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Out of Home Placement Services - Pre-Contractual Audit Report Training. Department of Public Welfare OCYF Bureau of Budget and Program Support. Today’s Agenda. Welcome, Introduction, Background, and Updates Tom Diehl Process and Submission of Budget Packets LaShanna Sloane

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Out of home placement services pre contractual audit report training

Out of Home Placement Services - Pre-Contractual Audit Report Training

Department of Public Welfare

OCYF

Bureau of Budget and Program Support


Today s agenda
Today’s Agenda Report Training

  • Welcome, Introduction, Background, and Updates

    • Tom Diehl

  • Process and Submission of Budget Packets

    • LaShanna Sloane

  • Overview of Indirect Administrative Staff Roster & Expenditures

    • Michael Laird

  • Concepts & Completing Budget Forms

    • Michael Laird

  • Review

  • Questions


  • Background
    Background Report Training

    • OIG Audit

      Deferrals

    • Fiscal Years Processes

      FY 08/09 – First Year Process

      FY 09/10 – Modified Process

      FY10/11 – Continual Process Improving Log Process


    Independent living
    Independent Living Report Training

    Federal financial participation is limited to foster care maintenance payments made on behalf of a child described in section 472 (a) of the Act who is in a foster family home or in a child care institution (section 472 (b)). Both "foster family home" and "child care institution" are defined in section 472 (c). Title IV-E does not include "independent living" in these definitions, and it is not considered foster care within the meaning of the Act.


    Independent living1
    Independent Living Report Training

    Programs Identified as Independent Living and

    Requesting Title IV-E Reimbursement

    Request to be Title IV-E Allowable

    a) Change Type of Service from Independent Living

    and/or

    b) Program Description

    Note:

    Independent Living and Life Skills Training are

    social services; therefore not eligible for Title IV-E.


    Ocyf licenses
    OCYF Licenses Report Training

    • FY 10/11 – License Requirements

    • Community Residential Rehabilitation

      Host Homes


    Appeals vs reconsideration
    Appeals vs. Reconsideration Report Training

    • Reconsideration Process

    • Appeals Process


    Act 148
    Act 148 Report Training

    3140.21(c) Reimbursement for Services

    The following costs will not be considered as reimbursable costs:   (1)  The cost of mental health or mental retardation treatment services.    (2)  The cost of medical and dental services when the client is eligible for other funding or has private resources.

    3140.46 Use of Other FundsPayments made by the Department under this chapter will be made only on the costs remaining after other appropriate funding sources and client-generated revenues have been exhausted.


    Act 1481
    Act 148 Report Training

    Medical Cost

    • Behavioral Health – No Title IV-E or Act 148 reimbursement.

    • Medical Assistance - Recommendation

      County provides proof that the child is not eligible for Medical Assistance.


    General information
    General Information Report Training

    • Who needs to complete these forms???

      • Public and Private providers of Out of Home Placement Services eligible for Federal Title IV-E and/or State Act 148 funding directly from OCYF or indirectly through a contractual relationship with a county agency.

    10

    10


    Foster family providers public vs private submissions
    Foster Family Providers Report TrainingPublic vs. Private Submissions

    Public Providers

    Foster Family Provider Cover Sheet

    Rate Sheet

    Current Foster Family Service Sheet

    Foster Family Per Diem Calculations Sheet

    Private Providers

    Foster Family Provider Cover Sheet

    Rate Sheet

    Current Foster Family Service Sheet

    Local Service Provider Staff Roster

    Local Service Provider by Job Classification Sheet

    Direct Administrative Expenditure Sheet

    Indirect Administrative Staff Roster Indirect Administrative Expense Sheet

    Master List of All Agency Programs Sheet

    Service Projection Chart

    Administrative Cost Per Child Per Class of Service Sheet

    Cost Allocation Plan Sheet

    Foster Family Per Diem Calculations Sheet

    11

    11


    General information1
    General Information Report Training

    Office of Developmental Programs (ODP)

    ODP Cost Reports-Difficult to identify public funding requests.

    Out of State Providers

    Must be licensed.

    Budget Reports/Support Documentation.


    Process fy 10 11
    Process FY 10/11 Report Training

    Submission and Review process will remain the same.

