HEALTH DISPARITIES GRANT PROGRAM

August 11, 2014

Program Contact: Deanna J. Butler, Office of Health Equity

Fiscal Contact: Francesca Isabelle, Prevention Services Division

This presentation will provide…

This presentation is designed for program managers and fiscal staff working on the Health Disparities Grant Program

Important program concepts regarding managing the contract, meeting the terms of the Statement of Work, and reporting progress

Important fiscal concepts regarding managing the contract, remaining compliant to existing rules and regulations, invoicing and cost reimbursements

An overview will not include everything you need to know to contract with CDPHE, and if you have additional questions, please use the contacts below.

Contract Basics

Read your contract!

Reference it regularly

Use both the statement of work and budget to complete work promised

Know what is expected of you

Program and fiscal staff can help

Program Responsibilities

Utilize the Statement of Work and reference it often as a legal and binding document

Know when deliverables are due and ask for assistance if they cannot be met

Ensure that grant expenditures are consistent with activities promised in the statement of work

Reporting

Reporting

Submit quarterly performance reports outlining achievements during the quarter.

Explain whether the activities were met, meeting, not started, partially met, unmet, and whether demographic data was available and provided.

Reporting Con’t.

Quarterly Reporting Dates

Quarter 1 - July 1, 2014-September 30, 2014 (Report due October 15, 2014)

Quarter 2 - October 1, 2014-December 31, 2014 (Report due January 15, 2015)

Quarter 3 - January 1, 2015-March 31, 2015 (Report due April 15, 2015) Quarter 4 - April 1, 2015 - June 30, 2015 (Report due July 15, 2015)

Reporting Con’t.

A Final Report must be submitted within 30 days of the end of the grant cycle, and conclusion of the 3-Year funding (July 30, 2015)

A summary of outcomes achieved and the lessons the grantee learned from the implementation of the grant services

The number of people and target population the grantee served and the services provided

Measures or indicators used along with the data methodology and data variables How results will be used, disseminated and communicated Whether plans for sustainability after the grant period were implemented, what are

they Lessons Learned Summary/Conclusions Recommendations  

Reporting Con’t.

You will enter demographic the data into the Survey system, address: www.surveymonkey.com/s/KPWYZW3

The survey will ask about the success of deliverables, and any immediate program needs you have

Contract Monitoring

Contract Monitoring

Effective July 1, 2009, the Colorado Department of Public Health and Environment (CDPHE) implemented a contract monitoring performance.

Regular contractor performance evaluations are conducted as a routine component of contract monitoring

A handbook is used as a standardized process within CDPHE to conduct contractor performance evaluations

Contractor performance is defined as how a contractor meets the obligations of the contract

Obligations include all standards, requirements and deliverables stated in the contract in addition to adherence to the budget, price and provision of customer service.

Contract Monitoring Con’t.

Performance evaluations will occur regularly throughout the contract period. CDPHE staff has the option of conducting evaluations 3 times per year (Level 3) or 4 times per year (Level 4).

A final evaluation will occur at the end of the life of the contract. For construction contracts valued at $500,000 or more, an additional construction contract evaluation must be completed in addition to the final evaluation as required by C.R.S. §§ 24-102-205, 24-102-206, 24-103.5-101.

Contract Monitoring Con’t.

Factors

I. Quality – overall performance, delivery of products and services

II. Timeliness – quarterly reporting, billing, response to program requests

III. Budget – reimbursement requests, consistency with activities and deliverables, response to fiscal requests

IV. Business Relations – agency representatives are knowledgeable about the project and responsive to program and fiscal requests

V. Deliverables – Statement of Work progress, deliverables were complete, accurate and submitted in a timely manner, quality of quarterly reports

Types of Monitoring Activities

I. Site Visits Periodically, your agency may be required to allow CDPHE staff access to its

operations to perform site reviews, data reviews, fiscal reviews or other evaluations of your program.

Requires that your agency cooperate during the course of such visits and reviews.

