FFY2013 EAP Annual Training Part 6: Assurance 16; Program Fiscal Management; Local Plan; Incidents & Appeals

1. FFY2013 EAP Annual Training Part 6: Assurance 16; Program Fiscal Management; Local Plan; Incidents & Appeals

2. Chapter 9 – Assurance 16

3. Chapter 9 – Assurance 16 Intentions • Promote A16 as an activity that contributes to maintaining affordable, continuous, and safe home energy for low-income Minnesota households • Clarify EAP A16 policy and expectations • Emphasize the importance of A16 for household emergencies • Reiterate and clarify the need for documentation

4. Chapter 9 – Assurance 16 EAP Improves HH Outcomes in 3 Ways: • Primary Heat payments • Crisis payments • A16 case management

5. Chapter 9 – Assurance 16 What It Is Assurance 16 allows states to spend up to five percent (5%) of their LIHEAP Block Grant funds on “services encouraging and enabling households to reduce their home energy needs and thereby the need for energy assistance, including needs assessment counseling, and assistance with energy vendors.” Assurance 16 (A16) funds may also be used for A16 reporting.

6. Chapter 9 – Assurance 16 Minnesota Focus • The statewide focus of A16 continues to be case management in support of the Coordinated Responsibility Model Required A16 Activities • Outreach • Advocacy • Referral

7. Chapter 9 – Assurance 16

8. Chapter 9 – Assurance 16 A16 a A16 A16 A16

9. Chapter 9 – Assurance 16 Why it matters: Outreach

10. Chapter 9 – Assurance 16 Why It Matters: Advocacy & Referral Source: 2005 RECS

11. Chapter 9 – Assurance 16 Why It Matters: Referral & Outreach Source: 2006-10 American Community Survey Public Use Microdata Sample & 2005 RECS

12. Chapter 9 – Assurance 16 How Are We Doing? Source: Minnesota Energy Assistance Program (eHEAT)

13. Chapter 9 – Assurance 16 How Are We Doing? Source: Minnesota Energy Assistance Program (eHEAT)

14. Chapter 9 – Assurance 16 How Are We Doing? Source: Minnesota Energy Assistance Program (eHEAT)

15. Chapter 9 – Assurance 16 Allowable Activities • EAP-related outreach, referral and advocacy • A16 does not fund all of an SP’s outreach, referral and advocacy activities • A16 is EAP money for EAP activities Allowable Expenditures • The direct preparation, performance and recording of EAP outreach, EAP referral and EAP advocacy activities can be charged to A16, including the related portion of fringe benefits earned

16. Chapter 9 – Assurance 16 Examples of Activities & Information Chargeable to A16 • Staff time for an EAP staff person making a referral to Head Start • Needs assessment counseling for EAP households • Working with energy vendors on behalf of a household • EAP outreach materials and activities • Other EAP public relations measures and activities  • Postage to mail A16 materials and information • Non-EAP outreach workers’ travel time, mileage and time assisting with EAP application during home visits

17. Chapter 9 – Assurance 16 A16 Case Management Activities • Encouraging households to sign up for CWR protection, where applicable • Helping households identify a reasonable payment amount for their budgets • Helping households negotiate a reasonable payment agreement with energy vendors

18. Chapter 9 – Assurance 16 Examples of Expenditures Not Chargeable to A16 • A Head Start employee who spends time eliciting client needs and ascertains the household needs EAP • An executive director speaking to a community group about all programs the SP offers • Costs for office space, desks, equipment, chairs, and supplies • Staff time for answering the SP phone when a caller inquires about SP programs available to assist their family • Postage and time used to mail or hand out an EAP or other application • Primary Heat or Crisis payments • ERR, low-cost residential weatherization, or other cost-effective energy-related home repair activities

19. Chapter 9 – Assurance 16 Documentation: Why It Matters • Empowers you to set goals and track your progress • Enables state and others to verify your A16 activities are taking place and are eligible Best Practices • Document activities as they occur to maintain an accurate record • Train your staff on the objectives of A16 and reasons for doing it • Use eHEAT logs as a basis for charging against A16 • The same task can be recorded several times if it takes several steps • Questions? Ask your Program Performance Auditor.

20. Chapter 9 – Assurance 16 Documentation:Best Practices (Continued) • Enter enough detail in the eHEAT notes field to differentiate A16 from Admin activities • Notes Examples: Who, What, Where, When, How

21. Chapter 9 – Assurance 16 Q&A

22. Ch. 16–Fiscal Management

23. Ch. 16–Fiscal Management Manual Changes • Property Management Requirements • Record Retention Requirements

24. Ch. 16–Fiscal Management Property Management Requirements • Changes in Property Management are based on current federal and state requirements • Impetus is concern safeguarding sensitive data and increasingly scarce resources • Let the appropriate people in your agency know

25. Ch. 16–Fiscal Management Property Management Requirements Equipment Service Providers must follow the standards found in OMB Circulars A-110 Attachment N. Property Management Standards and Attachment O. Procurement Standards; A-102 Common Rule Section .31 Real Property, .32 Equipment and .36 Procurement as applicable. In addition, the following policies regarding sensitive equipment apply.