    Statewide Involvement

    County Review Teams

    Office of Children Youth and Families (OCYF)-Provide Technical Assistance

    Review Structure

    Private Providers-County Review Teams

    Public Providers- Office of Children Youth and Families (OCYF)


    Submission process fy10 11
    Submission Process-FY10/11 Report Training

    Submit Workbook(s) electronically to OCYF via [email protected]

    Private Out of Home Placement Service Providers-April 30th 2010.

    Subject Line-Legal Entity/Parent Org Name-“FY” Fiscal year- “Initial Submission/Re-Submission”.

    (i.e. RMA Organization-FY10-11-Initial Submission)

    File Name-Certification of Compliance #-Unit Id-“FY” Fiscal year-Legal Entity/Parent Org Name-Facility Name.

    (i.e. 649580-EE-FY10-11-RMA Organization-DEF Shelter)

    (i.e. 123450-AA-FY10-11-RMA Organization-ABC Homes)

    Note: If more than one class of service on a report, please follow below….

    (i.e. 123450-_-FY10-11-RMA Organization-ABC Homes)

    14

    14


    Submission process fy10 111
    Submission Process-FY10/11 Report Training

    • Public Out of Home Placement Service Providers-April 16th 2010.

      • Subject Line-County Name-Fiscal year-“Initial Submission/Re-Submission”.

        (i.e. Doe County-FY10-11-Public Initial Submission)

      • File Name-Certification of Compliance #-Unit Id-Fiscal year-County Name-Facility Name.

        (i.e. 649580-EE-FY10-11-Doe County-DEF Shelter)

        (i.e. 123450-AA-FY10-11-Doe County-ABC Homes)

        Note: If more than one class of service on a report, please follow below….

        (i.e. 123450-_-FY10-11-Doe County-ABC Homes)

    15

    15


    Submission process fy10 112
    Submission Process-FY10/11 Report Training

    Multiple Submissions (Same rate/Same service).

    File Name- “Multiple” Certification of Compliance #-Unit Id-“FY” Fiscal year-Legal Entity/Parent Org Name-Facility Name.

    (i.e. Multiple 649580-EE-FY10-11-RMA Organization-DEF Shelter)

    (i.e. Multiple 123450-AA-FY10-11-RMA Organization-ABC Homes)

    Note: If more than one class of service on a report, please follow below….

    (i.e. Multiple 123450-_-FY10-11-RMA Organization-ABC Homes)


    Submission process fy10 113
    Submission Process-FY10/11 Report Training

    The assigned Regional Lead will submit to OCYF electronically.

    Subject Line-Legal Entity/Parent Org Name-“FY” Fiscal year-“FINAL for QA”…

    (i.e. RMA Organization-FY10-11 FINAL for QA).

    The file naming conventions will remain the same

    17

    17


    Who is my assigned regional lead
    Who is my assigned Regional Lead? Report Training

    Southeast Region

    Jim Murphy-Delaware County

    Central Region

    Bill Kasper-Dauphin County

    Northeast Region

    Sonia Love-Monroe County

    Northwest Region

    Diane Cottrell-Erie County

    Southwest Region

    Richard Deland-Allegheny County


    Review team lead responsibilities
    Review Team Lead Responsibilities Report Training

    Point of Contact for the County Review teams and Out of Home placement service providers.

    Making initial contact identifying review counties and requesting other documents.

    Coordinate review process with participating counties.

    Track progress-Keeping regional lead informed.

    Follow up with provider for additional requests.

    Document comments in Workbook (insert tab in workbook).

    Finalize the documentation for OCYF review and positing.

    19

    19


    County review team will review for
    County Review Team will Report Trainingreview for:

    Allowable State Act 148 Costs

    Allowable Federal Title IV-E Costs

    Costs are Ordinary, Necessary and Justifiable that benefit the operations and delivery of service

    Distribution of costs are Fair and Equitable

    20

    20


    Allowable costs
    Allowable Costs Report Training

    Ordinary, Necessary and Justifiable for the operations of the program

    Service qualifies as an Allowable Service

    Each line item expenditure is allowable by regulations

    21

    21


    Fair and equitable
    Fair and Equitable Report Training

    Distribution of apportioned costs

    Indirect Administrative Cost

    In accordance with relative actual benefits accruing to the program

    All activities including unallowable activities and services share in the indirect costs

    22

    22


    State allowable expenditures
    State Allowable Expenditures Report Training

    Title 55 Chapters 3170 and 3140.

