Template for Federal Program Compliance Supplements 2002

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APRIL 2014
93.531
PPHF 2012: COMMUNITY TRANSFORMATION GRANTS AND
NATIONAL
DISSEMINATION
AND
SUPPORT
FOR
COMMUNITY TRANSFORMATION GRANTS - FINANCED
SOLELY BY 2012 PREVENTINON AND PUBLIC HEALTH
FUNDS
State Project/Program:
ACA-PPHF COMMUNITY TRANSFORMATION GRANT (CTG)
U. S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
CENTERS FOR DISEASE CONTROL AND PREVENTION
Federal Authorization:
301A, 311BC, 317K2(42USC241A, 243BC247BK2)
State Authorization:
N/A
N. C. Department of Health and Human Services
Division of Public Health
Agency Contact Person – Program
N. C. DHHS Confirmation Reports:
Sharon Nelson
Community Transformation Grant
(919) 707-5207
Sharon.Boss.Nelson@dhhs.nc.gov
SFY 2014 audit confirmation reports for payments made to
Counties, Managed Care Organizations (MCOs or, formerly,
Local Management Entities), Boards of Education, Councils
of Government, District Health Departments and DHSR
Grant Subrecipients will be available by early September at
the
following
web
address:
http://www.ncdhhs.gov/control/auditconfirms.htm. At this
site, click on the link entitled “Audit Confirmation Reports
(State Fiscal Year 2013-2014)”.
Additionally, audit
confirmation reports for Nongovernmental entities receiving
financial assistance from the DHHS are found at the same
website
except
select
“Non-Governmental
Audit
Confirmation Reports (State Fiscal Years 2012-2014)”.
Agency Contact Person – Financial
Judith McDermott
Chief Budget Officer
(919) 707-5080
Judith.McDermott@dhhs.nc.gov
The auditor should not consider the Supplement to be “safe harbor” for identifying audit
procedures to apply in a particular engagement, but the auditor should be prepared to justify
departures from the suggested procedures. The auditor can consider the supplement a “safe
harbor” for identification of compliance requirements to be tested if the auditor performs
reasonable procedures to ensure that the requirements in the Supplement are current. The
grantor agency may elect to review audit working papers to determine that audit tests are
adequate.
Auditors may request documentation of monitoring visits by the State Agencies.
I. PROGRAM OBJECTIVES
The purpose of the North Carolina Community Transformation Grant (CTG) Project is to reduce
chronic diseases, promote healthier lifestyles, reduce health disparities, and control health care
spending. Through the CTG Project, NC Division of Public Health (DPH) works with State and
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ACA-PPHF COMMUNITY TRANSFORMATION GRANT (CTG)
local partners to implement strategies across four strategic directions: tobacco-free living, active
living, healthy eating, and increasing access to clinical preventive services.
Funding is allocated to 10 local health departments to lead the efforts of multi-county regions,
called Community Transformation Collaboratives. DPH will provide technical assistance to
Collaboratives in implementing the identified strategies while working to create State policies
that support them. In addition to funding local health departments to lead regional efforts,
Community Transformation funds are allocated to regional Area Health Education Centers
(AHEC) to support staff that will assist primary care practices in making quality improvement
systems changes that enhance the clinical management of patients with high blood pressure and
high cholesterol and who use tobacco. These staff will work with the Community
Transformation Collaboratives in their regions to link the primary care providers with community
resources for chronic disease self-management, weight management and tobacco use cessation.
North Carolina Community Care Networks, the statewide umbrella organization that supports the
14 networks in designing and implementing care improvement initiatives for Medicaid and other
underserved populations, will also play an important role in engaging primary care practices in
the initiative.
DPH was awarded the CTG grant to work with communities to implement policy, systems and
environmental changes that address the required Strategic Directions of tobacco-free living,
active living and healthy eating and high impact evidence-based clinical and other preventive
services (Grant Number 5U58DP003511-02). The total grant award for years 1, 2 and 3 is
$7,466,092 each year. The project period is 9/30/11 – 9/29/16. The CTG program is providing
funding to local health departments totaling $4.2 million annually and funding to contractors for
activities related to evaluation, technical assistance, and quality improvement services.
II. PROGRAM PROCEDURES
Funding to Local Communities:
Per the federal funding opportunity announcement (CDC-RFA-DP11-1103PPHF), at least 50% of
funds were awarded to local areas, including county or city health departments, and local
governmental entities.
DPH will work with CTG communities to implement the strategies in this proposal over the fiveyear funding period. $4.2 million will be awarded to 10 regional collaboratives that consist of 10
counties. Each collaborative will be awarded $420,000 annually. An RFP was released outlining
the following 11 strategies:
Strategic Direction 1: Tobacco Free Living
1. Increase the number of smoke-free government buildings and indoor public places.
2. Increase the number of tobacco-free government grounds, including parks and recreational
areas.
3. Increase the number of smoke-free multi-unit housing, including public, affordable, and
market-rate housing.
4. Increase the number of 100% tobacco-free community colleges campuses and state and
private university/college campuses.
Strategic Direction 2: Active Living and Healthy Eating
5. Increase the number of new or revised comprehensive plans that include health
considerations.
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ACA-PPHF COMMUNITY TRANSFORMATION GRANT (CTG)
6. Increase the number of organizations that allow access to physical activity facilities.
7. Increase the number of small food retail stores offering and promoting healthier food and
beverage options.
8. Increase the number of new or enhanced farmers’ markets, mobile markets, farm stands and
community supported agriculture programs.
Strategic Direction 3: Clinical Preventive Services
9. Increase the number of healthcare providers who implement Quality Improvement (QI)
systems for the clinical practice management of high blood pressure and high cholesterol.
10. Increase the number of healthcare providers that implement QI systems for tobacco use
screening, referral and treatment.
11. Improve systems for referrals of patients with high blood pressure, high cholesterol and
tobacco use to existing community prevention and self-management programs, services and
resources (e.g., self-management programs, Eat Smart Move More Weigh Less, Quitline).
Eligible Communities:
Per the federal funding opportunity announcement (CDC-RFA-DP11-1103PPHF), funds were
awarded to 98 of the 100 NC counties who were ineligible to apply for CTG funds themselves
due to population restrictions. Wake and Mecklenburg counties are not funded because they were
eligible to apply for CTG funds.
Agreements with Contractors:
 The CTG Project provides funds to contractors for activities related to evaluation, technical
assistance, and quality improvement services. An executed contract agreement between the
contractor and the Division of Public Health is the mechanism for the transfer of funds. Each
contract has specific funding amounts and an approved budget with anticipated expenditures
by category and amount.

