National Monitoring Standards 2013 CDR Matthew Newland Public Health Analyst Department of Health and Human Services Health Resources and Services Administration HIV/AIDS Bureau Division of Metropolitan HIV/AIDS Programs Session Overview • • • • • Purpose of National Monitoring Standards HRSA/HAB Expectations Monitoring Standards Implementation Updates to Standards Resources Purpose of National Monitoring Standards (NMS) • Provide a compilation of all major Ryan White Program documents used for COMPLIANCE, OVERSIGHT, and EXPECTATIONS • Assist grantees in meeting Federal requirements for program and fiscal management, monitoring, and reporting • Help standardize project officer monitoring of grantees • Clarify the oversight expectation of Ryan White Part A Program • Assist/guide grantees in compliance to monitoring expectation • Identify specific roles regarding monitoring of sub-grantees Purpose of NMS Compliance, Oversight, and Expectations • Ryan White Legislation • Code of Federal Regulations • HHS Grants Policy Manual • HRSA/HAB Policies • Part A Funding Opportunity Announcement • Part A Manual (clarification, best practice) • Program Terms and Conditions of Award • OIG/GAO Reports and Recommendations National Monitoring Standards • NMS Developed in response to OIG, Congress, and GAO oversight issues Published April 2011 Revised May 2013 • Three Components to the NMS Universal Monitoring Standards (18 pages) Fiscal Monitoring Standards (43 pages) Program Monitoring Standards (78 pages) • Monitoring Standards: FAQs (19 pages) Why Do We Need National Monitoring Standards? Contract Monitoring Fiscal Monitoring – a system to assess the appropriate use of funds including the control, disbursement, use, and reporting of allowable costs Program Monitoring – a system to assess whether allowable services are provided to eligible clients according to service limits Quality Management – a system to assess the degree to which a service meets or exceeds established professional standards and user expectations HRSA/HAB Expectations • Any agency or individual receiving Federal funding is required to be monitored for compliance with federal and programmatic requirements • Grantees must perform fiscal monitoring activities to ensure Ryan White funding is being used for approved purposes • Grantees are required to conduct “comprehensive” annual monitoring site visits to all sub-grantees, unless an exemption has been granted by HAB/DMHAP NMS-OIG Recommendations • Specify and enforce standards and guidelines for how grantees should monitor grantees • Standardize a corrective action process and address grantee issues more formally • Increase the frequency and comprehensiveness of site visits NMS Implementation Grantee Responsibilities: • Conduct annual visit • Develop its own Monitoring Standards • Ensure compliance with all the National Monitoring Standards • Make National Monitoring Standards available to subgrantees and document monitoring activities • Keep POs informed about its monitoring activities Monitoring Standard Elements Each Monitoring Standard has four elements: • Performance Measure/Method • Grantee Responsibility • Provider/Sub-grantee Responsibility • Source Citation Example of a Part A Fiscal Monitoring Standard Performance Measure/ Method Standard Grantee Responsibility Provider/Subgrantee Responsibility Source Citation Section A: Limitation on Uses of Part A funding 1. Adherence to 10 percent limit on proportion of federal funds spent on administrative costs in any given grant year For grantees without a fiduciary intermediary or administrative agent Identification and description of all expenses within grantee budget that are categorized as administrative costs Documentation that administrative expenses do not exceed 10 percent of the awarded Ryan White grant Identify and appropriately categorize administrative expenses and ensure that they do not exceed 10 percent of total grant Provide HRSA/HAB with current operating budgets with sufficient detail to determine and review administrative expenses PHS ACT 2612 A 2604(h)(1) N/A Universal Monitoring Standards • Section A: Access to Care • Section B: Eligibility Determination • Section C: Anti-Kickback Statute • Section D: Grantee Accountability • Section E: Reporting • Section F: Monitoring • Appendix 1 – Report Due Dates Universal Standards - Updates Item Location Change Type Source/Purpose Section B: 1. Eligibility Determination Clarification PCN #13-02 Client Eligibility and Recertification Requirements Section D: 1. Grantee Accountability New Citations Steven Young and Heather Hauck Letter 09/20/2012 “Exemption to Annual Site Visits” Section E: 2. Reporting Language added under Grantee Responsibility; New Citations FFATA Reporting Section F: 2. Monitoring Standard updated; New Citation “Note” added on Annual Site Visit Exemption; SY and HH Letter 09/20/12 Appendix 1 Report Due Dates Updated Added “Estimated UOB and Carryover” due date Part A Fiscal Monitoring Standards • • • • • • • • • • • • Section A: Limitation on Uses of Part A Funding Section