renovations less than $100,000 Establishment of reserves up to 3 months Interest payments to cover cash shortfalls Salaries above the cap Fundraising Some meals Incentives to patients $20 or less Contract expense base on an immediate need Any proposed expenditure of non-grant scope of project funds other than one that conforms to the list above must be submitted to HRSA for prior review and approval 12