APRIL 2011 93.520 CENTERS FOR DISEASE CONTROL AND PREVENTION AFFORDABLE CARE ACT (ACA) COMMUNITIES PUTTING PREVENTION TO WORK State Project/Program: ACA CPPW COMMUNITY GRANTS U. S. Department of Health and Human Services, Centers for Disease Control and Prevention Federal Authorization: 301A, 311BC, 317K2 (42USC241A, 243BC247BK2) N. C. Department of Health and Human Services Division of Public Health Agency Contact Person Program Cathy Thomas, Branch Head Physical Activity and Nutrition (PAN) Branch (919) 707-5216 Cathy.Thomas@dhhs.nc.gov Agency Contact Person Financial Judith McDermott, Chief Budget Officer Division of Public Health (919) 707-5080 Judith.McDermott@dhhs.nc.gov N. C. DHHS Confirmation Reports: SFY 2011 audit confirmation reports for payments made to Counties, Area Programs, Boards of Education, Councils of Government, District Health Departments, DCD State Level Contractors and HRSA Bioterrorism Grant Subrecipients 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 2010-2011). 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 Year 2009-2011). 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. B-4 93.520 1
I. PROGRAM OBJECTIVES In the United States today, seven of ten deaths and the vast majority of serious illness, disability, and health care costs are caused by chronic diseases, such as obesity, diabetes and cardiovascular disease. Key risk factors lack of physical activity, poor nutrition, and tobacco use are major contributors to the nation s and to North Carolina s leading causes of death. Physical inactivity and poor dietary habits are major risk factors for chronic diseases including cardiovascular disease, cancer, diabetes, and obesity. According to the 2009 North Carolina Behavioral Risk Factor Survey, less than half of North Carolina adults (46.4%) get the recommended amount of physical activity and 20.6% eat five or more fruits and vegetables each day. More than two thirds of North Carolina adults (65.4%) and one third of North Carolina children (32.3%) are overweight or obese. Many North Carolinians die prematurely and suffer from diseases that could be prevented or more effectively managed. The Centers for Disease Control and Prevention s (CDC) Communities Putting Prevention to Work (CPPW) initiative seeks to address the risk factors of physical inactivity and poor nutrition. Research has shown that implementing policy, systems, and environmental changes, such as improving physical education in schools, improving safe options for active transportation, providing access to nutritious foods, and other broad-based policy change strategies, can result in positive behavior changes related to physical activity and nutrition, which positively impact multiple chronic disease outcomes. The NC Division of Public Health (DPH) received a CPPW grant to implement projects to promote physical activity and healthy eating in the Appalachian District (Alleghany, Ashe, and Watauga counties) and Pitt County. The Appalachian District Health Department and the Pitt County Health Department will work with partners to implement evidence-based strategies that promote healthful eating and active lifestyles. The CPPW grant provides the Appalachian District Health Department (ADHD) with resources to develop and implement policy, systems, and environmental change interventions that will lead to sustained. The CPPW grant is funded through the Patient Protection and Affordable Care Act (PPACA) and administered by the CDC. II. PROGRAM PROCEDURES Per the federal funding opportunity announcement (CDC-RFA-DP09-912ARRA09), a maximum of two health districts serving fewer than 500,000 people could apply for funding with the support of the State health department as part of a State-coordinated application. The North Carolina Division of Public Health, Physical Activity and Nutrition (PAN) Branch coordinated a competitive selection process to determine which two local health departments to include in the state-coordinated application. The selection process consisted of a written application and an in-person presentation with reviewers scoring each applicant independently against pre-set criteria. The Appalachian District Health Department and the Pitt County Health Department were selected to participate in the State-coordinated application. The North Carolina Department of Health and Human Services, Division of Public Health was awarded the ACA CPPW Communities Grant (1U58DP003053-01) for the period September 30, 2010 through September 29, 2012. The grant was awarded through the U. S. Centers for Disease Control and Prevention with funding from the Patient Protection and Affordable Care Act (PPACA). The grant requires that at least 75% of the total award be allocated to the Appalachian District Health Department and the Pitt County Health Department. This is accomplished by establishing Agreement Addenda to the North Carolina Division of Public Health s Consolidated Agreement with local health departments/ General Agreement Guidance: The Consolidated Agreement provides general guidelines regarding approved policies and procedures related to the implementation of public health programs and B-4 93.520 2
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 ACA Community Grant Agreement Addendum (#861) to the Consolidated Agreement provides guidance to local health departments regarding specific requirements for local programs receiving ACA CPPW funds. Health departments also receive detailed guidance from the PAN Branch related to developing their annual Community Action Plan for health promotion activities. Monitoring: On a monthly basis, the CDC and PAN Branch assess programmatic risk through a monthly program review call with each funded local health department. CDC documents progress on these monthly calls. The PAN Branch attends monthly coalition meetings in each community to monitor progress and provide technical assistance. CDC will conduct a programmatic site visit to each local health department at least once during the two-year grant period. The PAN Branch will monitor expenditures by budget category on a monthly basis through an expenditure report form completed by each local health department. 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 with communities that will identify barriers and gaps that exist in current policy General operating expenses including rent, phone services, postage, etc. Furniture or equipment only if with approval of CDC B-4 93.520 3
