APRIL 2006 93.988 COOPERATIVE AGREEMENTS FOR STATE-BASED DIABETES CONTROL PROGRAMS AND EVALUATION OF SURVEILLANCE SYSTEMS State Project/Program: DIABETES PREVENTION AND CONTROL PROGRAM PROJECT DIRECT U. S. Department of Health and Human Services Federal Authorization: Public Health Service Act, Section 301(a) and Section 317(k)(3), 42 U.S.C. 247b, as amended; Health Services and Centers Amendments of 1978, Public Law 95-626; Omnibus Budget Reconciliation Act of 1981, as amended, Public Law 97-35. State Authorization: N. C. Department of Health and Human Services Division of Public Health Agency Contact Person Program Christopher Bryant Diabetes Prevention & Control Branch (919) 707-5343 Christopher.Bryant@ncmail.net Agency Contact Person - Financial Frances Dreps (919) 707-5071 Frances.Dreps@cmail.net N. C. DHHS Confirmation Reports: SFY 2006 audit confirmation reports for payments made to Counties, Area Programs, Councils of Government and District Health Departments will be available by around late August to early September at the following web address: http://www.dhhs.state.nc.us/control/ At this site, page down to Letters/reports/forms for ALL Agencies" and click on "Audit Confirmation Reports (State Fiscal Year 2005-2006). 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 2003-2005). 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. I. PROGRAM OBJECTIVES Project DIRECT is a multi-year community diabetes education project, funded by the Centers for Disease Control and Prevention. It is intended to develop, implement and evaluate strategies that can be incorporated into State-based diabetes control programs statewide and nationally. DIRECT involves a partnership among the Community of Southeast Raleigh, NC; the Division of Public Health in the NC Department of Health and Human Services, Wake County Human Services; and the Centers for Disease Control and Prevention (CDC). The mission is to reduce the burden of diabetes and its complications. The target population is the African-American community in Southeast Raleigh and the surrounding communities. B-4 93.988 1
In previous years, Project DIRECT was funded under a separate federal grant from the Centers for Disease Control and Prevention (CFDA 93.283). In September 1999, separate funding for Project DIRECT ended and thereafter was included in the award to North Carolina for the Diabetes Prevention and Control Program (CFDA 93.988) to become one consolidated program under a single federal grant. II. PROGRAM PROCEDURES The Diabetes Prevention Control Program (DPCP) awarded $248,000 to Wake County Human Services under the Consolidated Contract. Wake County is responsible for housing Project DIRECT and hiring staff at Project DIRECT. This includes responsibilities for managing all funds allocated to the county for the project. This includes hiring staff, paying salaries, paying rent, purchasing supplies, contractual services, and travel services. The Consolidated Contract sets forth the more general requirements of the funding relationship between the state and local public health agencies. The respective requirements are detailed under headings including: Work to Be Performed; Funding Stipulations; Fiscal Control; Responsibilities of the State; and, Compliance. More specific information is set out in a document called the Contract Addendum which details each program 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 Guidance which is sent annually from each of the Divisions to all health departments being allocated funds from specific sources, i.e., State appropriations or federal grant funds. This Guidance indicates the amount of the allocated funds and their respective sources. Each health department will be able to provide an auditor with a copy of the Consolidated Contract for the particular year being audited, as well as, copies of the Budgetary Guidance, Contract Addenda, expenditure reports and any activity reports for each source of money received. If the health department cannot provide these documents, they are available from the respective State health program office above. The Diabetes Prevention and Control Program is responsible for monitoring and evaluating the work of Project DIRECT, Wake County Human Services. An annual Progress Report is due to CDC. The report is prepared as a group effort between the staff of Project DIRECT at both the state and county levels. Project DIRECT is required to prepare summary reports and updates on activities whenever requested by the DPCP or CDC. Staff members of Project DIRECT are responsible for: Providing training for health care providers. Developing training materials. Coordinating self-management education programs and self-help support groups for persons with diabetes. Providing nutrition training for churches. Coordinating health assessments and the subsequent development of action plans for African-American churches. Coordinating Ready Set Walk and Lay Exercise Leader programs in the community. B-4 93.988 2
Early identification of persons at risk for diabetes or those with the disease who are not receiving medical care through initiatives with Wake Health Services, Inc, a local community health center and the media. Data collection for evaluation purposes only, not research. Staffing and support to the Project DIRECT Executive Committee and Coalition. Report writing and grant development. Institutionalization of the project and transition out of research, along with state staff. With the DCPC and Consultant develop a Project DIRECT Academy to train Local Health Department s and other community-based organizations. The governing body for the project is the Executive Committee. This committee is responsible for policy-level decisions. The committee normally meets every other month and is staffed by Wake County personnel. Community input is important for the project. Several organized groups are in place to create opportunities for community input. These groups include: the Executive Committee (the governing body), the Coalition (that consists of all community representatives and groups active with the project), Community Ambassadors (community persons that provide on-site support of activities, attend health fairs and participate on radio shows), Scientific Team, and Academy Planning Committee Ad Hoc committees. III. COMPLIANCE REQUIREMENTS A. Activities Allowed or Unallowed Several activities were approved in the budget. These activities include: 1. Purchase of materials and resources to physicians from practices participating in project. 2. Purchase of materials to conduct training classes and lead self-management education programs and support groups on diabetes. 3. Purchase of supplies for nutrition classes. 4. Purchase of media services to promote project. 5. Hiring of professionals to: facilitate training workshops, teach self-management education programs, provide healthy cooking demonstrations, provide administrative assistance, and review medical records. Costs per hour were based on rates at the time the budget was prepared. Costs may differ based on the availability of services and the current market price. 6. Executive Committee and Coalition meeting support to provide a forum for gathering community input. Suggested Audit Procedure: Review the Consolidated Contract Addenda and expenditure documentation to determine the appropriateness of activities paid by these funds. B-4 93.988 3