26. Ch. 16–Fiscal Management Sensitive Equipment Sensitive Equipment means tangible, nonexpendable, personal property having a useful life of more than one year that is generally for individual use; could easily be sold or subject to pilferage or misuse; or could be used to store sensitive personal information

27. Ch. 16–Fiscal Management Sensitive Equipment • Examples include:

28. Ch. 16–Fiscal Management Property Management Requirements Procedures for managing equipment will meet the following requirements: • Property records must be maintained • A physical inventory of the property must be taken and the results reconciled with the property records at least once every year • Procedures must be in place to: • Prevent loss, damage, or theft of the property • Keep the property in good condition • Ensure the highest possible return if the property must be sold

29. Ch. 16–Fiscal Management Inventory Requirements • Individual pieces of EAP-funded sensitive equipment must remain recorded in the Service Provider’s inventory records while retained in the Service Provider’s possession for the reasonable estimated life of the respective item • See the table below for the estimated useful life of possible EAP-related sensitive equipment

30. Ch. 16–Fiscal Management Equipment Disposal or Transfer • In addition to equipment with a value of $5,000 or greater, DOC must approve disposal of sensitive equipment • SPs must ensure and certify that any information retained in the equipment that is subject to data practices requirements is completely removed prior to disposition • Removal must be done by overwriting the data • Equipment capable of holding sensitive data must be overwritten at least 6 times before their disposal or transfer will be approved

31. Ch. 16–Fiscal Management Record Retention • Service Providers are required to maintain copies of all books, records, documents, and accounting procedures and practices relevant to EAP for a minimum of six years • Previously, the contract erroneously indicated three years • Contract language: • “Under Minn. Stat. § 16C.05, subd. 5, the Grantee’s books, records, documents, and accounting procedures and practices of the Grantee or other party relevant to this grant agreement or transaction are subject to examination by the State and/or the State Auditor or Legislative Auditor, as appropriate, for a minimum of six years from the end of this grant agreement, receipt and approval of all final reports, or the required period of time to satisfy all state and program retention requirements, whichever is later.”

32. Ch. 16–Fiscal Management Q&A

33. FFY2013 EAP Local Plan

34. FFY2013 EAP Local Plan 3. Control Activities 3.1. Program Control Activities 3.2. Control Activities – Fiscal 2013 Updates 3.1.6. ERR-Control questions are improved 3.1.7. Crisis verification is added

35. FFY2013 EAP Local Plan 3.1. Program Control Activities (8 parts) 3.1.1. EAP Application processing system: timeliness, EAP tools, accuracy, consumption, reporting … 3.1.2. EAP System Partnerships: vendors, outreach partners 3.1.3. EAP Hours of Operation 3.1.4. Intake Sites 3.1.5. EAP Duties and Functions 3.1.6. ERR-Control 3.1.7. Crisis verification (new) 3.1.8. Assurance 16 Services

38. 2 1 1 1 2 5 1 2 5 2 2 1 2 1 2 1 2 1 1 1 7 2 4 2 38

41. FFY2013 EAP Local Plan 3.2. Control Activities – Fiscal (5 parts) 3.2.1. Service Provider Fiscal Information 3.2.2. Fiscal Transactions 3.2.3. Fiscal Budgeting, Allocation and Reporting 3.2.4. Inventory Controls 3.2.5. Fiscal Activities

44. FFY2013 EAP Local Plan Q&A

45. Chapter 12 Incidents & Appeals

46. Chapter 12 Incidents&Appeals Highlights • Context • Policies and procedures • Expanded types of incidents • New overpayment policies and recovery processes • Revised appendices • Reminders and areas for improvement

47. Chapter 12 Context • FFY12 chapter was improved and reorganized • Numerous corrections required this year • Office of the Legislative Auditor • Limited funds increases pressure for: • Accuracy of benefits • Full recovery of overpayments

48. Chapter 12 Incidents Types of Incidents • Event Notifications • Data Security and Breaches • Errors • Waste (new) • Abuse (new) • Suspected Fraud • Disasters and Emergencies

49. Chapter 12 Definitions Definitions Error (redefined) • Unintentional misuse of program funds • Unintentional mistakes in the handling and processing of application information • Isolated and affects one or just a few households • If an unintentional mistake affects more households follow waste procedures

50. Chapter 12 Definitions Definitions (continued) Waste • Waste occurs as the result of resources being consumed by inefficient or non-essential activities, including systemic errors or misapplication of policy Abuse • Abuse occurs as the result of purposeful departure of policies and procedures where resources are improperly used Impacts • HHs, integrity of funds, reputation and scarce resources