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FISCAL MONITORING. Gary Payne, CPA, CIA, CISA Unit Manager, Fiscal Monitoring Contract Oversight & Support Section. FISCAL MONITORING October 13, 2009. WHY? WHAT IS IT? WHY SHOULD I CARE?. WHY FISCAL MONITORING?. Ensure Accountability of Taxpayer Funds Disbursed.

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FISCAL MONITORING

Gary Payne, CPA, CIA, CISAUnit Manager, Fiscal MonitoringContract Oversight & Support Section


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FISCAL MONITORINGOctober 13, 2009

WHY?

WHAT IS IT?

WHY SHOULD I CARE?


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WHY FISCAL MONITORING?

  • Ensure Accountability of Taxpayer Funds Disbursed.

It’s required by OMB Circular A-133 [Federal Funds] & Uniform Grant Management Standards (UGMS) [State Funds] to:



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WHAT IS FISCAL MONITORING?

  • Single Audits

  • Review, Monitoring, & Follow-up on Single Audit Findings by HHSC OIG & DSHS

  • Performing On-site & Desk Reviews of Subrecipient Contractors by DSHS Personnel

  • Adequacy of monitoring sub-contracts executed by DSHS contractors by the DSHS contractor (i.e. You have to monitor your sub-contractor’s performance/compliance).


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WHAT’S THE BIG DIFFERENCE BETWEEN SINGLE AUDITS & FISCAL MONITORING?

  • There is overlap. A Single Audit’s scope is on the entity’s total Federal or State Awards.

  • A DSHS Fiscal Review’s scope is more focused. It is targeted on ascertaining contractual compliance with DSHS contract requirements.

THEY SEEM REDUNDANT!


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“OK, drill down to what DSHS tests & evaluates?” MONITORING?

  • It can include any contract requirements included in a DSHS contract.


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“Uhm, this covers a lot of ground. MONITORING?DSHS contracts are pretty voluminous.”

  • Governance (re: The Enron & “Bernie” Slide)

  • Allowability of Expenditures

  • Period of Availability

  • Cost Allocation Plans

  • Matching & Program Income

  • Other

“Could you give me the Cliff Notes version?”


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GOVERNANCE MONITORING?

  • Defined by OMB Circulars, UGMS & Federal Agency Common Rule

  • Defined by DSHS Contract Requirements

  • Defined by Texas Administrative Code (Community Centers)


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ALLOWABILITY OF EXPENDITURES MONITORING?

  • Defined by applicable OMB Circulars & UGMS

  • Defined by grant specific terms (i.e. review the DSHS contract for specific requirements, some grants have specific prohibitions for certain expenditures that would be allowable under most other grants).


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PERIOD OF AVAILABILITY MONITORING?

Defined by OMB Circulars, UGMS & Federal Agency

Common Rule

It means that transactions must occur within the contract

term. This applies to revenue, expenditures, program

income, and matching costs.


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COST ALLOCATION PLANS (CAPS) MONITORING?

  • Has a compliant CAP been submitted?

  • Did the entity follow the CAP?

Defined by OMB Circulars, UGMS & Federal Agency Common Rule

It means that transactions must occur within the contract

term. This applies to revenue, expenditures, program

income, and matching costs. Discussion of CAPS in detail, is beyond the time limits of this presentation, but can be categorized into the two following aspects:


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MATCHING MONITORING?

Common exceptions include:

  • Inadequately documented match (particularly in-kind)

  • Counting other grant expenditures as match for DSHS grants

  • Match claimed occurred outside contract terms.

Matching requirements are defined in DSHS contracts.


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PROGRAM INCOME MONITORING?

  • Inadequately documented program income

  • Incorrect allocation of program income

Program Income is defined in OMB Circulars, UGMS & Federal Agency Common Rule. Review the DSHS Contract for specific requirements.

Common exceptions include:


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OTHER MONITORING?

Waste, Fraud, & Abuse = Referral to HHSC Office of Inspector General for Investigation


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“Hey, That’s Scary Stuff! We Don’t Want to Go There!”

  • Board Governance is providing appropriate oversight of management.

  • Management operates with appropriate checks & balances (i.e. internal controls).

But it’s the law. The best means of preventing entering this arena, is to ensure:


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“Yeah, but how? We’re small and mainly staffed by lay people and volunteers - not attorneys & CPAs!”

Contract with professional staff (attorneys, CPAs, etc.) for appropriate expertise, DSHS contracts generally allow administrative costs to cover such needs.


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TECHNICAL ASSISTANCE SECTION people and volunteers - not attorneys & CPAs!”

DSHS has a Technical Assistance Section to advise and help DSHS contractors.

For assistance you should contact:

Robert Vitek, Manager

Financial Technical Assistance Unit

Contract Oversight & Support

888.963.7111 x2326 (toll free)

512.458.7111 x2326 (direct)

[email protected]


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ABOUT DSHS TECHNICAL ASSISTANCE people and volunteers - not attorneys & CPAs!”

The DSHS Technical Assistance Unit is designed to assist DSHS contractors with current questions or problems in a prospective manner.

DSHS contractors should be aware that DSHS Technical Assistance cannot resolve single audit findings or DSHS Program or Fiscal review findings. This function represents an “ounce of prevention, not a pound of cure.”


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“My board is great but the guy sitting next to me could use some help in this area!”

“Okay, How about Board Governance?”


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BOARD RESPONSIBILITIES use some help in this area!”

  • Brief Board members of these requirements prior to executing DSHS contracts

  • Review websites referenced on the following slide

Members of Board have specific legal responsibilities pursuant to State laws and DSHS contract requirements.

Management & Board legal counsel should:


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WEBSITES FOR NON-PROFIT BOARD GOVERNANCE - BEST PRACTICES use some help in this area!”

www.wcnwebsite.org/practices/board.htm

www.navref.org/bestpractices/gov_bod_intro.htm

www.aicpa.org/download/training-bod.pdf

www.directorsforum.org/resources/cg_documents/cgnews_bestpractices.php

www.npgoodpractice.org/Glossary/Default.aspx?index=B


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QUESTIONS AND ANSWERS use some help in this area!”


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