    Allowable Costs and Procedures…

    Applicable to county Children and Youth Agencies in the Commonwealth and Providers of Service to the county agencies

    Includes expenses which the Department considers allowable and reimbursable. If the expenses are not included, they will not be eligible for Department financial participation

    Department and county will share the cost of providing services to the child, to the extent that the cost is not borne by the Federal Government, private person or agency

    23

    23


    Title iv e allowable expenditures
    Title IV-E Allowable Expenditures Report Training

    Title IV Part E of the Social Security Act

    http://www.socialsecurity.gov/OP_Home/ssact/ssact-toc.htm

    Title IV Part E of the Child Welfare Policy Manual

    http://www.acf.hhs.gov/j2ee/programs/cb/laws_policies/laws/cwpm/index.jsp

    Guide for allowable costs

    Foster Care Maintenance

    Foster Care Administrative

    24

    24



    Omb circular a 87 definitions
    OMB Circular A-87 Definitions Report Training

    • F. Indirect Costs1. General. Indirect costs are those: (a) incurred for a common or joint purpose benefiting more than one cost objective, and (b) not readily assignable to the cost objectives specifically benefited, without effort disproportionate to the results achieved.


    Indirect administrative forms

    Appendix A Report Training

    V. Indirect Admin Roster

    VI. Indirect Admin Expenses

    VII. Cost Allocation Plan

    VIII. Master Program List

    Appendix B

    IV. Indirect Admin Roster

    V. Indirect Admin Expenses

    VI. Cost Allocation Plan

    VII. Master Program List

    Indirect Administrative Forms


    When completing more than one packet per provider
    When Completing more than one packet per Provider… Report Training

    The Indirect Forms Must Be Identical In Each Packet


    Errors from last year
    Errors from last year… Report Training

    • Filling out the Title IV-E Columns for the packet specific amounts

      • The Indirect Administrative Expenses should be evaluated independently.

      • The Program specific Title IV-E Percentage is applied on different forms depending on the Appendix. (Program specific found on Direct Admin or Instit Fac. Expend page)


    Errors from last year1
    Errors from last year... Report Training

    • Attempting to match the Title IV-E Amounts on the Indirect Admin. Exp. Form and Master Program List

      • We do not consider the Master Program List until we complete the Indirect Administrative Expense form.

      • The Title IV-E Amounts that are unallowable due to Setting are determined on the Master Program List


    Example exercise
    Example Exercise Report Training

    • Completed Correctly but missing one piece…

    • Two-Level Indirect Admin. Provider




    Master program list
    Master Program List Report Training


    Master program list distribution
    Master Program List Report TrainingDistribution




    Combining the layers
    Combining the Layers Report Training

    • Master Program List – This was the share identified in the first Master Program List which is added into the Indirect Admin Expense (2) form under [Other]


    Master program list 2
    Master Program List (2) Report Training


    Master program list distribution1
    Master Program List Report TrainingDistribution


    What is missing
    What is missing?? Report Training


    Cost allocation plan cap
    Cost Allocation Plan (CAP) Report Training

    • Vital part of the Indirect Admin. Package

    • Has more information than just how the indirect administrative expenses are allocated.

    • We will cover this later in training once we have learned about all the elements related to Maintenance and Administrative Expenses…


    Core concepts

    Core Concepts Report Training

    Maintenance vs. Administrative


    Maintenance vs administration
    Maintenance vs. Administration Report Training

    • Foster Care Maintenance

      • Social Security Act - Title IV - Part E

        • Definitions – (4) Foster Care Maintenance payments

    • Foster Care Administrative Activities

      • Code of Federal Regulations

        • Allowable Administrative Costs


    Structure of a foster family per diem
    Structure of a Report TrainingFoster Family Per Diem


    Foster family home maintenance
    Foster Family Home Report TrainingMaintenance

    (4)(A) The term “foster care maintenance payments” means payments to cover the cost of (and the cost of providing) food, clothing, shelter, daily supervision, school supplies, a child's personal incidentals, liability insurance with respect to a child, and reasonable travel to the child's home for visitation. In the case of institutional care, such term shall include the reasonable costs of administration and operation of such institution as are necessarily required to provide the items described in the preceding sentence.


