Milwaukee County Department of Health & Human Services (DHHS) 2006 Purchase of Service Contracts Orientation Presented by: Dennis Buesing – DHHS Contract Administrator Rosemarie Forster – DHHS Contract Services Coordinator Diane Kaas – DHHS QA Coordinator Wes Albinger – DHHS Contract Services Coordinator
Overview of 2006 Purchase-Of-Services Contract & Changes Presented By: Dennis Buesing, DHHS Contract Administrator
Audit Requirements& Audit Review IssuesNew Audit Schedules and Changes in Allowable Costs (New Forms)2006 Purchase of Services Revenue & Expenses Report (New Forms)Budget & Other Final Submission Items New & Proposed Resolutions and Ordinances
Who Must Have an Audit? • Audits are required by State Statute if the care & service purchased with State funding exceeds $25,000 per year • Statutes require audits to be performed at least every other year. County contracts typically require annual audits • Standards for audits are found in DHFS/DWD/DOC Provider Agency Audit Guide, 1999 Revision (on line at www.dhfs.state.wi.us/grants) • Non-profit providers that receive $500,000 or more in federal awards must also have audit performed in accordance with OMB Circular A-133 Audit of State, Local Governments, and Non-Profit organizations. Federal audit requirements are for an annual audit.
Audit Waiver • Statutes allow the Dept. to waive audits. Audits may not be waived if the audit is a condition of state licensure, or is needed to claim federal funding (e.g. Group Foster Care or Child Caring Institutions). • Waiver request can be entertained only if agency does not need to have an audit according to Federal Audit requirement. • Waiver need to be approved on case to case basis by regional office based on the risk assessment ( Funding <$75,000 is considered low risk) • DHHS has been approving Audit Waivers for Fee for Service contracts mainly on basis of economic hardship • In case of small residential care providers ( Family group home and AFH) county has the authority to grant a waiver. • For POS Contracts, the DHHS is planning to approach County Board to make a Blanket Waiver request to state DOR for contracts up to $100,000.
Audit Review Issues • The County does not have to allow either a profit or reserves to providers who do not include a Schedule of Allowable Profits, or Reserve Supplemental Schedule with their audit. • Corrective action plan for all current-year audit findings related to County funded programs. • Management’s response to each audit comment and item identified in the Management Letter. • Allowable Cost Rules under rental agreements with Related Parties contain additional restrictions • Allowable rent expense under related party leases may not exceed the actual costs to the related party with whom title vests. (Generally, mortgage interest, real estate taxes, insurance, maint./utilities & depreciation)
Changes in Allowable Costs • The Annual audit report shall contain a budget variance and reimbursable cost calculation for each program contracted.(refer new format) • Costs allowable under State and Federal allowable cost guidelines that exceed the approved program budget by the greater of (1) 10% of the specific budget line item or (2) 3% of total budgeted costs are deemed unallowable. You can remedy this variance by submitting amended budget and having it approved by DHHS prior to end of contract year. (Refer to Section 4 Reporting Requirements Page 113 of Technical Requirement Booklet) • An annual audit report that omits information or doesn’t present line item information utilizing classifications as per Form 3 will place the Contractor out of compliance with the contract.
2006 Purchase of Service Revenue & Expenses Report • 2006 Purchase of Service Revenue & Expense Report has been revised. (New Forms) • No More Macros. No buttons to hide columns or see the summary and detail as in last year’s forms. • New Tabs added for uniformity and detail of items requiring further explanation: • Exp-Details TAB– to enter all the expenses; • Units TAB– to enter units and multiple rates within program; • Equipment TAB– to report all equipment over $500 purchased with county funds; and • Travel TAB– to report detail of employees’ travel expenses. • 2006 Professional Services Expense Report has been revised too. (New Forms)
Budget and Other Final Submission Items • Providers using Old Forms, or modifying current forms. • Providers using initial submission numbers for total DHHS request, vs. the numbers approved by County Board. This affects forms 1, 3, 3S, 4, 4S, 5, 5A and 6. • Providers reporting Milwaukee County’s share of the program only, versus the total program, typically on Forms 1 or 5. • Providers reporting only on programs applied for, versus all agency programs, Form 5. • Lack of Agreement between total clients to be served on the client characteristics chart and Form 1. • Not Properly filling up Form 5 ( Row 9200 Allocated Costs), and Form 6. • Omission of IRS form 990 (listed as requirement in Technical Requirements, but not listed as a specific item # on submission checklist, created some confusion).
