Transcript Brad Barney - TARGET Center

Ryan White
Technical Assistance Webinar
Effectively Complying with Your
Draw Down Restriction
June 21, 2012
HIV/AIDS Bureau, Division of Service Systems
Office of Federal Assistance Management
Effectively Complying with Draw Down Restriction
Harold Phillips
Deputy Director, Division of State and Territorial HIV
Programs
Brad Barney
Office of Federal Assistance Management (OFAM)
Moderator
Anita Edwards
Project Officer, Northeastern Central Services Branch
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Effectively Complying with Draw Down Restriction
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Agenda
HRSA Announcements
When is Draw Down Restriction used
Special Conditions or Restrictions
Process for Putting Grantee on DDR
Corrective Action Plan
Draw Down Requests
Removal of Draw Down Restriction
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HRSA HAB Announcements
•ADAP FY 2012 ERF
•Ryan White 2012 Grantee Meeting
•HIV Testing for AIDS-Free Generation
•Funding to Support Linkage to Care
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Question & Answer Session
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Effectively Complying with Draw Down Restriction
Harold Phillips, Deputy Director
Division of State and Territorial HIV Programs
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When is Draw Down Restriction Used
• One of HRSA’s responsibilities is to safeguard Federal funds through
the monitoring of programmatic progress, grantee expenditures,
and adherence to legislative and programmatic requirements.
• When potential problems are identified, HRSA attempts to correct
any issues by working with the grantee and providing guidance and
technical assistance (TA)
• When TA and other inputs are not sufficient to correct a problem, a
grantee may be deemed “high-risk,” and increased monitoring in
the form of draw down restrictions (DDR) may be used.
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When is Draw Down Restriction Used
What determines when a grantee is “high risk?” (45 CFR
92.12):
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Has a history of unsatisfactory performance, or
Is not financially stable, or
Has a management system which does not meet the
management standards set forth in 45 CFR 92.20, or
Has not conformed to terms and conditions of previous
awards, or
Is otherwise not responsible; and if the awarding agency
determines that an award will be made, special
conditions and/or restrictions shall correspond to the
high risk condition and shall be included in the award.
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When is Draw Down Restriction Used
For local government or states/territories funded under Part A
and Part B respectively of the Ryan White HIV/AIDS Treatment
Program draw down restrictions may also be used when a
grantee has failed to:
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Take adequate steps to implement Ryan White program requirements;
Respond adequately to previous (TA) efforts and/or award conditions;
Implement adequate programmatic and fiscal oversight of contractors/subgrantees regarding the use of funds and payer of last resort requirements;
Assure adequate staffing and/or coordination between the grantee’s Ryan
White program managers and the grantee fiscal/budget officer; and/or
Address financial shortfalls or other fiscal problems that impact the grantee’s
capacity to disburse and manage funds, provide adequate program oversight,
and/or assure continuity of care and treatment for eligible clients.
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Special Conditions or Restrictions
Special conditions or restrictions may include:
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Payment on a reimbursement basis;
Withholding authority to proceed to the next phase
until receipt of evidence of acceptable performance
within a given funding period;
Requiring additional, more detailed financial reports;
Additional project monitoring;
Requiring the grantee or sub-grantee to obtain
technical or management assistance; or
Establishing additional prior approvals.
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HAB Process for Placing Grantee on
Draw Down Restrictions (DDR)
• Project Officer (PO) and Grants Management Specialist (GMS)
consult re: identified issues
• PO prepares DDR Recommendation and proposed CAP
• Division convenes a DDR Review Meeting (Director, Senior Program
Advisor, Branch Chief, PO, GMS, others from OFAM or HAB as appropriate to situation)
• Division Director and DGMO/OFAM concur on the decision to
impose DDR and the final CAP
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HAB Process for Placing Grantee on
Draw Down Restrictions (DDR)
• The Grantee is notified by:
– Issuance of a Notice of Award explaining the condition
– Letter from the Division Director, that includes the CAP
– Project Officer call and/or email to alert the Grantee Program Director
to the action being taken and schedule a conference call
• A record of all communication with the grantee and actions
taken in relation to a DDR will be maintained in the Grantee’s
official folder in the HRSA ElectronicHandbooks (EHB)
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DDR Corrective Action Plan
Corrective Action Plan (CAP)
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Identifies the deficiency or problem(s)
Gives background information about the problem(s)
Provides details of HRSA’s efforts to remedy the
problems (Technical Assistance (TA), conference calls,
written guidance, etc.)
Lists specific corrective actions that the grantee must
complete, the responsible person(s), and the
timelines for each step
Details the final expected outcome
Identifies any recommended training or TA
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HAB Monitoring of Grantees on DDR
• PO Monitoring includes:
– DDR-specific conference calls initially as needed (including key Grantee program
and fiscal staff)
– Monthly Monitoring Calls: regular agenda item
– Review/approval of all Requests for Funds
– Review/approval of all submissions related to CAP
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Biweekly PO and Branch Chief review of grantee progress
Site visit if needed
Quarterly DDR Meetings to evaluate progress
Annual DDR as part of the annual grant application/award process
• HAB Level:
– HAB Senior Program Advisor will monitor status of all Ryan White Grantees on DDR
in consultation with the Division Senior Program Advisors
– The Associate Administrator is kept informed of the status by the Senior Advisor as
well as by Division Directors in their 1-1 biweekly meetings
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Effectively Complying with Draw Down Restriction
Brad Barney
Office of Financial Assistance Management
(OFAM)
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Notice of Award
Notice of Award (NoA)
• Once a grantee is placed on restricted draw down, a new NoA will be
released with a grant specific term detailing the reason for the restriction.