    Foster family home administrative payment
    Foster Family Home Report TrainingAdministrative Payment

    • “…costs for the administration of the Foster Care Program” Code of Federal Regulations Title 45 Section 1356.60

      ~ Examples ~

    • (i) Referral to services;

    • (ii) Preparation for and participation in judicial determinations;

    • (iii) Placement of the child;

    • (iv) Development of the case plan;

    • (v) Case reviews;

    • (vi) Case management and supervision;

    • (vii) Recruitment and licensing of foster homes and institutions;

    • (viii) Rate setting; and

    • (ix) A proportionate share of related agency overhead.

    • (x) Costs related to data collection and reporting.

    • (3) Allowable administrative costs do not include the costs of social services provided to the child, the child's family or foster family which provide counseling or treatment to ameliorate or remedy personal problems, behaviors or home conditions.


    Final Foster Family Home Per Diem Report Training

    XI. Foster Family Per Diem Calculation

    Administrative

    Payment

    Maintenance

    Payment

    X. Administrative Costs per child by Class of Service

    I. Current Foster Family Class of Service Description

    II. Local Service Provider Staff Roster

    IX. Service Projection Chart

    IV. Direct Administrative Expenses

    III. Local Service Provider by Job Classification

    V. Indirect Administrative Staff Roster

    VII. Cost Allocation Plan

    VI. Indirect Administrative Expense

    VIII. Master List of All Agency Programs


    Maintenance portion
    Maintenance Portion Report Training

    • We only have to identify Maintenance costs specifically for Appendix A – FFH

      • All of Appendix B is Maintenance (See In case of Institutional care, …)

    • Only one form

      • Current Foster Family Service Descriptions



    Example exercise1
    Example Exercise Report Training

    • Maintenance Form Only

    • This form would not be approved as is…can you explain why?

    • Incidentals Not Included in the Foster Family Per Diem – Still need to review


    Common errors
    Common Errors Report Training

    • ERROR  Transportation to Counseling/Medical Appointments on this form.

      • This is an Administrative Expense as per Child Welfare Policy Manual 8.1B (28)

        28. Question: May a State claim the costs of a worker, a foster parent, or a volunteer transporting a child or his or her family to various appointments, such as medical or counseling, or to court hearings and case reviews as a title IV-E administrative cost?

        Answer: Yes, these transportation costs, regardless of who provides them, could reasonably be considered related to case management activities and necessary for the proper and efficient administration of the title IV-E State plan and therefore an allowable administrative cost under 45 CFR 1356.60(c). Any such costs must be allocated through an approved cost allocation plan and the claims must be on behalf of a title IV-E eligible child or candidate for title IV-E foster care.

        Source/Date: 01/09/09

        Legal and Related References: 45 CFR 1356.60(c)


    Common errors1
    Common Errors Report Training

    • ERROR  Child’s Personal Incidentals listed on the Direct Admin. Exp. Form

    • Child’s Personal Incidentals are Maintenance Expense ONLY.


    Cover sheet foster family homes appendix a
    Cover Sheet- Foster Family Homes Report TrainingAppendix A

    54


    Cover sheet
    Cover Sheet Report Training

    Purpose of this form is to.

    To provide the identifying information for the Provider and the packet being completed

    When Completing This Sheet:

    • Complete all fields listed on sheet. If a field does not apply, insert N/A in that field.

    • Information at the top of each sheet should automatically populate on the top portion of subsequent sheets

    55


    Cover sheet1
    Cover Sheet Report Training

    • If completing the contract documentation packet for multiple certificate of compliance numbers who have the same per diem rate and same service rate, please complete the bottom of the coversheet.

    Note: When completing this packet for multiple foster family providers, compile all expenses and report the overall total for each area of the forms.  The singular packet will display all expenses for all included certificate of compliance numbers as well as the total days of care for all included certificate of compliance numbers.

    56


    Summary rate sheet
    Summary Rate Sheet Report Training

    57


    Summary rate sheet1
    Summary Rate Sheet Report Training

    Purpose of this form is to.

    Reflect the Total and Title IV-E per diem requests ALL Child Welfare Services within an agency.

    When completing this sheet:

    Provider’s Requested per diems and Requested Title IV-E per diems are reported on this form.

