1 public health monitoring summit september 2008 public health monitoring summit september 2008

11Public Health Monitoring Summit SePublic Health Monitoring Summit September 2008ptember 2008

Public Health Monitoring Public Health Monitoring SummitSummit

September 2008

Public Health Monitoring Summit SePublic Health Monitoring Summit September 2008ptember 2008

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AgendaAgenda• Purpose• Definitions and Terms• The Life Cycle of a Grant• Responsibilities• General Monitoring Overview• Monitoring “Special” Subrecipients• Fiscal Monitoring• Reporting Requirements• Upcoming Activities• Tools and Resources• Needs?


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PurposePurpose

To ensure that all DPH monitors are equipped to be successful monitors by providing the following information:

– A review of the monitoring process– An update on monitoring in DPH– Tools and Resources– Opportunity to explore needs and concerns


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Definitions and TermsDefinitions and Terms• Grant: An award of financial assistance from a federal agency to a recipient to carry out a public

purpose of support or stimulation authorized by a law of the United States or North Carolina law.

• Grantor: An entity that makes a grant. For our purposes, either the federal government or state government.

• Grantee: A non-state entity that receives State funds (including federal funds that pass through the State) as a grant from a State agency.

• Subrecipient: Same as grantee.

• Compliance Supplement: An instrument used to assist auditors in performing the required audits per OMB Circular A-133.

• Compliance Requirements: Compliance Supplements for each program list which of the 14 Federal requirements with which that program must comply. The State adds a 15 th requirement, Conflict of Interest.

• Contract: a binding agreement between two or more persons or parties; especially one legally enforceable.


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Outcome

Monitoring

Service

Contract A A

OutputOutput

PROGRAM

Grant Application


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The Life Cycle of a Grant The Life Cycle of a Grant

• Refer to Handout # 1


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Funding information is posted to the Catalog of Federal Domestic Assistance & assigned a CFDA #

State submits an application for grant to federalgovernment

Federal government reviews application

Feds denygrant

Application

Feds approve & provide funding

to state

Feds distribute grant money as block grants tostate

State decides to subcontract some or all of the program

admin.

Stateadministersprogram

State agencyreceivesfunding

State reports use of funding to

funding body

End

State puts out Request for

Application

Proposalssubmitted

State selectscontractor(s)

Contract signed

Contractor begins work

State agency performs monitoring activities as defined in monitoring plan

Contract period ends

If funding exceeds$500K per year

contractor must haveaudit

Legislature designates state

appropriation forprogram

State justifies sole service


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Federal Agency ResponsibilitiesFederal Agency Responsibilities

Federal Agencies Post Funding Opportunities on the Grants.gov website

– Review grant proposals from states and other non-federal entities

– Evaluate proposals against established criteria– Award grant money– Advise funded agencies of requirements– Provide technical assistance– Ensure money is spent as designated


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State Legislature ResponsibilitiesState Legislature Responsibilities

• Provide State Appropriation to fund specific initiative

• Designate responsible agency

• Advise how funds are to be used

• Establish reporting requirements


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State Agency ResponsibilitiesState Agency Responsibilities

• To accomplish the work. This could be done by:

• The state directly

• Contractors


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State Agency Responsibilities State Agency Responsibilities

If State Agency decides to contract, they have two options:

• Put out for a Competitive Bid

• Justify a sole source contract

Either way, the State Agency selects a contractor or contractors by evaluating proposals against established criteria.


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State Agency and Contractor State Agency and Contractor ResponsibilitiesResponsibilities

• In Contract Negotiations, ensure Contract includes:– Terms and Conditions– Scope of Work– Performance Measures– Federal Government Required Certifications– Accountability– Reporting Requirements– Monitoring Information

• Contract Execution


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Subrecipient’s ResponsibilitiesSubrecipient’s Responsibilities

• Ensure their staff is trained and competent

• Do the work

• Adhere to contract terms

• Report as required to funding agency and OSA


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Everybody’s ResponsibilityEverybody’s Responsibility

• To meet program objectives.

• To spend money appropriately.


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What is Monitoring?What is Monitoring?• Regular observation and recording of

activities taking place in a project or program.

• Process of routinely gathering information on all aspects of the project– Check on how activities are progressing– Give feedback about progress– Make decisions for improving performance


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Why Must We Monitor?Why Must We Monitor?