The new term reads:
– Notice: As a result of [issue], all drawdown of Federal funds from the Payment
Management System (PMS) concerning this grant must have approval of the
Grants Management Officer before funds are drawn. Beginning immediately,
by the 20th of each month or a minimum of 10 days before funds are needed,
an original signed SF 270 must be submitted and subsequently approved for
anticipated expenditures, along with documentation to substantiate the
request. This restriction is expected to be temporary, pending resolution of
the above concerns by your organization. HRSA will determine when such
resolution has occurred, and will notify the grantee in writing when the
restriction has been lifted.
• NoA may also contain specific Conditions of Award in relation to the draw
down restriction, which require a timely response
• All responses to grant conditions and corrective action plan (CAP)
guidelines must be submitted via EHB prior approval system
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Draw Down Restriction Requests
Draw Down Requests
When on draw down restriction, a Request for Reimbursement (SF270) must be
submitted. When submitting a Request for Reimbursement (SF270), there are several
steps involved. All steps must be completed in order to have the request processed:
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Grantees must access the to HRSA Electronic Handbook (EHB) to request reimbursement of funds
via the Prior Approval Portal .
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In the “Comments” section of the Cover Sheet, indicate the sequenced number of the request
including the dollar amount. For example: 1st Request for Reimbursement- $200,000.00
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Grantees must upload the following documents:
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SF270. Please Note: The SF270 must correlate with the amount requested for reimbursement. All
appropriate boxes must be completed on the SF270; please do not overlook Block 4 (Identification number
assigned by Federal Agency)
Summary Sheet listing all documents/invoices being submitted (Sample Template Available).
Documents substantiate the requested amount, e.g. paid invoices/checks, pay stubs, etc.
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Please Batch and submit the documents according to budget categories, (e.g. grantee administration, CQM, Services,
ADAP, MAI, Part B Emerging Communities.)
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Draw Down Restriction Requests
Draw Down Requests (cont)
After the draw down request is submitted via EHB, the
following will occur:
• The Project Officer will review all documents submitted and
verify that the funds requested are within the scope of the
grant.
– If there are any discrepancies within the submissions, the
Project Officer will submit a “Change Request” to the grantee in
EHB.
• The change request will specify any questions or concerns the Project
Officer may have.
• The Grantee must then resubmit the Request for Reimbursement with
the necessary changes.
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Draw Down Restriction Requests
Draw Down Requests (cont)
• If the grantee’s submissions adequately substantiate their request, the
Project Officer will submit a recommendation for approval to the Division
of Grants Management Operations (DGMO) via EHB. The “Comments”
Section will note the approval amount recommended.
• Upon review and approval by the GMO, an email of the SF270 will be sent
to Payment Management System (PMS) and the project officer.
• PMS will inform grantees of the amount approved for reimbursement.
• Grantees can request the disbursement of approved funds through PMS.
Note: Grantees must still access the PMS, in a timely fashion, to request
disbursement of funds.
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Removal from Draw Down Restrictions
HAB normally revisits a Grantee’s DDR status when the following types
of corrective actions are completed:
• Issued contracts and/or memoranda of agreements for the full
amount of the Part A or B grant award
• Submitted required program terms and progress reports within the
required time-frame
• Submitted documentation demonstrating compliance with required
steps in the Grantee’s DDR CAP
• If applicable, also the Grantee’s progress in:
– Completing other corrective actions required by HAB or OFAM
following a Compliance or Comprehensive Program Site Visit
– Implementing relevant consultant or HAB recommendations in a
Technical Assistance Report
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HAB Process for Removal from DDR
• Who initiates the process?
– Usually the PO, in consultation with their Branch Chief
– Sometimes the Grantee may submit a formal request
• Step 1 : The PO consults with the GMS and, as appropriate,
other Divisions within OFAM regarding the adequacy of
Grantee progress in complying with CAP
• Step 2: The PO prepares a “recommendation” to lift the DDR
that includes a summary of Grantee’s progress
• Step 3: A Division-level Review to lift DDR is convened.
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HAB Process for Removal from DDR
• Participants in the DDR Review consider :
– The length of time the grantee has been on DDR
– The PO’s assessment of grantee progress per their
written summary and recommendation
– Grantee submissions documenting corrective actions
completed
– Training and/or TA provided to address the
deficiency/problem(s)
– Other relevant findings/recommendations based on
PO or consultant site visits
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HAB Process for Removal from DDR
• Step 4: Division Director approves/disapproves the request to lift the DDR
• Step 5 If approved – The Grantee is notified by:
– A revised Notice of Award (GMS/DGMO)
– A formal letter from the Division, which is also uploaded in the EHB’s
• Step 5 If disapproved –
– The PO schedules a conference call with the grantee to discuss
required corrective action steps that have not yet been adequately
completed.
– And, if the review process was initiated by a request from the Grantee,
a formal letter is sent informing them of HRSA’s decision, the reasons,
and what required corrective actions still need to be completed in
order to lift the DDR.
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Removal of Draw Down Restriction
• HAB will work with OFAM to periodically review
draw down restriction status of grantees
• The review will include updates of corrective
action plans, monitoring calls
• Based upon progress on correcting deficiencies,
grantees will be removed from draw down
restriction
• OFAM will issue a revised NoA lifting the
condition
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Question & Answer Session
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Effectively Complying with Draw Down Restriction
Thank You!
The webinar will be available for viewing on
the TARGET Center
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