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1 The following information was used as visual aid during a presentation/training session led by a BKD, LLP advisor. This content was not designed to be utilized without the verbal portion of the presentation. Accordingly, information included on these slides, in some cases, are only partial lists of requirements, recommendations, etc. and should not be considered comprehensive. These materials are being issued with the understanding that they must not be considered legal advice. 1 // experience drive

2 CPAs & ADVISORS experience clarity // CFO GUIDEBOOK TO GRANTS MANAGEMENT Presenter: David Fields, Director October 23, 2014

3 FEDERAL REGULATIONS What do you know about federal regulations? How did you learn it? How are you supposed to deal with it given all of the other things on your plate? What do you think is the most important issue with federal regulations? Least? 3 // experience clarity

4 MYTHS Reasonable & defendable I will just explain it... Cannot tell me what to do... What are other myths? 4 // experience clarity

5 WHY DO WE CARE? OIG audits of CHCs 18 in 2012 projected 57 in 2013 Six and seven figure questioned costs New era of accountability phrase spoken with ARRA bill Accountability, not new rules HRSA scrutinized by OIG OIG audits of CHCs Significant questioned costs 5 // experience clarity

6 THE RULES Federal laws & regulations Section 330 of the Public Health Services Act (42 U.S.C. 254b) Program specific: CHC (42 CFR 51c) & Migrant (42 CFR 56) Grant administrative regulations (OMB Circular A-110) : 45 CFR 74 ~ Non-profits & 45 CFR 92 ~ State, Local, Tribal Government Cost principles: 2 CFR part 230 (OMB Circular A-122) Audit requirements: OMB Circular A // experience clarity

7 THE RULES Awarding agency guidance HHS Grants Policy Statement BPHC Policy Information Notices ( PINs ) & Program Assistance Letters ( PALs ) Notice of award ( NOA ) terms & conditions 7 // experience clarity

8 FEDERAL REGULATION MAP HHS / HRSA / BPHC Office Supply Company Non-Profit CHC Organization (PRIVATE) Section 330 CHC Grant Local / Tribal Government Gov t Contract - Paper Gov t Contract - Staples CHC Department (PUBLIC) 501(c)(3) Non-Profit Requirements Local / Tribal Government Requirements Federal Contractor Requirements A-110 Grants Management Standards Agriculture 7 CFR 3019 A CFR, Part 230 Cost Principles Standards A-133 Single Audit A-102 Grants Management Standards Agriculture 7 CFR 3016 A-87 2 CFR, Part 225 Cost Principles Standards A-133 Single Audit Federal Acquisition Regulation - FAR HHS 45 CFR 74 HHS 45 CFR 92 HUD 24 CFR 84 HUD 24 CFR 85 8 // experience clarity 8

9 OMB Super Circular OMB Super Circular finalized 12/26/13 Consolidates eight grant related circulars into a uniform regulation applicable to all grant recipients, including OMB Circulars A-110, A-122 and A-133 Effective for grants issued after December 26, 2014, most likely applicable for year ending December 31, 2015 Streamlined grant requirements 9 // experience clarity

10 CODIFICATION OF EIGHT OMB CIRCULARS Administrative Requirements A-102 A-110 A-89 Grants and Cooperative Agreements with State and Local Governments Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations Catalog of Federal Domestic Assistance A-21 Cost Principles for Educational Institutions 2 CFR Part 200 Cost Principles A-87 Cost Principles for State, Local and Indian Tribal Governments A-122 Cost Principles for Non-Profit Organizations Audit Requirements A-133 A-50 Audits of States, Local Governments and Non-Profit Organizations Audit Follow-Up 10 // experience clarity 6

11 A CFR PART 74 HHS NOT-FOR-PROFIT VERSION Purpose of 45 CFR 74 Guidance to uniform administrative guidance HHS grantees not-for-profit organizations Who? Not-for-profit What? Administrative Requirements e.g., foundational grant rules 11 // experience clarity

12 A CFR PART 74 HHS NOT-FOR-PROFIT VERSION Why? Speak the language, know the terms Describes your responsibilities Because they are your responsibilities Warnings Your Organization Who knows & who is responsible? Best practices To do 12 // experience clarity

13 FINANCIAL & PROGRAM MANAGEMENT TO Purpose of financial & program management Yes there is an app rule for that Rules & regulations Permeates many daily activities Documentation Cash management Administratively feasible 13 // experience clarity

14 PROPERTY STANDARDS TO Federal versus non-federally funded Reversionary interest Inventory Can you identify federal items? Have you documented required elements? E.g. condition, use, serial #, etc. 14 // experience clarity

15 PROCUREMENT TO Code of Conduct Competition Procedures Thresholds Cost/Price analysis Documentation 15 // experience clarity

16 REPORTS & RECORDS TO Monitoring Financial Reporting Record Retention 3 years from date of final report What about other dates? 16 // experience clarity

17 POLICIES Cash management 74.21(b)(5) Allowable & allocable expenses 74.21(b)(6) Fixed asset to Documentation & inventory inventory 17 // experience clarity