Requirements for contractors are detailed in the contract Scope of Work, which lists
performance expectations that each contractor must achieve in exchange for the funding.

Each contract agency must provide the auditor with a copy of the contract agreement and
expenditure reports. If the contractor cannot provide these documents, they are available
from the Division of Public Health, Budget Office or the CTG Project office listed above.
General Agreement Guidance:
The Consolidated Agreement provides general guidelines regarding approved policies and
procedures related to the implementation of public health programs and describe requirements of
the funding relationship between the State and local public health agencies. These requirements
are detailed under the following heading: Work to Be Performed; Funding Stipulations; Fiscal
Control; Responsibilities of the State; and, Compliance. Budgetary Guidance is sent annually
from each of the Divisions to all local health departments. The Budgetary Guidance document
specifies the amount of funds allocated and their respective sources.
Program Guidance:
The CTG Addendum (#885) to the Consolidated Agreement provides guidance to local health
departments regarding specific requirements for local programs receiving funding from ACAPPHF. Health departments also receive detailed guidance from the CTG Project staff related to
developing their annual budget, MOU’s, and Implementation Plans.
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ACA-PPHF COMMUNITY TRANSFORMATION GRANT (CTG)
Monitoring:
Monitoring is ongoing through weekly phone calls, emails, and site visits by CTG State staff who
provide technical assistance. Progress is reviewed by CTG Project staff during weekly staff
meetings. The Office of Local Health Services is responsible for assessing fiscal risk status for
local health departments.
III. COMPLIANCE REQUIREMENTS
In developing the audit procedures to test compliance with the requirements for a federal funded
program, the auditor should look first at OMB Circular A-133, Part 2, Matrix of Compliance
Requirements, to identify which of the 14 types of compliance requirements described in Part 3
are applicable and then look to Part 3 for the details of the requirements.
A. ACTIVITIES ALLOWED OR UNALLOWED
Funds may be expended for reasonable program purposes, including:

Staff salaries, wages, and fringe benefits

Travel

Supplies

Media campaign

Technical assistance

Evaluation

Purchase of contractual services

General operating expenses including rent, phone services, postage, etc.
Funds may not be used for the following types of expenditures:

Research

Clinical care

Pre-award costs

Construction

Equipment

Lobbying, pursuant to 31 U.S.C Section 1352; 18 U.S.C. Section 1913.
Suggested Audit Procedure
Identify the types of activities that are either specifically allowed or prohibited. Select a
sample of transactions and verify that the transaction was for an allowable activity.
ACA—PPHF Community Transformation Grant Requirements: As a recipient of
ACA—PPHF Community Transformation Grant funds, local health departments and districts
have agreed to:

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Support a minimum of two full-time (2.0 FTE) Regional CTG Coordinators to serve the
entire collaborative area. One of the Coordinators must be based in the lead agency. If
the lead agency is not in a rural county, then the other Coordinator must focus primarily
on work in rural counties.
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
Identify staff to serve as Intervention Leads for Tobacco Free Living, Active Living,
Healthy Eating and Communications. These positions are dedicated to leading strategy
specific work for the Community Transformation Collaborative. This work should build
upon, but not duplicate, other grant funded efforts.

Establish and convene a Community Transformation Collaborative at least quarterly.

Include Quality Improvement Coaches based in the AHEC Regional Offices in strategic
planning efforts.

Submit a one-year Community Transformation Implementation Plan (CTIP) outlining all
activities planned for FFY 2013-2014 and budget are submitted to the CTG Project
Consultant. The plan will be reviewed and must be approved by the CTG Project
Consultant before implementation.

Ensure that activities described in the CTIP address policy, systems and environmental
changes supporting tobacco free living, active living, and healthy eating and link clinical
preventive services related to high blood pressure and high cholesterol to community
supports.

Ensure that interventions are designed to promote health equity and reduce health
disparities among targeted populations.

Include CTG Project staff in intervention planning, implementation, and evaluation.

Conduct at least one peer-to-peer learning event annually to address CTG strategies
among counties in the region.