Must comply with recommendations resulting from visits and reviews, with appropriate corrective action(s) taken within the prescribed time frame(s).

II. Compliance Monitoring and Notifications

III. Ongoing communication with the program, fiscal, and subject matter expert staff

IV. Requests for documentation

Regulations and Policies

Regulations your agency is required to know and abide by:

2 CFR, Part 225 (formerly OMB Circular A-87) Cost Principles for State, Local and Indian Tribal Governments

2 CFR, Part 601 (formerly OMB Circular A-102) Uniform Administrative Requirements for Grants and Agreements with State and Local Governments (Common Rule)

OMB Circular A-133 Audits of States, Local Governments and Non-Profit Organizations

Regulations your agency is required to know and abide by Con’t.:

Hatch Act Prohibits use of federal funds for partisan political purposes of any

kind 5 U.S.C. 1501-1508 and Public Law 95-454, Section 4728

Davis-Bacon Act Fair wages in accordance with local market conditions for laborers

and mechanics employed by contractors and subcontractors 40 U.S.C. 276A – 276A-5

Nondiscrimination on basis of race, color, national origin, age or disability 42 U.S.C. 6101 et seq., 42 U.S.C. 2000d and U.S.C. 794

Regulations your agency is required to know and abide by Con’t.:

Americans with Disabilities Act Uniform Relocation Assistance and Real Property Acquisition Act Federal Acquisition Streamlining Act of 1994

Prohibits use of federal money to lobby the legislative body of a political subdivision of a State Section 2101, Public Law 103-355

Health Insurance Portability and Accountability Act of 1996 (HIPAA) Must comply if your agency is a covered entity

42 U.S.C. 1320d – 1320d-8

Regulations your agency is required to know and abide by Con’t.:

If agency expends >$500,000 in federal funds in a fiscal year: A-133 annual audit required Submit a copy of audit report to State Internal Audit Office within 30

calendar days of receipt, or 9 months of end of fiscal year (whichever is earlier)

Take corrective action within 6 months of report to address any noncompliance

Regulations your agency is required to know and abide by Con’t.:

SB 07-228 Requirements for monitoring performance under state contracts and

tracking related information in CMS Increased contract monitoring measures Final contractor performance evaluations Establishment of statewide CMS with public interface

CDPHE Policy Ongoing contract monitoring by program and fiscal staff Contractor performance evaluations

Special Provisions

Address required Colorado State Controller approval, fund availability, governmental immunity, compliance with law, prohibition of software piracy, conflict of interest, and exclusive employment of individuals who are lawfully present in the U.S. and authorized to work in the U.S.

Additional Provisions

This is the most critical portion of the contract to be familiar with, for both program and fiscal staff.

Read it and refer to it often!

Additional Provisions – Funding & Billing Information

CFDA number and federal funding source (if applicable), details on State funding mechanism and purpose of funding

Allowable reimbursement period

Requirement for Reimbursement

Budget Revisions

Additional Provisions – Subcontracting

Work may be performed using subcontracts with other providers or collaborative partnerships with other community partners

Requires prior written approval from Program Manager Relationship and roles must be formalized in an MOU or other

binding contractual agreement Subcontractor(s) must adhere to all requirements of the contract Your agency must maintain records of subcontracts for at least three

years

Additional Provisions Con’t.

Program-specific Federal and State Regulations HIPAA Business Associate Determination

Indicates whether State has deemed the contractual relationship with your agency to constitute a Business Associate relationship under HIPAA

In most instances, your agency will not be considered a Business Associate

Program-specific Requirements Funding adjustments

Financial Risk Assessment Management

Local Agencies _Director of Contracts and Management of Performance Monitoring Unit

Site Visits Non-Local Agencies _Contract Compliance Officer Risk Level-Low, Medium and High Memo Financial Assessment Questionnaire

Billing

Your Approved Budget

A copy of your original approved budget will be included in your contract.

If you revise your budget, you will need to base your spending on the

latest approved budget and make sure all parties at your agency are informed of the revision.