Funds may not be used for the following types of expenditures: Research Clinical care (but can include funds for clinical services where appropriate) Pre-award costs Construction, alteration, maintenance, or repair of a public building or public work unless all of the iron, steel, and manufactures goods used in the project are produced in the United States unless HHS waives the application of this provision. Lobbying, pursuant to 31 U.S.C Section 1352; 18 U.S.C. Section 1913. 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 CPPW Community Grant Requirements: As a recipient of ACA CPPW Community Grant funds, local health departments and districts have agreed to: Develop, attain CDC approval, and implement a 24-month Community Action Plan (CAP) to increase supports for healthy eating and physical activity. Develop a Leadership Team consisting of 8-10 high-level leaders of influence in the community to oversee the strategic direction of the project activities, be responsible for enacting policies related to the evidence-based strategies in the Community Action Plan, establish and maintain an organizational structure and governance for the community coalition, and participate in project-related local and national meetings. Assist the PAN Branch in developing and implementing a comprehensive evaluation plan for the grant project, including quantitative and qualitative data collection for process and outcome measurement. Develop a sustainability plan with their Leadership Team by September 2012 to clearly articulate how progress achieved in the CAP will be sustained after the grant has ended. 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 CPPW Community Grant Agreement Addendum, expenditure reports, Community Action Plan, and Monthly Progress Reports (CDC to document beginning in February 2011) for their grant activities funds. If the health department cannot provide these documents, they are available from the PAN Branch 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. Review selected expenditures for consistency with applicable cost principles. C. Cash Management Funds are granted on a reimbursement basis. B-4 93.520 4
D. Davis-Bacon Act E. Eligibility Clinical care is not an allowable cost for this grant, but funds can be used for clinical services where appropriate. Local Health Departments are authorized to establish and administer client eligibility criteria for individual services provided through the Consolidated Agreement. These criteria are not prescribed in the Agreement. Procedures for determining client eligibility and evaluate for adequacy are located at the local health department level. Community based programs are not based on individual client eligibility. Health departments are expected to include targeted services to eliminate health disparities in special populations. Review the local health department eligibility criteria for individual services and records of activities reported to CDC to determine if individuals targeted for interventions are the actual beneficiaries of the activities. F. Equipment and Real Property Management Purchase of equipment is not allowable unless identified in the budget and approved by CDC. Review approved budget and any expenditure for equipment purchases. G. Matching, Level of Effort, Earmarking H. Period of Availability of Federal Funds The grant period is September 30, 2010 through September 29, 2012. Funding for the entire twoyear grant period was made available for draw down on September 30, 2010. Grant funds for local health departments will be allocated through the NC Division of Public Health Consolidated Agreement over State Fiscal Years 2009-10, 2010-11, and 2011-12. Each local health department can provide the auditor with a copy of the Consolidated Agreement for the particular year being audited. The PAN Branch 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. Select a sample of funded procurement, if any, for activities subject to federal agency codifications of the grants management common rule. J. Program Income B-4 93.520 5
K. Real Property Acquisition and Relocation Assistance 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. Review the files for evidence of monthly progress reports. Review the files for evidence of Community Action Plan. M. Subrecipient Monitoring On a monthly basis, the CDC and PAN Branch assess programmatic risk through a monthly program review call with each funded local health department. Progress if measured against a CDC approved Community Action Plan developed by each health department. CDC documents progress on these monthly calls. The PAN Branch attends monthly coalition meetings in each community to monitor progress and provide technical assistance. CDC will conduct a programmatic site visit to each local health department at least once during the two-year grant period. The Office of Local Health Services is responsible for assessing fiscal risk status for local health departments. The PAN Branch will also monitor expenditures by budget category on a monthly basis through an expenditure report form completed by each local health department. 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: Administrative, Local and Community Support, Chronic Disease and Injury Prevention, Epidemiology, Oral Health, Women s and Children s Health, and 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 B-4 93.520 6
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) 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. s 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. B-4 93.520 7