    If there is no Unit ID or Title IV-E rate then put N/A

    58


    Summary rate sheet2
    Summary Rate Sheet Report Training

    Difference Between Calculated, Contracted and Requested Per Diems

    Calculated: Determined after Provider has reported all expenses then divided those expenses per applicable methodology

    Contracted: Contractual Agreement between County and Provider determines this rate

    Requested: The rate the Provider is Requesting prior to contracting with a County

    59



    Local service provider staff roster1
    Local Service Provider Staff Report TrainingRoster

    The purpose of the form is:

    • Identify the baseline salary costs for staff that work at the program level.

    • Know what type of staff are working at the program level and understand the variety of job functions that they perform.

    Note: The individuals reported on this form are related to the Certificate(s) of compliance reported on the Cover Sheet.

    61


    Local service provider staff roster2
    Local Service Provider Staff Report TrainingRoster

    The form should be completed for Prior Year Actual Audited FY.

    If a new program, please complete the roster for the first year of operation.

    Over-time can be reported by showing the specific employee on two lines, accounting for the FTE associated with them and salary amount which is traditionally more than their baseline salary.

    Overtime cannot be grouped as a single line item

    62


    Local service provider staff roster3
    Local Service Provider Staff Report TrainingRoster

    • Position/Title – Increased Scrutiny, Job Descriptions needed.

    • Job Functions

      • Are the salaries listed in the job categories reflective of Position/Title?

      • Are salaries listed in more than one job category?

      • If so, Job Descriptions and Methodology of salary allocation to job category needed!


    Local service provider staff roster4
    Local Service Provider Staff Report TrainingRoster

    Are salary amounts in the correct job category?

    “Percentage Allocated to the Facility” match “Total Salary/Wage allocated to this Site”?

    64


    Local service provider staff roster5
    Local Service Provider Staff Report TrainingRoster

    Are there any Red error messages in the right hand column?

    The Error Message will appear when…….

    The salary amounts in each job category and/or Total Salary/Wage allocated to the facility does not match with the percentage that was placed in the “Allocation to the Facility” column.

    65



    Local service provider by job classification1
    Local Service Provider by Job Classification Report Training

    The purpose of this form is to:

    • Understand the number of staff (FTE) needed to run the program.

    • Understand how Title IV-E allowable amounts were developed for each job classification.

    • Understand how staff time is allocated to the program.

    • Projection of staff costs over a three year period.

    67


    Local service provider by job classification2
    Local Service Provider by Job Classification Report Training

    Job category salary/wage totals transferred over from the previous sheet?

    Review the job titles/positions under each job category. Look at the salary/wage costs and Title IV-E allowable amounts for each fiscal year.

    Are there any error messages?

    Do Clinical/Treatment employees have amounts in the Title IV-E Columns? (Unallowable for Title IV-E)

    68


    Local service provider by job classification3
    Local Service Provider by Job Classification Report Training

    FTE counts should accurately reflect the number of staff needed to run a program.

    (Example of FTE counts are in 3170-10-01 bulletin)

    Title IV-E allowable amounts for each job position/title corresponds with the allowable activity of the staff performing allowable duties.

    Job Descriptions/Time Study

    Each of the columns will automatically total at the bottom of the sheet.

    69


    Local service provider by job classification4
    Local Service Provider by Job Classification Report Training

    Narrative at the bottom of the page:

     Clear explanation of how staff time is allocated to each job category.

    Ex. Payroll tracks actual time spent working in the program.

     The explanation given for how the Title IV-E allowable amounts were calculated.

    Ex. Ratio of allowable to unallowable staff activities

    70


    Local service provider by job classification5
    Local Service Provider by Job Classification Report Training

    NEW-Official Use column

    • Reviewers can use the macro

      located above the final review columns.

    • This will transfer all the information from the Projected FY to the “official use” columns.

    • The reviewer can still manually change any line item if needed.



    Direct administrative expenditures1
    Direct Administrative Expenditures Report Training

    The purpose of this form is to:

    • Identify all expenditures for the program.

    • Understandthe expenditures for the program which encompasses three budget years.

    • Determine if line item expenses qualify for state and/or federal financial participation.

    73


    Direct administrative expenditures2
    Direct Administrative Expenditures Report Training

    Line items should be assessed for State and Federal allowability.

