Program and Fiscal Compliance Issues

1
Program and Fiscal Compliance Issues

• Geri Baucom, Fiscal/Contracts Specialist
• Johnna Meyer, Policy Manager
• California Department of Aging

2
Program and Fiscal Compliance

• Fiscal Process Overview
• Direct Services
• Program Development (PD) or Coordination (C)
• Consumer Contributions
• Matching Requirements
• Nutrition Services Incentive Program (NSIP)

3
Fiscal Process Overview

• Allocations
• Budgets, Budget Revisions, Contracts
• Monthly Reporting
• Financial Closeout Reports/Closeout Statements
• Audit/Audit Resolution
• Final Closeout

4
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

5
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

6
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

7
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

8
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

9
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

10
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

11
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

12
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?

13
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?

14
Consumer Contributions (OAA Section 315)

• Voluntary Contributions
• Cost Sharing

15
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
• Cant be Denied Service for Not Contributing
• Must be Used to Expand Services

16
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)

17
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
• Cant Be Denied Service for Failure to Make Cost
  Sharing Payment

18
Excluded Services

• Information Assistance
• Outreach
• Case Management
• Ombudsman
• Elder Abuse Prevention
• Legal Assistance
• Congregate Home-Delivered Meals

19
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

20
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

21
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)

22
Expansion of Services
Not Match Because no funds Spent on III E Clients
Match Because CRC Funds Spent on III E Clients
Acme Caregiver Training
CRC




100
75
25
Title III E Federal (CDA Allocation to AAA)
Title III E Non Federal (Local Funds)
Minimum Title III E Program
23
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

24
Questions?

• Thank you