Overview

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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
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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
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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
[email protected]
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