FISCAL MONITORING
HIVCS CAG
9/22/10
REASONS FOR FISCAL MONITORING
• Ensure organizations adhere to Federal Office of
Management and Budget (OMB) guidelines around:
– Allowable cost
– Time and effort reporting
– Appropriate allocation methodology for shared costs
• Ensure organizations have established internal controls in
place to appropriately manage federal funds
TYPES OF CONTRACT REIMBURSEMENT
• Cost Based: reimbursement for actual expenditures incurred by
programs
• Performance-Based (Fee-for-Service): reimbursement for the number of
services provided at the agreed upon reimbursement rate
• Performance-Based (Deliverables): reimbursement for
achieving/completing agreed upon program milestones.
METHODS OF FISCAL MONITORING
• Cost-Based Contracts:
– Support Documentation Review
– Fiscal Site Visits
• Performance-Based Contracts:
– Mid-year Expense Report
– Fiscal Questionnaire
• Both Cost and Performance-Based Contracts:
– Review of Organization’s annual audit reports
FISCAL MONITORING FOR COST-BASED
CONTRACTS
• Support Documentation Review:
– Annually, HIVCS reviews supporting documentation for all
cost-based subcontractor claims for one (1) month of a
given contract year.
– Documentation must consist of payroll records, payroll tax
documentation, vendor invoices, and general ledger and
cancelled checks which must reflect an allocation
methodology for shared costs.
– Payments will be withheld and/or disallowances applied as
a result of incomplete or missing backup documentation.
FISCAL MONITORING FOR COSTBASED CONTRACTS
•
Fiscal Site Visit:
–
Every three years, HIVCS conducts a site visit
to review documentation for reported
expenditures. Review is conducted on-site at
the agency.
–
Fiscal site visits consist of a review of two
months of expenses (one month to satisfy the
fiscal site visit requirement and one month to
satisfy the one monthly “support
documentation” review requirement).
FISCAL MONITORING FOR COST-BASED
CONTRACTS
• Fiscal Site Visit Continued..
– Contractors are instructed to obtain original back-up
documentation for all reported expenditures,
including personnel services file for budgeted staff.
– HIVCS staff reviews personnel files, payroll records,
payroll tax documentation, vendor invoices, and
general ledger and cancelled checks which must
reflect an allocation methodology for shared costs.
HIVCS FEEDBACK AND TA
• Subcontractors who have substantial documentation
deficiencies will be required to submit additional or monthly
backup documentation to support monthly expenditure
reports until HIVCS is confident the deficiencies have been
addressed.
• Subcontractors are allowed to modify budgets to maximize
contract MRA in the event of disallowances.
• Subcontractors allowed to reconcile and revise reported
expenses as necessary (i.e. removing disallowed costs)
• HIVCS provides TA for completing modifications
FISCAL MONITORING FOR PERFORMANCEBASED CONTRACTS
• Mid-Year Expense Report:
– A report that summarizes costs incurred for running the program for the
first six months
– Annual
– The report will show cost by service family by budget categories (e.g.,
Personnel Services, Travel), not individual line item.
– a general ledger (G/L) must accompany the report.
Report and G/L will be reviewed to ensure compliance with regulations
regarding unallowable costs and NOT to verify adherence to contract
budget or correspondence to YTD revenue.
FISCAL MONITORING FOR PERFORMANCEBASED CONTRACTS
Fiscal Questionnaire:
– Agency self-assessment of fiscal and administrative
controls, asset management and MIS protocols
– Administered per contractor
– Agency completes the full questionnaire every two years
– Contractors given ample time to complete and submit the
questionnaire to HIVCS
HIVCS FEEDBACK AND TA
Mid-year Report:
• HIVCS Fiscal Analyst reviews the general ledger for any “red
flag” items (i.e. unallowable costs)
• If unallowable expenses are found in the G/L contractors
instructed to transfer these expenses to another funding
source
Fiscal Questionnaire:
• HIVCS Fiscal Analyst reviews completed questionnaires and
discuss any issues of concern with contractor, including
referrals for technical assistance.
FISCAL MONITORING – ANNUAL AUDIT
REVIEW – BOTH COST AND PERFORMEDBASED CONTRACTS
Public Health Solutions/HIVCS requires that all contractors submit
annual audit packages. The audit package consists of the following
documents:
• Agency-wide Financial Statements
• A-133 audit report (if applicable)
• Management Letter
If an organization is not required to prepare an A-133 audit report, the
following documents must be submitted:
– Exemption Letter (signed by ED, CFO, or Auditor)
– Schedule of Expenditures of Federal Awards
• The audit package is submitted to Public Health Solutions/HIV Care
Services within thirty (30) days after its completion, but no later than
(9) months after the end of the audit period.
HIVCS FEEDBACK AND TA
• Contractors are sent multiple communications/reminders to submit the
audit package.
• An agency is considered out of compliance with our audit requirements if
it fails to submit the audit package by the required due date.
• Non-compliance for failing to submit the audit package will result in
disciplinary action, which includes HIVCS holding payments, and a
Corrective Action/Compliance Plan request.
• Monthly reimbursements remain on hold until the requested information is
received by HIVCS.
QUESTIONS / COMMENTS
Questions