Transcript Document

Establishing Internal Control Policies
Over ARRA Reporting
Mississippi Primary Health Care Association
February 17, 2010 – Holmes Community College
Michael Holton, Manager
RSM McGladrey
[email protected]
RSM McGladrey Inc. is a member firm of RSM International – an affiliation of separate and independent legal entities.
Goals of the Session
• Understand background of ARRA and the funding involved
• Identify specific reporting/compliance requirements
• Discuss the framework for developing an internal control
policy over ARRA reporting
• Appendices
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What are the Different Health Center ARRA Programs?
• ARRA grants, issued by HRSA/BPHC, specifically for Community
Health Centers total $2 billion
– Provides $500 million in grants to:
• 126 New Access Point (NAP) grants awarded in February/March 2009 –
support new sites and service areas
• Increased Demand for Services (IDS) – increase services at existing sites
and provide payments for spikes in uninsured populations
– Provides $1.5 billion for repair, renovation, construction of health
centers including purchase of Health Information Technology (HIT)
• Capital Improvement Program (CIP)
• Facility Investment Program (FIP)
– ARRA grants are two-year, one-time awards
• Community Health Centers may be entitled to other ARRA grant
funding from other Federal agencies or as sub-recipients from State
governments
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ARRA Grant Reporting Requirements
• Government-wide Reporting
– Office of Management and Budget (OMB) Federal Reporting under
ARRA (FederalReporting.Gov)
– Required reporting by ALL prime recipients of ARRA funding
– Prime recipients may delegate reporting to sub-recipients
• Program-Specific Reporting
– HRSA Health Center Quarterly Report (HCQR)
– Other Federal Agencies
– Sub-recipients of ARRA funding from State governments or other
prime recipients
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ARRA Reporting Under HCQR for HRSA Grants
• ARRA health center specific reporting requirements are contained
in the Health Care Quarterly Report Reporting Manual (HCQR,
http://bphc.hrsa.gov/recovery/HCQRManual.pdf) and the HRSA
Electronic Handbook
– Also see PAL 2009-08
• Separate reporting from that required under FederalReporting.Gov
• The HCQR Reporting Manual was last updated on December 30,
2009
– Includes changes in counting FTEs and adds FIP reporting requirements!
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Overview of Quarterly Report (SF-PPR)
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The EHB will combine the information from the different grant-specific reports into an
integrated data presentation. Employees, patients, and visits are to be reported on only ONE
of the ARRA health center grants received so that adding the separate reports together will
give an accurate picture of the grantee’s total ARRA supported activities.
•
All grant-specific reports require the completion of Pages 1 and 2.
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Page 1 – Cover Page
– Performance Narrative
– Total Cumulative New Patients (Unduplicated) – line 10.a.
– Total Cumulative New Uninsured Patients – line 10.b.
– Optional attachments
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Page 2 – Staffing and Utilization
– Staff FTEs – “Quarterly” New and Retained Staff
– Cumulative Visits and Patients
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ARRA Reporting – CIP/FIP Grant Specific Reporting
Form SF-PPR Page 3 – CIP/FIP Project Report (each project)
• Many health centers received CIP/FIP funding to support more than one
CIP/FIP project. There will be one SF-PPR Page 3 for “each” CIP/FIP
project, with project specific data to be reported.
• For “each” CIP/FIP project, the following data elements will be reported:
– Award amount
– Project Status – must be selected from 4 categories based on the timeline and
critical milestones described in the CIP/FIP project application
• Not Started; Less than 50%; Greater than 50%; or Completed
– Progress Specific Narrative
– Attachments as needed or instructed by HRSA (not required)
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ARRA Reporting – CIP/FIP Grant Specific Reporting
Page 4-CIP/FIP Project Closeout Report (each project)
• The SF-PPR Page 4 form will be included only when an ARRA
supported CIP/FIP project has been marked as “Completed”.