• To ensure accountability

• To verify that funds are being spent for intended purposes

• To meet the requirements of GS 143C-6-23

• To confirm continuation of funding

• It’s just good business sense


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Who Must We Monitor?Who Must We Monitor?

We are required to monitor all subrecipients, which is any entity with which we have a Financial Assistance arrangement. This includes:

• Non-profits• For profits• UNC System• Local health departments• Other units of Local Government


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MonitoringMonitoring

When does Monitoring Begin?

• Pre-Award – Site visit– Risk Assessment – Research contracts with other programs or

agencies (Subrecipient Monitoring System and OSBM Suspension List)


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MonitoringMonitoring

Pre-Award Risk Assessment Factors:• Subrecipient’s Stability• Geographic Problems• Amount of award vs. total resources• Susceptibility to fraud – based on minutes

and internal controls• New program• Public or legislative scrutiny


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How Do We Monitor?How Do We Monitor?Each division must:

• Develop an annual monitoring plan for all subrecipients.

• Develop program plans that address monitoring needs specific to each program.

• Ensure that all internal staff conducting any monitoring activity are trained and that efforts are coordinated internally.

• Update the DHHS Subrecipient Monitoring System.


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Monitoring PlanMonitoring PlanBefore contract is finalized, determine

frequency and types of monitoring activities. Base this on:– Risk– Funding Source Requirements– Compliance Supplements

Include monitoring plan in contract and/or provide link to your monitoring plan in Employee Toolkit.


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Monitoring ActivitiesMonitoring Activities

• Review of Programmatic Reports• Review of Financial Reports• Review of Contract• Review of Self-Assessment of Internal Control• Review of Historical Findings• Telephone Contact• Follow-up on Prior Year Audit Findings• On Site VisitsAs long as it’s documented, it counts.


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Monitoring by Compliance Monitoring by Compliance SupplementsSupplements

• The Compliance Supplement for each program should be reviewed before a monitoring event to see which compliance requirements apply to the program.

• See Handout #2 for Compliance Requirement definitions.

• Why do we do that? Stay tuned.


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Fiscal MonitoringFiscal MonitoringDo not need to be an accountant. Ask simple

questions, such as:• How many checkbooks do you have and why?• How do you handle petty cash?• Can you show me your journals and ledgers and

walk me through?• Can I review your invoices and compare them to

your canceled checks?• How many signatures do you require on a check

and does this match what is in your policy and procedures?


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Analysis of Monitoring EventsAnalysis of Monitoring Events

Look for Red Flags:• Inability to clear outstanding issues• Letters of complaint• Inaccurate/incomplete/late project submissions

or progress reports• Failure to meet agreed-upon schedules• Failure to comply with terms of contract or

agreement• Staff turnover/inexperienced staff• Change in leadership; Board turnover


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Monitoring “Special” SubrecipientsMonitoring “Special” Subrecipients

• Universities:

• UNC System– Historically low risk

• Private Universities and Colleges:– Considered low risk, unless a red flag

appears

Both can be monitored minimally fiscally (will be added to divisional plan)


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Local Health Departments• Only required for Financial Assistance arrangements• LHDs complete a Self Assessment of Internal Controls

Annually • Program Monitoring performed by Program monitors• Fiscal Monitoring performed by Administrative

Consultants • ACs notify appropriate program if finding• Local Public Health Districts submit Quarterly Fiscal

Monitoring Report to the DHHS Office of the Controller


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Special Appropriations

• They must meet GS 143C-6-23 requirements.

• Do best you can with what you’ve got.


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Monitoring vs. AuditingMonitoring vs. Auditing

• Monitoring is done prior to execution of the contract and throughout the life of the contract.

• Auditing is done after the end of the contract period.

• We should use compliance supplements to monitor since auditors use compliance supplements to audit.


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Misuse of FundsMisuse of Funds

• If you become aware of a possible misuse of funding, it is your duty to report this to the Office of the State Auditor. You can do this anonymously.

• If it’s a LHD, inform supervisor of program issue immediately. Use chain of command to report. They are to be reported to the Local Government Commission (LGC).


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GoalsGoals

• There will be no findings because we have monitored so well.

• The Office of the State Auditor will not be called in to do a audit.

