Preparing for an Audit: Ensuring Compliance and Efficiency

1. HPE OrientationAudit Touch Points Christopher T. Clarke, PhD, FACHE Chief Financial & Informatics Officer & Cynthia M. Miller, Deputy CFO

2. What, Me Worry?

3. Nobody Likes and Audit!

4. No Worries just preparation “Give me six hours to chop down a tree and I will spend the first four sharpening the axe.”  Abraham Lincoln Adopting the right attitude can convert a negative stress into a positive one. Hans Selye

5. No Small Thing – Your Clinical Trainee Budget

6. Increased OIG Interest In the end the DEO is Responsible “As a result, the Designated Education Officer (DEO) did not establish required local policies and procedures for resident educational activity record keeping, monitoring resident participation in educational activities, and reconciling educational activity records with invoices submitted by the University of XXXX College of Medicine (the medical school).”

7. A well run process relies onSymbiotic Responsibilities DA Process

8. Audit Touch PointsMajor Processes and ResponsibilitiesSlide 1 of 2

9. Audit Touch PointsMajor Processes and ResponsibilitiesSlide 2 of 2

10. Knowledge You Can UseCynthia Miller This Photo by Unknown Author is licensed under CC BY-SA

11. Field/OAA Fiscal Timelines • Sept – OAA releases the upcoming FY’s Target Allowance (Trainee Funding) to VHA Fiscal Service • Oct – VHA Finance Office releases the quarterly Target Allowance to VAMCs (depending on Congress, i.e., budget impacts, Finance’s release of funds could be delayed) • Dec – Needs/Excess (1stqtr). • March – begin submitting updated Rate Schedules and Stipend Memos • March – Needs/Excess (2ndqtr) • June – Needs/Excess (3ndqtr) • July – New Academic Year (position starts) • mid-July to early August – Needs/Excess (4thqtr) • This NE call is early due to VACO Fiscal Service changes in cut-off times. This will result in you having to work with the affiliates to ‘estimate’ the 4thqtr bills.

12. Six Definitions & Key Processes • Disbursement Agreement (2 Kinds – Submitted On-line) • “What It’s Not” – a Contract • “What It Is” – a payroll mechanism by which VA allows a “disbursing agent” to centrally administer salary payments and fringe benefits for physician and dental residents assigned to a VA medical facility. • Disbursing Agent – pays salary and benefits (can be same as sponsoring institution, not always) • Rate Schedule • Stipend Letter • Needs and Excess Report (Submitted On-line)

13. Disbursement Agreements(Timing of the Payments) Payment in Advance • VA agrees to pay up to 80% of estimated charges in advance in each quarter. Payment in Arrears • VA agrees to reimburse the Disbursing Agent based upon receipt of a properly prepared invoice and reconciliation against VA records. • The frequency of payment is monthly or quarterly.

14. Rate Schedules Rate Schedules are used to: • Determines the legal daily rate to pay residents • Analyze Needs/Excess requests. • The DAILY RATE MUST be used to Verify Invoices and estimate costs Rate Schedules must be updated at least annually. • Even if Rates have not changed; • Updates for next AY: begin January – end of June; • Must be updated any time rates change; • VA matches Affiliate – Updates come from Affiliate

15. Rate Schedules Submissions • Usually DEO (CFO in the loop) responsibility to review and negotiate with affiliate before submission to OAA; • Do not simply pass the affiliate rates on to OAA without a review; • Do not ask or allow affiliate to submit to directly OAA • Use OAA Template • # of AL days, Affiliate and Disbursing Agent must be on rate schedule • Best if Benefits are itemized and not estimated by % • What is NOT allowed: • Affiliate administrative expenses (see ECC for these) or • Any items or funding that become property of Resident • Resident Travel (may use local funding, see Handbook 1400.09) • Meals • Housing

16. Stipend Letters • For Medical (260), Dental (174) and Chief Residents (8.5) • Always for Trainees paid by the VA • These Programs are often accredited in the name of VA • Uses “Index Program” to determine Annual Salary • Uses VA Benefits • OAA only approves annual salary • Salary cannot be inflated to compensate for affiliate benefits

17. Needs and Excess Reporting Used as a mechanism to reconcile differences that occur from OAA “Initial Target Allowance” Funding; • Reported Quarterly (On-line) – Negative Replies Required; • Analyzed by OAA before approval; • Reported by Fiscal but DEO should be involved and approve; • Must use proper needs/excess code for that program.

18. Fiscal Budget Reports You Can Use Current Funding Allocations : Medical Care Specific Purpose Funds - Current Funding Allocations http://vaww.oaa.med.va.gov/DBReports/NeedsandExcessCurrentAllocations.aspx/ Needs and Excess Expenditures: Facility Requested Needs and Excess Report http://vaww.oaa.med.va.gov/DBReports/NeedsandExcess.aspx/ http://vaww.oaa.med.va.gov/DBReports/NeedsExcessByProgram.aspx/ Disbursing Agent Rate Schedules by Year/Facility (Multiple pages) http://vaww.oaa.med.va.gov/DBReports/disbDisbursingReport.aspx Associated Health Locality Based Stipend Rates by Facility & Program http://vaww.oaa.med.va.gov/DBReports/LocBasedStipends.aspx http://vaww.oaa.med.va.gov/DBAHealth/RptBaseStipendV2.aspx/ Associated Health & Nursing Funding Allocation Plan http://vaww.oaa.med.va.gov/DBAHealth/ahRptAllocPlan1.aspx/

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