General Billing Information

You can only bill CDPHE for items listed in your approved budget. You will bill by submitting a standardize customize invoice form posted at https://www.colorado.gov/pacific/cdphe/standardized-invoice-form-and-links listed as CDPHE STANDARD Reimbursement invoice Form.

You may use the instructions How to Use the CDPHE Reimbursement Invoice Form to guide you how to fill out your reimbursement invoice form at https://www.colorado.gov/pacific/cdphe/standardized-invoice-form-and-links

You may request a budget revision if your situation changes and you need to realign your budget. Please request the budget revision form from the OHE Fiscal Officer if you are in this situation.

General Billing Information Con’t.

The project billing period is July 1, 2014 through June 30, 2015

Your agency should have a mechanism in place to track expenses relating to this contract separately from all other expenses your agency incurs.

State and Federal rules mandated that contractors can NOT bill a contract for any expenses that occur outside of the contract period.

You are not required to report match in your invoices, please do not fill out the match or in-kind column

General Billing Information Con’t.

Invoicing

Agencies must invoice using the same categories listed in their approved budget.

Agencies are not required to submit supporting documentation with their reimbursement invoice form but this will be reviewed during fiscal site visits or when requested.

Supporting documentation for non-local agencies are required according to their financial risk rating level. Financial risk ratings are high, medium or low.

General Billing Information Con’t.

Invoicing

Invoices are due 45 days after the monthly period ends.

Financial Risk Rating. The results of an FRMS assessment that determines a contractor's risk of non compliance with CDPHE contracts and used to determine the frequency of monitoring (invoice sampling). FRMS assesses Local Agencies.

Financial Risk Rating. Risk assessment, past performance scores and if applicable, site visit and desk review findings are combined to produce a final financial risk rating for each potential grantee. The Compliance Unit assesses Non-Local Agencies.

General Billing Information Con’t.

Federal Time and Effort Requirements

If employees work on and are charged to multiple projects , the employees must fill out timesheets/ activity reports detailing time worked on each project.

Salary must be allocated to the projects based on those timesheets/ activity reports.

These records do not need to be sent to CDPHE, but will be reviewed during fiscal site visits or when requested.

General Billing Information Con’t.

Food and Meal Requirements

Contracting agencies are required to steward State & Federal money, using it in the most effective ways possible.

Food at staff meetings is not an allowable cost. There are a few circumstances where purchasing food/drink is an allowable cost, for example, food for outside stakeholders tied to an event or conference.

Food / meal costs will be subject to scrutiny.

General Billing Information Con’t.

Contract Number and Encumbrance

This year, your agency received a contract with the new contract number in the document. However, we do not have the encumbrance number available yet. As soon as we have it available, the OHE fiscal officer will send a pre-populated standardized invoice template.

General Billing Information Con’t.

Indirect Cost

Most CDPHE contracts allow agencies to bill CDPHE an indirect rate based on the following:

A. Agency Negotiated Approved Indirect Cost Rate.

B. In the absence of a negotiated approved indirect rate, a cost allocation method may be used.

Follow your budget, if indirect was approved you can used indirect.

General Billing Information Con’t.

Budget Flexibility

You are authorize to transfer funds on Direct Costs from one line item to another line item in your approved budget but you must notify the SBHC Program Director at CDPHE by email prior to the transfer. The cumulative changes on total direct costs of your approved CDPHE funding may not exceed 25% of your total funding. Indirect cost cannot be increased.

You cannot transfer more than 25% on the cumulative changes on CDPHE total direct costs of your total funding without a written Budget Revision Request Form approved by your SBHC Program Director at CDPHE.

General Billing Information Con’t.

Budget Major Line Items

Your budget includes major budget categories, called Major Line Items.

These may include:

A. Personal Services including Fringe Benefits

B. Supplies and Operating Expenses

C. Travel

D. Other Costs

E. Contractual

F. Indirect

General Billing Information Con’t.

When you need to do a budget revision

Budget Revisions are required in most cases for CUMULATIVE changes in excess of 25% of the total direct costs or $250,000, whichever is less, between approved budget categories.