Support CTG staff and Community Transformation Collaborative members in
participating in DPH coordinated training opportunities, including webinars, and
conference calls.
Suggested Audit Procedure
Each health department can provide the auditor with a copy of the Consolidated Agreement
for the particular year being audited, as well as, copies of the Budgetary Guidance, the
ACA—PPHF CTG Agreement Addendum, expenditure reports, and Implementation Plan. If
the health department cannot provide these documents, they are available from the CTG
program in the Division of Public Health.
B. ALLOWABLE COSTS/COST PRINCIPLES
All grantees that expend State funds (including federal funds passed through the N. C.
Department of Health and Human Services) are required to comply with the cost principles
described in the N. C. Administrative Code at 09 NCAC 03M .0201. OMB Circular A-87
applies to this program.
Suggested Audit Procedure
Review selected expenditures for consistency with applicable cost principles.
C. CASH MANAGEMENT
Funds are granted on a reimbursement basis.
D. DAVIS-BACON ACT
N/A
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E. ELIGIBILITY
Applicant agencies should state the objectives of the project, outline the method of operation,
describe the evaluation procedures, and provide a budget with justification of funds.
Suggested Audit Procedure
Review the executed Contract to determine if eligibility criteria were met.
F. EQUIPMENT AND REAL PROPERTY MANAGEMENT
Purchase of equipment is not allowable unless identified in the budget and approved by CDC.
Suggested Audit Procedure
Review approved budget and any expenditure for equipment purchases.
G. MATCHING, LEVEL OF EFFORT, EARMARKING
N/A
H. PERIOD OF AVAILABILITY OF FEDERAL FUNDS
The project period is September 30, 2011 through September 29, 2016. Funds are awarded
annually from CDC. Grant funds for local health departments will be allocated through the
NC Division of Public Health Consolidated Agreement over State Fiscal Years 2011-12,
2012-13, 2013-14, 2014-15, and 2015-16.
Suggested Audit Procedure
Each local health department can provide the auditor with a copy of the Consolidated
Agreement for the particular year being audited. The Community Transformation Grant
Project manager can provide the Notice of Award from CDC.
I. PROCUREMENT AND SUSPENSION AND DEBARMENT
All grantees that expend federal funds (received either directly from a federal agency or
passed through the N. C. Department of Health and Human Services) are required to conform
to federal agency codifications of the grants management common rule accessible on the
Internet at http://www.whitehouse.gov/omb/grants/chart.html.
Suggested Audit Procedure
Select a sample of funded procurement, if any, for activities subject to federal agency
codifications of the grants management common rule.
J. PROGRAM INCOME
N/A
K. REAL PROPERTY ACQUISITION AND RELOCATION ASSISTANCE
N/A
L. REPORTING
Statutory Authority: 15A NCAC 16A.0506: Local health departments must prepare activity
reports as referenced in the Agreement Addendum.
Statutory Authority: 15 A NCAC 16A.0506: Local health departments are required to submit
Expenditure Report, DHHS 2949 (Rev. 3/98) on a schedule set out in the consolidated
Agreement between the parties.
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ACA-PPHF COMMUNITY TRANSFORMATION GRANT (CTG)
Suggested Audit Procedure
Review the files for evidence of annual implementation plan.
M. SUBRECIPIENT MONITORING
On a monthly basis, the CDC CTG program assesses programmatic risk through a monthly
program review call. Progress if measured against an Implementation Plan developed by
each county collaborative. The Office of Local Health Services is responsible for assessing
fiscal risk status for local health departments. The CTG program will also monitor
expenditures by budget category on a monthly basis through an expenditure report form
completed by the State fiscal lead.
Suggested Audit Procedure
Review files for evidence of monthly progress and expenditure reports.
N. SPECIAL TESTS AND PROVISIONS
Consolidated Agreement System
The DHHS Division of Public Health is made up of six major sections: (1) Administrative,
(2) Local and Community Support, (3) Chronic Disease and Injury Prevention, (4)
Epidemiology, (5) Oral Health, Women’s and Children’s Health, and (6) Legal and
Regulatory Affairs. The Division utilizes a single written agreement to manage all funds, that
is, State, federal or private grant funds, that the Division allocates to local health departments
across the State. This document, as amended, is called the Consolidated Agreement.
The Agreement sets forth the more general requirements of the funding relationship between
the state and local public health agencies. The respective requirements are detailed under the
headings: Responsibilities of the Department (Local Public Health Unit); Funding
Stipulations; Fiscal Control; Responsibilities of the State; and Compliance. More specific
information related to program activity is set out in a document called the Agreement
Addenda which detail outcome objectives (which may or may not be negotiable at the
beginning of each fiscal year) that each health department must achieve in exchange for the
funding. A third part of the system is the Budgetary Authorization which is sent annually
from each of the Sections or Branches of the Division to all health departments being
allocated funds from specific sources, i.e., State appropriations or other federal grant funds
for specific activities. This Estimate indicates the amount of the allocated funds and their
respective sources. Each health department should be able to provide an auditor with a copy
of the Consolidated Agreement for the particular year being audited, as well as copies of the
Budgetary Authorization and any revisions, Agreement Addenda, expenditure reports and
any activity reports for each source of money received. If the health department cannot
provide these documents, they may contact the State Division of Public Health Budget Office
for assistance.
CONFLICT OF INTEREST AND CERTIFICATION REGARDING NO OVERDUE
TAX DEBTS
Compliance Requirement
All non-State entities (except those entities subject to the audit and other reporting
requirements of the Local Government Commission) that receive, use or expend State funds
(including federal funds passed through the N. C. Department of Health and Human Services)
are subject to the financial reporting requirements of G. S. 143C-6-23 for fiscal years
beginning on or after July 1, 2007. These requirements include the submission of a Notarized
Conflict of Interest Policy (see G. S. 143C-6-23(b)) and a written statement (if applicable)
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that the entity does not have any overdue tax debts as defined by G. S. 105-243.1 at the
federal, State or local level (see G. S. 143C-6-23(c)). All non-State entities that provide State
funding to a non-State entity (except any non-State entity subject to the audit and other
reporting requirements of the Local Government Commission) must hold the subgrantee
accountable for the legal and appropriate expenditure of those State grant funds.
Suggested Audit Procedures
The auditor should review Section B. FUNDING STIPULATIONS of the Consolidated
Agreement before beginning an audit. The fourteen items of this Section describe much of
the detailed information the auditor may be seeking during a review of these programs.
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