    Title IV-E allowable Employee Benefits and Staff Training line items reflect Title IV-E allowable staff/activities.

    Do the Facility and Operational expenses reflect allowable staff/activities?

    74


    Direct administrative expenditures3
    Direct Administrative Expenditures Report Training

    Any items listed under “Other- (please list)”:

     The line item must be clear and describe the expenditure so the items can be assessed for State and Federal financial participation.

    For Offsetting Revenue, please list any revenues that offsets the costs.

    Examples:

    Fundraising Medical Assistance

    Foundation endorsements Title 1

    Program Income Clothing reimbursement

    75


    Direct administrative expenditures4
    Direct Administrative Expenditures Report Training

    • Education and Mental Health/Mental Retardation Services are UNALLOWABLE for Federal and State Participation

      • Never list these expenses in the Title IV-E Column

      • If Specific Off-setting Revenue is not listed such as Title I or Medical Assistance, an Off-setting Revenue of “County Share of Education or MH/MR Services” must be listed.


    Direct administrative expenditures5
    Direct Administrative Expenditures Report Training

    • Title IV-E Allowable Percentage

      • Are there any Red error messages?

    • An error message in Red will appear in the Title IV-E allowable percentage field if Title IV-E costs reported on this sheet exceed the Total projected expenditures.

    77


    Practice exercise
    Practice Exercise Report Training

    There are some errors so pick out what you would question.

    In your group, discuss any errors that were made.

    78



    What do you need

    What Do You Need? Report Training

    What should the CAP contain in order to complete this package?


    What do you need1
    What Do You Need? Report Training

    • Allocation of Expenditures

      • Methodology + Example

    • Determination and Distribution of Title IV-E Expenses

      • Methodology + Example


    What do you need2
    What Do You Need? Report Training

    • Job Descriptions?

    • Time Studies?


    Service projection chart
    Service Projection Chart Report Training

    83


    Service projection chart1
    Service Projection Chart Report Training

    • Completed for all Three Fiscal Years

      • Monthly trend for each Class of Service for Fiscal Years:

        • Actual Audited Fiscal Year

        • Estimated Actual Fiscal Year

      • Project Budget Fiscal Year:

        • Total for the Class of Service for the year


    Service projection chart2
    Service Projection Chart Report Training

    • There should be one chart for each class of service

    • **During the Review Process, the Provider will project the Days of Care for FY 10/11

    • **During Contract Negotiation, County agencies and Providers can discuss the reasonableness of the projected Days of Care.


    Determining the ffh per diem

    Determining the FFH Per diem Report Training

    Combining the Maintenance and Administrative Per Diems to Create the Total and Title IV-E Per Diem


    Distributing total admin cost to classes

    Distributing Total Admin Cost to Classes Report Training

    Forms to Use:

    Direct Administrative

    Service Projection Chart

    CAP

    Admin Cost per Child



    Admin cost per child per class form1
    Admin Cost per Child per Class Form Report Training

    • Provider enters a Percentage on the Admin Cost Per Child form

    • The CAP must explain how the Percentage was determined


    Total administrative expense direct admin expense form
    Total Administrative Expense Report TrainingDirect Admin Expense Form

    • Carried over from the Master program list.

    • The Title IV-E Amount from the Master Program List is Multiplied by the Direct Admin Title IV-E Percentage


    Admin cost per child per class form2
    Admin Cost per Child per Class Form Report Training

    • Carried over from the Direct Admin Expend. Form

    • The form multiplies the Percentage by the Grand Total Administrative Expense.


    Admin cost per child per class form3
    Admin Cost per Child per Class Form Report Training

    From The Service Projection Chart


    Total admin distribution
    Total Admin Distribution Report Training

    • Provider enters a Percentage on the Admin Cost Per Child form

    • The Admin (Total and Title IV-E) portion of the Per diem is Calculated

    • The CAP must explain how the Percentage was determined



    Foster family reimbursements by class of service1
    Foster Family Reimbursements by Class of Service Report Training

    • We Combine the Maintenance and Administrative per Diems

    • The Official Use Column Percentages

      • Determines the Allowable Percentage for the Maintenance and Administrative portion of each per diem. (Invoicing)


    Congratulations
    Congratulations Report Training


    Questions

    QUESTIONS ?? Report Training

    Resource Account

    [email protected]


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