B: Unallowable Costs Section C: Income from Fees for Services Performed Section D: Imposition and Assessment of Client Charges Section E: Financial Management Section F: Property Standards Section G: Cost Principles Section H: Auditing Requirements Section I: Matching of Cost-Sharing Funds Section J: Maintenance of Effort Section K: Fiscal Procedures Section L: Unobligated Balances Part A “Fiscal” Monitoring Standards - Updates Item Location Change Type Section A: 4, Limitation on Clarification (6, 5, 6, 8 Uses of Part A 8); New Funding Citations (4, 5, 6, 8) Section B: 7, Unallowable 9 Costs Source/Purpose Item 6. “Note” added under Standard - website for obtaining Indirect Cost Rate; Citations: H. Philips & S. Young Letter “Administrative Costs & Rent”; FOA – “Indirect Cost Rate”; HAB PN 08-02 – “Waiver of Core Medical Services Requirements” Language added Performance Measure/ Method Item 7 new bullet on document review for outreach; Item 9 new bullet on document review for foreign travel Part A “Fiscal” Monitoring Standards - Updates Item Location Change Type Source/Purpose Section D: Imposition & Assessment of Client Charges Terminology Updated Schedule of Charges (previously sliding fee scale) Section E: 3, 4, 5, 6 Financial Management Language added; reformat Revisions to approved budgets Section H: 2 Auditing Requirements New Standard Small Program Audits; S. Young & H. Hauck Letter 09/20/12 Section K: 10 Fiscal Procedures Language added Estimation of carryover request to Grantee Responsibility Section L: 1 Unobligated Balances Language update; new Citation Submission of UOB; HAB PN 12-02 “UOB and Carryover Provisions” Part A Program Monitoring Standards Section A: Allowable Uses of Part A Service Funds Section B: Core Medical Services Section C: Support Services Section D: Quality Management Section E: Administration Section F: Other Service Requirements Section G: Prohibitions and Additional Requirements Section H: Chief Elected Official (CEO) Agreements and Assurances Section I: Minority AIDS Initiative Part A “Program” Monitoring Standards Updates Item Section B: 3 Location Core Medical Services Change Type Source/Purpose Language updated LPAP eligibility, advisory board, 340B compliance Section C: 7, Support Services 10 Language updated and clarified Housing services; Medical transportation – clarified need for prior approval when purchasing or leasing vehicle Section F: 2 Language updated “Referral relationships with key points of entry” Language updated and added Direct Cash Payments; two items added to Additional Prohibitions Other Service Requirements Section G: 5, Prohibitions on 9 Promotion Part A “Program” Monitoring Standards Updates Item Location Change Type Source/Purpose Section H: 3a, 3f, 5a CEO Agreement & Assurances Language updated - 3a & 3f; Language deleted with referral to Fiscal Monitoring Standards – 5a 3a-Obligation and expenditure of funds; 3f-Medicaid status; 5aImposition of charges for services Section J: 1c Data Reporting Requirements Language added Grantees ensure providers are entering clientlevel data Monitoring Standards: FAQs • FAQs are divided into seven sections: National Monitoring Standards (NMS) Basics Structure of the NMS Documents Implementation of the NMS Universal Monitoring Standards Questions Program Monitoring Standards Questions Fiscal Monitoring Standards Questions Appendix 1 FAQ - Updates FAQ # Section Change Type Source/Purpose #9 Structure of NMS Deleted #9 from FY12 no longer relevant #23 Implementation of NMS Updated (replaces #24 & #25) Annual site visit exemption #24 Implementation of NMS Updated (Previously Desk audits may substitute #26) for site visit with approved exemption #34 Universal MS New PCN #13-02 Client Eligibility & Recertification Requirements #42 Universal MS New Underinsured qualify for RW services FAQ - Updates FAQ # Section Change Type Source/Purpose #43 Universal MS Updated Clarifies eligibility for insurance and RW #53 Fiscal MS Clarification Clarifies use of RW funds for QM #54 Fiscal MS Clarification Indirect cost rates #55 Fiscal MS Clarification Indirect cost rate documentation requirements for grantee/subgrantees #56 Fiscal MS Updated Includes “exceptions” for rent as allowable direct service cost #57 Fiscal MS Updated Includes language on auditing of high-risk programs FAQ - Updates FAQ # Section Change Type Source/Purpose #58 Fiscal MS New Small program audits; S. Young & H. Hauck Letter 09/20/12 #61 Fiscal MS Clarification Schedule of charges and limit on client charges #66 Fiscal MS New Schedule of charges discounts based on individual income #68 Fiscal MS Clarification Reimbursement is a form of program income #70 Fiscal MS Clarification Establishing MOE #71 Fiscal MS Updated Contains new web link for sample monitoring tools Appendix 1 Updated Website links updated Resources Part A and B Monitoring Tool: https://careacttarget.org/category/topics/programmonitoring (click the “Grantee” tab at the top of the page) Contact Information CDR Matthew Newland Public Health Analyst (301) 443-0296 mnewland@hrsa.gov