• There will be one SP-PPR Page 4 form for each project, which will
report:
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Square footage increased or improved
EHR Clinicians, other staff, & number of patients with an EHR
Amount of CIP funds expended
Amount of non-CIP funds expended
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HRSA Report Review Process
• BPHC will review the HCQR within 11 – 20 days following the end
of the reporting period
• BPHC will initially contact the HCQR “Point of Contact” person
with questions and/or comments
• BPHC will work with the health centers to resolve any errors or
discrepancies in the HCQR within 29 days of the end of the
reporting period
– Any changes to reports will be made through the EHB
• 30 days after the end of the reporting period, the HCQR will be final
• If you find that there is an uncorrected mistake once an HCQR is
final, the next HCQR can reflect a correction of the mistake as the
data reported is cumulative
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Overview of OMB Reporting
• OMB Memorandum M-09-21, Implementing Guidance for the Reports on
Use of Funds Pursuant to the American Recovery and Reinvestment Act of
2009*, addresses:
– Answers questions and clarifies issues related to the mechanics and chronology
of recipient reporting required by the Recovery Act;
– Provides clarification on what information will be required to be reported into
the central reporting solution at www.FederalReporting.gov and what
information will be reported on www.Recovery.gov;
– Instructs recipients on steps that must be taken to meet these reporting
requirements, including the incorporation of sub-recipient reporting
requirements under Section 1512(c)(4) of the Act; and
– Establishes a common framework for Federal agencies and recipients to
manage a data quality process associated with the Recovery Act recipient
reporting requirements.
* Memo M-09-21 can be found at http://www.whitehouse.gov/omb/assets/memoranda fy2009/m-09-21.pdf
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Who Must Register and Report at FederalReporting.Gov?
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Prime Recipients are non-Federal entities that receive Recovery Act funding as
Federal awards. Awards may be in the form of contracts, grants, or loans.
– The Prime Recipient is ultimately responsible for reporting.
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Sub Recipients are non-Federal entities that are awarded Recovery funding through
a legal instrument from a Prime Recipient. A Sub Recipient typically is delegated
grant or contract responsibility from the Prime Recipient for all or a portion of a
project or program.
– The Prime Recipient can delegate reporting responsibility to the Sub
Recipient, for the Sub Recipient’s portion of the project/program.
•
Vendors are defined as a dealer, distributor, merchant or other seller providing
goods or services that are required for the conduct of a Federal program. Prime
Recipients or Sub Recipients may purchase goods or services needed to carry out
the project or program from vendors.
– Vendors do not need to register or report data.
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What Reporting is Required?
• Total amount of funds received; and of that, the amount spent on
projects and activities
• A list of projects and activities funded by name to include:
– Description
– Completion status
– Estimates of jobs expected to be created or retained –
• Two (2) separate fields, a numeric field and a separate narrative with an
expanded description of the job creation and reporting methodology
• Prime recipients are required to generate estimates of job impact by
directly collecting specific data from sub-recipients and vendors on the
total FTE resulting from the sub-award
• FTE calculations similar to those used to report on the HCQR
• Details on sub-awards and other payments
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Major Recipient Reporting Activities
• Register on-line at www.FederalReporting.gov
– Before October 1, 2009
• Submit reports on-line at www.FederalReporting.gov
– 1-10 days after close of calendar quarter
• Review reports
– Prime Recipient Review – 11-21 days after close of calendar quarter
– Federal Agency Review – 22-29 days after close of calendar quarter
• Release of reports on www.Recovery.gov
– Final Reports available after Day 30
– Reports indicate Federal Agency review status:
• Not Reviewed
• Reviewed – No Comments
• Reviewed – Comments Provided (material omissions or significant reports
errors identified)
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Prime Recipient Responsibilities
• “Owns” recipient and sub-recipient data
• Initiates appropriate data collection and reporting procedures to
ensure that Section 1512 reporting requirements are met in a timely
and effective manner
• Implements internal control measures as appropriate to ensure
accurate and complete information
• Performs data quality reviews for material omissions and/or
significant reporting errors, making appropriate and timely
corrections to prime recipient data and working with the designated
sub-recipient to address any data quality issues
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Data Quality Requirements
• Scope of Data Quality Reviews:
– Accuracy, Completeness and Timely Reporting
– Avoidance of two key data issues
• Material Omissions – “Instances where required data is not
reported or reported information is not otherwise responsive to the
data requests resulting in significant risk that the public is not fully
informed as to the status of a Recovery Act project or activity”
• Significant Reporting Errors – “Instances where required data is
not reported accurately and such erroneous reporting results in
significant risk that the public will be misled or confused by the
recipient report in question”
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Data Quality Requirements
• Ensure that the following data fields are complete on your reports:
– Material Omissions –
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Awarding Agency Code
