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 • Can’t 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 • Can’t 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