18 POLICIES Procurement to Written code of conduct Price cost analysis Contract provisions Grant reporting policies Record retention // experience clarity

19 A CFR PART 230 Purpose Uniform cost principle administrative guidance Who? Not-for-profits What? What can & cannot be charged to a grant e.g., Foundational cost principles 19 // experience clarity

20 A CFR PART 230 Why? Know what is permissible Warnings Your organization who knows & who is responsible? Ignorance of law is no excuse Best practices To do 20 // experience clarity

21 GENERAL PRINCIPLES SECTION A APPENDIX A Allocation Fair Share Consistency Specifically, reasonably, necessary & equitably Documentation How are your costs supported? Prudent person 21 // experience clarity

22 ITEMS OF COST MUST BE Reasonable for performance of award Allocable A-122 No A-122 limitations or exclusions In accordance with policies & procedures Treated consistently GAAP Not double counted cost sharing, etc. Adequately documented 22 // experience clarity

23 GENERAL PRINCIPLES SECTION B, C & D APP. A Direct versus Indirect costs Cost Allocation Plan Do you have one? Indirect Cost Rate Do you need one? 23 // experience clarity

24 SELECTED ITEMS OF COST APPENDIX B Definitions & terms for how you determine if something is allowable or not Think we know Do we really know? This is critical when determining what to charge to each grant Know the risks 24 // experience clarity

25 SUPPORT SALARIES & WAGES SECTION 8(M) Time & effort reporting Maintained for all staff members whose compensation is charged in whole or in part directly to awards or if needed to facilitate determination of indirect cost rate (2) Includes hourly & salary Uses term personnel activity report See required elements on PAR slide 25 // experience clarity

26 PERSONNEL ACTIVITY REPORTS (PARS) After the fact Actual Not budget Total activity Signed as accurate Employee or Supervisor with firsthand knowledge Prepared monthly Coincide with at least one pay period 26 // experience clarity

27 TIME AND EFFORT REPORTING NEW Strengthens requirements for strong internal control Section (i) Charges to Federal awards for salaries and wages must.. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Personnel activity reports (time and effort reporting) is not specifically required Federal grantee must be able to properly document the allocation of salary costs to each Federal grant 27 // experience clarity

28 TIME AND EFFORT REPORTING - NEW Document the internal control system that is in effect to help prevent salary and wage expense from being allocated incorrectly Each grantee must be able to document the internal control system that is in effect to help prevent salary and wage expense from being allocated incorrectly 28 // experience clarity

29 TIME AND EFFORT REPORTING - NEW Section (i)(8) For a non-federal entity where the records do not meet the standards described in this section, the Federal government may require personnel activity reports, including prescribed certifications, or equivalent documentation that supports the records as required in this section. 29 // experience clarity

30 PINS & PALS Policy Information Notices (PINs) Define & clarify policies & procedures Program Assistance Letters (PALs) Summarize & explain items of significance HRSA program implementation activities Recently enacted laws Final regulations New HHS initiatives How do you monitor and address these? 30 // experience clarity

31 MUST READ PINS & PALS PIN : CHC Budgeting & Accounting Requirements PIN : Sliding Fee Discount and Related Billing and Collections Program Requirements PAL : Sites, Scope of Project, and Capital Projects PIN : Defining Scope of Project and Policy for Requesting Changes PAL : Process for Becoming Eligible for Medicare Reimbursement under the FQHC Benefit PIN : Health Center Program Governance 31 // experience clarity

32 19 KEY PROGRAM REQUIREMENTS Bureau of Primary Health Care Expectations 5 finance related Who in your organization is responsible for each of these? See audit guide 32 // experience clarity

33 19 HEALTH CENTER PROGRAM REQUIREMENTS Needs Assessment Required and Additional Services Staffing Accessible Hours of Operations/Locations After Hours Coverage Hospital Admitting Privileges and Continuum of Care Sliding Fee Discounts Quality Improvement/Assurance Plan Key Management Staff Contractual/Affiliation Agreements 33 // experience clarity

34 19 HEALTH CENTER PROGRAM REQUIREMENTS Collaborative Relationships Financial Management and Control Policies Billing and Collections Budget Program Data Reporting Systems Scope of Project Board Authority Board Composition Conflict of Interest Policy 34 // experience clarity

35 WHAT ARE YOU GOING TO DO? Take it seriously Educate Knowledge is power understand regulations Assign responsibility Break into segments Identify point person Enable them to succeed Hold accountable 35 // experience clarity

36 WHAT ARE YOU GOING TO DO? Segment action plans Review policies Reconsider processes Prioritize your weaknesses & start now Get training Stay informed & connected NACHC, State/Regional PCAs, Network Accept this is cost of doing business, but adjust as efficiently & painlessly as possible 36 // experience clarity

37 Please feel free to contact David Fields, CPA, CMA, CFM Director

38 The information in BKD seminars is presented by BKD professionals, but applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor before acting on any matters covered in these seminars.