Program and Fiscal Compliance Issues

Geri Baucom, Fiscal/Contracts Specialist

Johnna Meyer, Policy ManagerCalifornia Department of Aging

Program and Fiscal Compliance

Fiscal Process Overview Direct Services Program Development (PD) or Coordination

(C) Consumer Contributions Matching Requirements Nutrition Services Incentive Program (NSIP)

Fiscal Process OverviewAllocations

Budgets, Budget Revisions, Contracts

Monthly Reporting

Financial Closeout Reports/Closeout Statements

Audit/Audit Resolution

Final Closeout

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

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

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

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

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

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

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

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

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?

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?

Consumer Contributions (OAA Section 315)

Voluntary Contributions Cost Sharing

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

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)

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

Excluded Services Information & Assistance Outreach Case Management Ombudsman Elder Abuse Prevention Legal Assistance Congregate & Home-Delivered Meals

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

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

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)

Expansion of Services

+ =75% 25% 100%

Title III E Federal

(CDA Allocation to AAA)

Title III E

Non Federal (Local Funds)

Minimum Title III E Program

CRCAcme

Caregiver Training

Match Because CRC Funds Spent on III E Clients

$ $

Not Match Because no funds Spent on III E Clients

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

Questions?

Thank you