fiscal monitoring gary payne, cpa, cia, cisa unit manager, fiscal monitoring contract oversight...
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FISCAL MONITORING
Gary Payne, CPA, CIA, CISAUnit Manager, Fiscal Monitoring
Contract Oversight & Support Section
WHY?
WHAT IS IT?
WHY SHOULD I CARE?
FISCAL MONITORINGOctober 13, 2009
WHY FISCAL MONITORING?
It’s required by OMB Circular A-133 [Federal Funds] & Uniform Grant Management Standards (UGMS) [State Funds] to:
Ensure Accountability of Taxpayer Funds Disbursed.
‘NUFF SAID!
WHAT IS FISCAL MONITORING?
Single Audits Review, Monitoring, & Follow-up on Single Audit
Findings by HHSC OIG & DSHS Performing On-site & Desk Reviews of Subrecipient
Contractors by DSHS Personnel Adequacy of monitoring sub-contracts executed by DSHS
contractors by the DSHS contractor (i.e. You have to monitor your sub-contractor’s performance/compliance).
There is overlap. A Single Audit’s scope is on the entity’s total Federal or State Awards.
A DSHS Fiscal Review’s scope is more focused. It is targeted on ascertaining contractual compliance with DSHS contract requirements.
WHAT’S THE BIG DIFFERENCE BETWEEN SINGLE AUDITS & FISCAL MONITORING?
THEY SEEM REDUNDANT!
“OK, drill down to what DSHS tests & evaluates?”
It can include any contract requirements included in a DSHS contract.
Governance (re: The Enron & “Bernie” Slide) Allowability of Expenditures Period of Availability Cost Allocation Plans Matching & Program Income Other
“Uhm, this covers a lot of ground. DSHS contracts are pretty voluminous.”
“Could you give me the Cliff Notes version?”
GOVERNANCE
Defined by OMB Circulars, UGMS & Federal Agency Common Rule
Defined by DSHS Contract Requirements Defined by Texas Administrative Code (Community
Centers)
ALLOWABILITY OF EXPENDITURES
Defined by applicable OMB Circulars & UGMS Defined by grant specific terms (i.e. review the DSHS
contract for specific requirements, some grants have specific prohibitions for certain expenditures that would be allowable under most other grants).
PERIOD OF AVAILABILITY
Defined by OMB Circulars, UGMS & Federal Agency Common Rule
It means that transactions must occur within the contractterm. This applies to revenue, expenditures, programincome, and matching costs.
COST ALLOCATION PLANS (CAPS)
Defined by OMB Circulars, UGMS & Federal Agency Common Rule
It means that transactions must occur within the contractterm. This applies to revenue, expenditures, programincome, and matching costs. Discussion of CAPS in detail, is beyond the time limits of this presentation, but can be categorized into the two following aspects:
Has a compliant CAP been submitted? Did the entity follow the CAP?
MATCHING
Matching requirements are defined in DSHS contracts.
Common exceptions include:
Inadequately documented match (particularly in-kind)
Counting other grant expenditures as match for DSHS grants
Match claimed occurred outside contract terms.
PROGRAM INCOME
Inadequately documented program income
Incorrect allocation of program income
Program Income is defined in OMB Circulars, UGMS & Federal Agency Common Rule. Review the DSHS Contract for specific requirements.
Common exceptions include:
OTHER
Waste, Fraud, & Abuse = Referral to HHSC Office of Inspector General for Investigation
“Hey, That’s Scary Stuff! We Don’t Want to Go There!”
But it’s the law. The best means of preventing entering this arena, is to ensure:
Board Governance is providing appropriate oversight of management.
Management operates with appropriate checks & balances (i.e. internal controls).
“Yeah, but how? We’re small and mainly staffed by lay people and volunteers - not attorneys & CPAs!”
Contract with professional staff (attorneys, CPAs, etc.) for appropriate expertise, DSHS contracts generally allow administrative costs to cover such needs.
For assistance you should contact:
Robert Vitek, ManagerFinancial Technical Assistance UnitContract Oversight & Support888.963.7111 x2326 (toll free)512.458.7111 x2326 (direct)[email protected]
TECHNICAL ASSISTANCE SECTION
DSHS has a Technical Assistance Section to advise and help DSHS contractors.
ABOUT DSHS TECHNICAL ASSISTANCE
The DSHS Technical Assistance Unit is designed to assist DSHS contractors with current questions or problems in a prospective manner.
DSHS contractors should be aware that DSHS Technical Assistance cannot resolve single audit findings or DSHS Program or Fiscal review findings. This function represents an “ounce of prevention, not a pound of cure.”
“My board is great but the guy sitting next to me could use some help in this area!”
“Okay, How about Board Governance?”
Members of Board have specific legal responsibilities pursuant to State laws and DSHS contract requirements.
Management & Board legal counsel should:
BOARD RESPONSIBILITIES
Brief Board members of these requirements prior to executing DSHS contracts
Review websites referenced on the following slide
WEBSITES FOR NON-PROFIT BOARD GOVERNANCE - BEST PRACTICES
www.wcnwebsite.org/practices/board.htm
www.navref.org/bestpractices/gov_bod_intro.htm
www.aicpa.org/download/training-bod.pdf
www.directorsforum.org/resources/cg_documents/cgnews_bestpractices.php
www.npgoodpractice.org/Glossary/Default.aspx?index=B
QUESTIONS AND ANSWERS