Funding Agency Code
Award Type – Grant
Award Number
CFDA Number
DUNS Number
– Significant Errors –
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Award Amount
Number of Jobs
Federal Award Number
Recipient Name
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OIG ARRA Capability Audits – Sample Data Request
• Policies and procedures, including –
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Procurement (including conflict of interest)
Property
Personnel (including time and attendance)
American Recovery and Reinvestment Act Reporting
• Financial, including – Copy of equipment inventory log and reconciliation of physical
inventory results to equipment records
• Personnel, including
– Policy regarding allocation of labor to projects
– Example of time and attendance record
– Example of monthly percentage effort record
• Other, including organizational records, consultants/subcontracts,
and independent auditor reports for last 3 years
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Impact of ARRA Activities on Your Financial Management
System
• Separate Financial Status Reports (FSRs), ARRA reports and accounting
for Federal disbursement of funds on the PSC-272
• Separate sub-accounts in the general ledger system to monitor revenue and
expenses by each ARRA grant
• Revisions to the practice management system to report patient revenue and
statistical reporting of new and new, uninsured patients and visits related to ARRA
activities
• Revisions to payroll systems and time-and-effort reporting to reflect ARRA
activities
• Separate fixed asset accounts for CIP and FIP capital project costs
• Review and compliance with Federal grant requirements, such as property
management and procurement standards
• Establishment of internal controls over ARRA reporting data quality
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Developing Internal Control Policies over ARRA Reporting
• Establish written procedures relative to responsibilities for data
gathering/report preparation, Federal grant compliance and review
including the creation of checklists
• Establish appropriate record retention and maintenance of supporting
data and files relative to ARRA reporting
• Implement a review procedure and standard analytical review
procedures to review the accuracy of the report prior to and
subsequent to the filing of the reports
– Compare filings under FederalReporting.Gov with other Federal agency
reports for consistencies
• Establishing procedures and cross-validation of data to identify and/or
eliminate potential “double-counting” due to reporting anomalies
and/or delegation of reporting responsibility to a sub-recipient
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Developing Internal Control Policies over ARRA Reporting
Data gathering/report preparation:
• Create an ARRA Funding Inventory Log, updated quarterly, identifying all
grant funding received by the health center, those that are either directly or
indirectly funded through ARRA, and the respective reporting requirements
• Require individuals involved with the ARRA reporting process to participate
in all appropriate ARRA reporting webcasts or conferences
• Develop a report preparation checklist for individuals to sign and date
throughout the various stages of the ARRA report preparation, review and
submission process
• Clearly articulate in the checklists:
– Items that have been reported cumulatively versus quarterly
– Procedure to verify that FTEs, patients and visits are only reported on ONE
ARRA report and that double-counting is avoided
• Segregate report preparation function from the Federal grant compliance and
review functions
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Developing Internal Control Policies over ARRA Reporting
Federal grant compliance:
• For each type of ARRA funding identified in the ARRA Funding Inventory
Log, develop a checklist of each of the compliance requirements applicable
to each grant award. Consider:
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Compliance requirements outlined in the Notice of Grant Award
Compliance requirements outlined in the original applications guidance
BPIN 98-23: Health Center Program Expectations
45 CFR Part 74 (Administrative requirements for all DHHS grant awards)
• Procurement standards
• Real property standards
• Equipment standards
– OM B Circular A-122 (Federal cost principles)
• Time and effort reporting for salaries charged to a Federal grant
• Procedures should be implemented to complete the Federal compliance
checklist for each ARRA grant award on a quarterly basis
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Developing Internal Control Policies over ARRA Reporting
Review procedures:
• For each ARRA report filed, develop a review checklist including items to
be reviewed with references to underlying compliance requirements
• Consider pre-submission and post-submission reviews aligned with the
HRSA/OMB review processes
• Reviews should ensure that all other checklists (e.g. report preparation,
Federal grant compliance) have been completed and signed-off
• Reviews should cover:
– Compare filings under FederalReporting.Gov with other Federal agency reports
(e.g. HCQR) for inconsistencies
– Special focus on items considered “material omissions” and “significant
reporting errors”
– Special focus on cumulative/quarterly reporting AND no “double-counting”
– Comparison agency/award identification information to actual Notice of Grant
Awards and User Manuals
– Analytical review of fluctuations versus prior filings
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Developing Internal Control Policies over ARRA Reporting
Review procedures (cont’d):
• Analytical review of reports as compared to prior filings should include –
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Comparison of agency/award identification information
Comparison of fluctuations in FTEs, patients and visits
Comparison of amounts expended
If unusual fluctuations or changes have been identified, have they been clearly
articulated in the narrative sections of the report?