Budget revisions are also required to incur expenses against a budget category with zero funds budgeted. To open a new budget category line, one must seek approval PRIOR to incurring expenditures against the new line.

When requesting a line be opened for Contracts or Personnel Services, review of the contract scope of work is necessary. This will increase the amount of time required to obtain approval. Please plan accordingly.

General Billing Information Con’t.

Budget Revisions and Staff Turnover

You do NOT need to submit an official budget revision if one staff member left the organization and their duties are being taken over by a NEW staff member in the SAME POSITION.

When this happens, you would just put the new employee’s name and position on your billings and include a note each month that describes the situation. For Example, Sara Jones replaced Angela Thomas.

General Billing Information Con’t.

When to Check with your Fiscal Contact (as they may not require a budget revision)

When the cumulative changes on your CDPHE total direct cost is reaching the 25% of your total funding, your program manager will determine if an official budget revision is required at that time. Compare your original budget with the changes you plan to make to determine if you are within the 25% cumulative changes on your CDPHE funding. An example is provided in the next slide.

The Fiscal Officer may choose to accept written notification instead of an official budget revision for those circumstances.

Budgets: Major vs. Minor Line Items

On the example to the left, Total Personnel and Total Operating constitute Major Line Items.

All other budget lines constitute Minor Line Items.

This is important because it may help you determine when your CDPHE Total Direct Cost cumulative changes are reaching the 25% of your Total Funding.

Within each Major Line Item, you will include more detailed Minor Line items

Example: Original Planned Cumulative Budget Budget Changes

PA Marta Anderson $10,000 20,000 10,000 NP Laura Smith $20,000 40,000 20,000 NP Supervisor Maria Zin $10,000 13,000 3,000Total Personnel $40,000 $73,000

$33,000

Lab Tests $10,000 2,000 Educational Materials $5,000 0 Medical Supplies $30,000 10,000 .Total Operating $45,000 $12,000Total Direct Cost $85,000 $85,000

$33,000

Total direct costs $85, 000 x 25%= $21,250Total cumulative changes= $33,000

Compare the 25% total direct cost to the total cumulative changes. This example NEEDS A BUDGET REVISION prior to incurring expenses.

Sample Invoice

A unique number assigned by contractor

PO Referenced in contract document.

Contractor’s FEIN #

Agency name, address; name, phone #, email of contractor representative

Dates expenses incurred

Contractor signature

Sample Cost Ledger

Budget Revision Request Form

Contractor Name

Contract Period

Contract/Encumbrance

Number

ORIGINAL BUDGET

REVISED BUDGET

VARIANCE

Position Title/ Employee Name

$0.00$0.00$0.00$0.00$0.00$0.00$0.00$0.00$0.00$0.00$0.00$0.00

$0.00 $0.00 $0.00

ORIGINAL BUDGET

REVISED BUDGET

VARIANCE

Total Personal Services

(including fringe benefits)

Project Name

Personal Services

Supplies & Operating Expenses

Justification for Revision

Effective Date of Budget Revision

Colorado Department of Public Health and EnvironmentPREVENTION SERVICES DIVISION- BUDGET REVISION FORM

Program Contact Name,

Title, Phone and Email

Fiscal Contact Name,

Title, Phone and Email

Expenditure Categories Budget Totals

The Office of Health Equity announced a Request for Applications July 31, 2014.

*Current grantees are eligible to apply for funding under this Request for Applications (RFA).

Current grantees:Shall not duplicate or supplant services covered under an existing agreementMay propose new or expanded activities within overlapping time period of RFAsMay propose start date after September 30, 2015 to avoid the overlapping time period 

Program Contacts:

Program ContactDeanna J. Butler, General ProfessionalOffice of Health Equitydeanna.butler1@state.co.us(303) 692-3474

Fiscal Contact Francesca Isabelle, Fiscal OfficerPrevention Services Divisionfrancesca.isabelle@state.co.us(303) 691-4963

Questions???