B. Allowable Costs/Cost Principles Allowable costs are identified in the budget for the project which is a part of the Contract Addendum and also approved by the Centers for Disease Control and Prevention within their review of the entire DPCP grant award. Specific line items are listed below. 1. Salaries 2. Fringe Benefits 2. Temporary Wages 3. Contractual Services (including lease of office space, advertising, janitorial and exercise facilitator) 4. Travel 7. Supplies 8. Coalition Activities 9. Intervention Support 10. Other including (electricity, printing/duplication, postage, phone, maintenance agreement) 11. Indirect Cost @ 10% of overall budget Suggested Audit Procedure: Review the accounting records for the project to determine if actual expenditures are within the allowable costs for the budget provided. C. Cash Management In accordance with the provisions of the Consolidated Agreement with Local Health Department/Districts/Public Health Authorities/Human Services Agencies, local agencies report actual expenditures on a monthly basis. Payments are made in the following month based upon the amounts of reported expenditures to the extent that authorization remains. Payments, comprised of both Federal and State funds are used to support operating expenses, primarily salary and fringes and the purchase of pharmaceuticals for patients. E. Eligibility The project does not deny service to any person; however, the target population is the African-American community in Southeast Raleigh, NC and the places where the residents obtain medical services. Outreach activities are focused on reaching Southeast Raleigh residents through area faith organizations, fraternal organizations, health care providers and civic organizations. Project DIRECT s walking activities, diabetes self-management classes, support groups, church nutrition classes, or workshops are open to all Wake County residents but again, target African Americans in Southeast Raleigh. Persons participating in Ready Set Walk activities must provide a signed physician consent form prior to beginning the program. The quality improvement initiative is open to primary care providers who care for the target community. B-4 93.988 4
Suggested Audit Procedure: Review the Consolidated Contract Addendum, and records of activities reported to determine if groups targeted for interventions are the actual beneficiaries of the activities. F. Equipment and Real Property Management Local agencies are required to obtain prior written approval prior to purchasing or leasing to purchase items of equipment with an acquisition cost of greater than $1,000. (Consolidated Agreement) H. Period of Availability of Federal Funds In accordance with the provisions of the Notice of Grant Award (NGA), funds may be used to support costs incurred during the funding period. This period is the same as the State's grant funding period (March 30 through March 29). Unobligated, unexpended funds may not be carried forward. Settle-up and final expenditure submission should occur within forty-five days of the end of the contract period. I. Procurement and Suspension and Debarment Procurement 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 with federal agency codifications of the grants management common rule accessible on the Internet at http://www.whitehouse.gov/omb/grants/chart.html. 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 procurement standards described in the North Carolina General Statutes and the North Carolina Administrative Code, which are identified in the State of North Carolina Agency Purchasing Manual accessible on the Internet at http://www.doa.state.nc.us/pandc/agpurman.htm#p6_65. Nongovernmental subrecipients shall maintain written Procurement policies that are followed in procuring the goods and services required to administer the program. Suspension and Debarment Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. L. Reporting Financial Reporting: Compliance Requirement Local Health Department Projects: Local agencies are required to submit a monthly Local Expenditure Report. [15A NCAC 21A.0819] B-4 93.988 5
N. Special Tests and Provisions Administrative staff in the Division of Public Health developed a single contract document to manage all funds, both State and federal which the Division allocated to local health departments across the State. This document, as amended, is used as the Consolidated Contract for all local health departments and districts. This Contract sets fourth the more general requirements of the funding relationship between the state and local public health agencies. The respective requirements are detailed under headings including; Work to Be Performed; Funding Stipulations; Fiscal Control; Responsibilities of the State; and, Compliance. More specific information is set out in a document called the Contract Addendum which details each program 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 Guidance which is sent annually from each of the Divisions to all health departments being allocated funds from specific sources, i.e., state appropriations or federal grant funds. This Guidance indicates the amount of the allocated funds and their respective sources. Each health department will be able to provide an auditor with a copy of the Consolidated Contract for the particular year being audited, as well as, copies of the Budgetary Guidance, Contract Addenda, expenditure reports and any activity for each pot of money received. If the health department cannot provide these documents, they are available from the respective public health Divisions mentioned above. Suggested Audit Procedures - It is suggested that the auditor review Section B. FUNDING STIPULATIONS of the Consolidated Contract before beginning an audit. The fourteen items of this Section, as applicable, describe much of the detailed information the auditor may be seeking during a review of these programs. Conflicts of Interest and Certification Regarding Overdue Tax Debts 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. 143-6.2 for fiscal years beginning on or after July 1, 2005. These requirements include the submission of a Notarized Conflict of Interest Policy (see G. S. 143-6.2(b1)) and a written statement (if applicable) 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. 143-6.2(b2)). 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. B-4 93.988 6