Program and Fiscal Compliance Issues
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Transcript of Program and Fiscal Compliance Issues
Program and Fiscal Compliance Issues
Geri Baucom, Fiscal/Contracts Specialist
Johnna Meyer, Policy ManagerCalifornia Department of Aging
Program and Fiscal Compliance
Fiscal Process Overview Direct Services Program Development (PD) or Coordination
(C) Consumer Contributions Matching Requirements Nutrition Services Incentive Program (NSIP)
Fiscal Process OverviewAllocations
Budgets, Budget Revisions, Contracts
Monthly Reporting
Financial Closeout Reports/Closeout Statements
Audit/Audit Resolution
Final Closeout
Allocations, Budgets, Contracts Title III/VII, III E, CBSP
CDA Issues Planning Estimate AAA Submits Budget CDA Issues Contract With Budget Display
Health Insurance Counseling & Advocacy (HICAP), Title V CDA Issues Planning Estimate AAA Submits Budget CDA Issues Contract With Approved Budget
Monthly Reporting Title III/VII, CBSP, & HICAP Are
Electronic Files Title III E & Title V Are Excel
Reports Must Submit Each Month by the
Due Date Specified in the CDA Contract Exhibit B
Closeouts, Audit Resolution, Final Closeout Closeouts Due 60 Days After End of
Contract Period Closeouts Must Be Submitted on Time
to Avoid Losing One-Time-Only Funds Contract Closeout Statement Issued to
AAAs Identifying Unspent Funds AAA Resolves Audit Findings of
Providers, CDA Resolves Audit Findings of AAA
CDA Issues Audit Determination & Final Closeout
FY 2004/05 Closeout Process Changes Title III/VII, Title III E, & CBSP Combined
in One Closeout (CDA 180) to Conform to Revised Area Plan Budget/Contract
New HICAP Closeout (CDA 230) Title V Closeout (CDA 90) Revised to
Conform to Revised Title V Budget Title V Closeout Due August 1, 2005 to
Ensure Meeting Dept of Labor Reporting Requirements
Direct Services Requires Prior Approval (OAA & CCR) Area Plans & Updates (Appendix 1A, 1B,
or 1C) Area Plan Budget Summary of Costs and
Supporting Schedules Funds Can Only be Used for Activities &
Services Specifically Provided for in the OAA and Identified in the Area Plan Budget
Area Plans & Updates Appendix 1A Lists Services Determined to
be the Function of an AAA, Approval is Automatic
Appendix 1B & 1C Must be Completed for all Direct Other Services and Approved Based on Documentation Provided
Must Complete Appendix 1A, 1B, and/or 1C at the Beginning of Each Planning Cycle and if any Changes Occur During the Cycle
PD or C Specifics Definition is Different for Each (PD or
C) No Limit on the Amount of III B Funds
Used for PD or C Activities Must Budget/Spend Admin Allocation
(Including III E) Before Using III B for PD or C
PD or C Activities Limited to One Year
Area Plans & Updates PD or C Goals & Objectives Must Meet
Definition and be Clearly Identified During Public Hearings Submit Details of
Proposals to Fund PD or C as a Cost of III B Supportive Services (AAA Staff vs Services)
Provide Assurances that Expenditures Have Direct and Positive Impact on Services
Area Plan Budgets and Financial Closeout Reports Did AAA Budget/Spend All Funds
Allocated for Admin (III B, III C-1, III C-2, & III E)?
Did AAA Budget/Spend III B Funds for PD or C?
Is it Necessary to Adjust Admin and PD or C?
CDA Onsite Monitoring Does the AAA Have a System for
Tracking Employee Time Spent on PD or C Activities?
Do AAA Staff Track Actual Time By Cost Objective (Admin, PD, C, Direct Services, etc)?
Are the PD or C Activities Tied to Specific Goals and/or Objectives in the Area Plan?
Consumer Contributions (OAA Section 315)
Voluntary Contributions Cost Sharing
Voluntary Contributions Voluntary Contributions Same as Program
Income Program Income Specifics in CDA Contract
Exhibit B AAA/Provider Determines Suggested
Donation Must Be Non-coercive No Obligation to Contribute & Purely
Voluntary Can’t be Denied Service for Not Contributing Must be Used to Expand Services
CDA Onsite Monitoring Findings Providers Sending Monthly Billing/Invoices
to Clients Requesting Payment Providers Building a Budget Based on
Expected Donations as Opposed to Using Funds to Expand Services
“Program Income” Accounts Receivable in Provider Records
Service Not Provided Unless Client Donates (Transportation Vouchers Sold to Clients at a Discount)
Cost Sharing Not Yet Implemented in California Some Excluded Services State & AAA Requirements Before
Implementation Sliding Scale Based on Individual
Income and Cost of Service Can’t Be Denied Service for Failure
to Make Cost Sharing Payment
Excluded Services Information & Assistance Outreach Case Management Ombudsman Elder Abuse Prevention Legal Assistance Congregate & Home-Delivered Meals
Matching Contributions Matching Requirements Added to CDA
Contract Exhibit B Minimum Requirements Verified
During Budget & Closeout Review Must Result in an Expansion of
Services Sources of Match Must Meet Definition CDA Onsite Monitoring to Review
Source Documentation
Minimum Match Requirements Title III
25% Administration 10% Program (III B, III C-1, III C-2, III D) 25% Program (III E)
Title V 10% (Met With State Resources)
CBSP ADCRC - 25% Cash and/or In-kind Brown Bag - 25% Cash & 25% In-kind
Sources of Matching Funds Third Party In-kind Contributions Costs Incurred by the Grantee or
Subgrantee Other Cash Contributions State & Local Public Agencies Verified During Onsite Monitoring
(CDA & AAA)
Expansion of Services
+ =75% 25% 100%
Title III E Federal
(CDA Allocation to AAA)
Title III E
Non Federal (Local Funds)
Minimum Title III E Program
CRCAcme
Caregiver Training
Match Because CRC Funds Spent on III E Clients
$ $
Not Match Because no funds Spent on III E Clients
Nutrition Services Incentive Program (Formerly USDA) No Longer Based on Meal Rates Allocation Based on Prior Year Meals Allocation Adjusted When CDA
Receives NSIP Allocation NSIP Funds Automatically Paid to
AAAs the First Month of Each Quarter Meal Counts Reported With Monthly
Title III/VII Expenditures
Questions?
Thank you