• A comparison of amounts expended versus the total Federal award amount
should be compared with the elapsed time of the grant period and/or the actual
“percentage of completion” for CIP/FIP projects as indicated in the ARRA
report
• Project narratives and spending should be compared to the original grant
application to ensure that dollars are being spent consistent with the application
– Any deviations from the original grant application should be appropriately
supported by Federal approval
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Developing Internal Control Policies over ARRA Reporting
File maintenance/record retention:
• A “grant file” for each ARRA grant award should be established containing,
at a minimum –
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Original proposal
Original grant application guidance
Notice of Grant Award
Approvals from Federal agencies of subsequent revisions/modifications
Contractual agreements
• All quarterly ARRA reports should “each” have a standard file with a table
of contents and containing a printout of the final report, documentation of
timely submissions, and supporting documentation and completed checklists
– Maintain copies of all documents utilized to support the health center’s reporting
efforts including superseded user manuals, HRSA webcasts, etc.
• All quarterly ARRA reporting checklists should indicate whether supporting
documentation (e.g. contracts) should be attached to ease review and provide
a proper audit trail
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Key Points
• Make sure the internal control policies and checklists created
are flexible enough to work for various ARRA grant types
• The Board of Directors must approve the policy
• Ensure all individuals participating in ARRA activities are
familiar with the internal control procedures AND the Federal
grant compliance requirements, including program personnel
• Verify that you are aware of ALL of the ARRA funding your
health center receives and the respective compliance
requirements
• Once you create a policy, you must stay compliant with it!
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Appendix A –
FederalReporting.Gov Data Elements
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What Data is Needed for FederalReporting.Gov?
• Required Data (Contained in the Recipient Reporting Data Model)
– Prime Recipient
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Federal Funding Agency Name
Award identification
Recipient DUNS
Parent DUNS
Recipient CCR information
CFDA number
Recipient account number
Project/Grant period
Award type, date, description, and amount
Amount of Federal Recovery Act funds expended to projects/activities
Activity code and description
* Recipient Reporting Data Model can be accessed at www.Recovery.gov /Recipient Reporting
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What Data is Needed for FederalReporting.Gov?
• Required Data (Contained in the Recipient Reporting Data Model)
– Prime Recipient (cont’d)
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Project description and status
Job creation narrative and number
Infrastructure expenditures and rationale, if applicable
Recipient primary place of performance
Recipient area of benefit
Recipient officer names and compensation (Top 5)
Detailed information on sub-recipients and/or vendors utilized by the
recipient, including data elements required to comply with the Federal
Funding Accountability and Transparency Act (FFATA).
– Separate information for each sub-recipient/vendor for subawards/contracts equal to or more than $25,000
– Can aggregate information for sub-awards/contracts less than $25,000
– Sub Recipient is essentially the same information required by Prime
Recipient unless data is posted by Prime Recipient
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Appendix B –
Overview of Selected Federal Grant
Compliance Requirements
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Federal Grant Compliance Requirements
• Time allocation (OMB Circular A-122):
– For employees working on multiple Federal awards, personnel
costs should be charged to each award base on “after-the-fact, time
and effort reports in accordance with OMB Circular A-122.
• Must be signed by a supervisor having first hand knowledge of
how an individual spend their time
• May be prepared on a per pay-period basis or on a monthly
basis, aligned with the month’s applicable pay-periods
• Allocations based on budgeted percentages or time-studies are
not acceptable
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Federal Grant Compliance Requirements
• Procurement Standards (45 CFR Part 74):
– Does the center have appropriate procurements procedures in place
for purchases funded by Federal Awards?
• Open Competition (RFPs and bids for purchases over
$100,000)
• Contract requirements for alteration/renovation projects (e.g.
Davis Bacon Act)
• Cost/price analysis documentation
• Suspension and debarment concerns
• Other
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Federal Grant Compliance Requirements
• Property Standards (45 CFR Part 74):
– Does the Center maintain equivalent insurance coverage for both
property and equipment acquired with Federal funds as well as
non-Federal?
– Does the Center follow prescribed requirements relative to the use
and disposal of real property purchased in whole or in part with
Federal funds?
– Does the Center comply with Notice of Federal Interest filings?
– Other
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Federal Grant Compliance Requirements
• Equipment Standards (45 CFR Part 74):
– Does the center maintain a fixed asset inventory listing with all of
the required data elements including:
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Description
Acquisition date and cost
Asset identification number, or tag
Whether the asset was purchased with Federal funds
– Are physical inventories performed every 2 years?
– Does the center have appropriate procedures in place regarding the
disposal of equipment?
– Other
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Questions???
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www.rsmmcgladrey.com
@
[email protected]
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