• We will not be surprised to be in the N & O.

• Work is done correctly, money is spent accordingly, target measures are met.


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G.S. 143C-6-23G.S. 143C-6-23 Subrecipient Subrecipient Reporting RequirementsReporting Requirements

Level 1 - $1 - $24,999 due within 6 months of entity’s fiscal year endCertificationState Grants Compliance Reporting

Receipt of < $25,000.

Level 2 - $25,000 - $499,999 due within 6 months of entity’s fiscal year endCertificationState Grants Compliance Reporting

Receipt of >= $25,000 Schedule of Receipts and ExpendituresProgram Activities and Accomplishments

Level 3 - $500,000 or more due within 9 months of entity’s fiscal year endCertificationState Grants Compliance Reporting

Receipt of >= $25,000 Yellow Book or A-133 Single AuditSchedule of Federal and State AwardsProgram Activities and Accomplishments

Note: The levels above are the total annual receipts for all grants from State agencies.


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G.S. 143C-6-23G.S. 143C-6-23 Subrecipient Reporting Subrecipient Reporting RequirementsRequirements

Exceptions:

• Local government entities – they are not subject to reporting to OSA under GS 143C-6-23. They report to the Local Government Commission.

• State agencies.


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Grants Information CenterGrants Information Center

• Statewide automated system created by OSA that allows grantees to enter aforementioned reports electronically. Also provides a tracking and alert mechanism for grantees.

• Forthcoming enhancement will allow grantors to view these reports.

• Does not include local governmental entities or other state agencies.


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Penalties for Failure to ReportPenalties for Failure to Report

• If a subrecipient fails to report or if reports are incorrect or incomplete:

• OSA maintains a non-compliance list of reports that are at least 30 days overdue.

• After two written requests for late reports, DHHS suspends funds.

• The late reporters are put on the OSBM Suspension of Funding list.

State agencies are prohibited from disbursing financial assistance to any grantee that has not complied with the reporting requirements.


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Upcoming ActivitiesUpcoming Activities

• Entering Actual Monitoring Activities into the Subrecipient Monitoring System - ????

• Systems Merger – Effective ????

• Monitoring Plan Update – Due January

• Compliance Supplement Updates – Due January

• OSA Training Series


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Subrecipient Reporting

Division Contract System

Functionality

DHHS Systems Merger DHHS Systems Merger ProjectProject

DHHS Performance Management

Database

Subrecipient

Monitorin

g

System

DHHS Contracts

Database

Program Management

Database


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Tools and ResourcesTools and ResourcesFor GrantorsFor Grantors

Sources for Risk Assessment:• OSA’s Establishing Effective Grant

Monitoring Programs Training - Handout #2

• http://www.ncauditor.net/NonProfitSite/training/2006/EffectiveGrantMonitoring/Establishing%20Effective%20Grants%20Monitoring%20Program.ppt

• OSA Best Practices Newsletter• http://www.ncauditor.net/NonProfitSite/newsletters/Newsletter-2008-Fall.pdf

• AuditNet – The Global Resource for Auditors

• http://www.auditnet.org/docs/risk1.doc


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Tools and ResourcesTools and ResourcesFor GrantorsFor Grantors

• Subrecipient Monitoring System (to be replaced by Integrated System)

• DPH Monitoring Plan

• Program Monitoring Plans

• DHHS Office of the Controller

• DHHS’s and OSBM’s Suspension of Funding Lists

• Donna Gregory and Kathy Hardison


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Tools and ResourcesTools and ResourcesFor Grantors and GranteesFor Grantors and Grantees

OSA’s Grants Administration Certification Program• Establishing Effective Grant Monitoring

Programs• Creating Effective Policies and Procedures• Basics of Internal Control• Identifying Allowable and Unallowable Costs• Grants Update Training OSA’s quarterly newsletter


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Needs????Needs????

• Training of Subrecipients?

• Monitoring Universities?

• More trainings for monitors? Topics?

• Other support in specific areas?

• Quarterly Monitors Meetings?


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Thank you!Thank you!

• WE’VE COME A LONG WAY, THANKS TO YOU!

1 public health monitoring summit september 2008 public health monitoring summit september 2008

Documents

state agency responsibilities

monitoring process

state funds

state government

state appropriation

designated slide

federal requirements

nonstate entity