New and Proposed Resolutions and Ordinances • Milwaukee County's Code of Ethics, Chapter 9 of Milwaukee County Code of General Ordinances “No person(s) with a personal financial interest in the approval or denial of a contract being considered by a County department or with an agency funded and regulated by a County department, may make a campaign contribution to any candidate for an elected County office that has final authority during its consideration. Contract considerations shall begin when a contract is submitted directly to a County department or to an agency until the contract has reached its final disposition, including adoption, county executive action, proceedings on veto (if necessary) or departmental approval. The language in Section 9.05(2)(l) shall be included in all Request For Proposal (RFP) and bid documents. ”
Resolutions (cont’d)…… • In a recent resolution Milwaukee County's Board proposed to repeal and recreate Chapter 13 of County Code of General Ordinance Guidelines on Best Governance Practices required of Non-profit Organization and amend Chapter 7 – Financial & Management Accounting of County Administrative Manual
Civil Rights Compliance PlanRequirements Presented by: Rosemarie Forster, DHHS Contract Services Coordinator
Civil Rights Compliance (CRC) ALL contracting agencies must submit a Civil Rights Compliance Plan or Letter of Assurance ensuring Civil Rights Compliance The Equal Employment Opportunity certificate is a separate requirement and does notqualify as a CRC document.
CRC (Cont’d)…….. • Agencies with 25 or more employees AND at least $25,000 awarded in contracts are required to submit a full CRC plan • Agencies with fewer than 25 employees OR less than $25,000 in contracts may opt to submit a Letter of Assurance instead, which includes AA, EO and LEP policies
CRC (Cont’d)…….. Agencies who subcontract are also required to ensure the subcontractor maintains CRC requirements
CRC (Cont’d)…….. • Completion forms, template, instructions, sample policies and plans are posted on the State website at: http://www.dwd.state.wi.us/dws/civil_rights/plans_instructions.htm • Sample Letter of Assurance is included as Attachment 6, page 56 of the template • Site includes LEP analysis of 13 counties, including Milwaukee
CRC (Cont’d)…….. • The agency must have access to data concerning employees and program participants to complete the plan • http://www.dwd.state.wi.us/oea/ • Site includes statistics on county workforce profiles
CRC (Cont’d)…….. • If your agency has not already submitted a LOA or CRCP, please submit the appropriate document to: Dennis Buesing DHHS Contract Administrator 1220 W. Vliet St., Suite 109 Milwaukee, WI 53205
Wisconsin Civil Rights Compliance Officer Questions may also be directed to: David Duran, CRC Officer PO Box 7850 One West Wilson Street, Room 561 Madison, WI 53707-7850 firstname.lastname@example.org Phone: (608) 266-9372 Fax: (608) 267-2147
Quality Assurance, Contract and Program Compliance Requirements Presented By: Diane Kaas, DHHS Quality Assurance Coordinator
Laws, Rules and Regulations: • Compliance with requirements related to applicable provisions of DHHS Purchase-Of-Service Contract and Policies and Procedures, as well as other applicable provisions of Federal, State, and County regulations. • Maintain in good standing all licenses, permits, certifications, and service provider’s credentials relating to the services provided.
Caregiver Background Checks • Agency must complete a State-wide criminal background check and meet requirements of Wisconsin Caregiver Law. • Obtain Federal/Other State’s criminal background check for caregivers not residing in Wisconsin during the 3 years preceding the date of search. • Repeat background checks every 4 years for ongoing Providers or at any time within that period when an agency has reason to believe a new background check should be obtained
General Record Keeping • Maintain records in secure and locked cabinets/rooms. • Individualized client files must include all appropriate assessments, service and treatment plans, case contact notes, and all other required documents. • Case records should be maintained until participant becomes 19 years of age or until 7 years after treatment or other services, whichever is later. • Must maintain such records and financial statements as required by Federal, State and County rules and regulations. • Retain all documentation necessary to adequately demonstrate the time, duration, location, scope, intervention and effectiveness of the services rendered.
Inspection of Premises and County site Audits • County Representative has the right to inspect at all reasonable times, case, medical, program,financial and such other records as may be required by applicable contract, rules and regulations. • County also reserve the right to review Board approved by-laws, minutes, policies and procedures, employee files and employment records, client attendance and case records, billing and accounting records, financial statements, certified audit reports.
Outcome Measurement Initiative Presented By: Wes Albinger, DHHS Contract Services Coordinator
Outcome Measurement Initiative • Objective is to measure benefits for participants during or after their involvement with a program, such as improvement in knowledge, skills, function, or status • Not to be confused with process, services, or output-number or volume of services delivered
Outcomes(Cont’d)…….. • In 2006, Contract Administration will be implementing four pilot programs in Outcome Measurement • For Fiscal Year 2007, Outcome Measurement will be included in the Purchase of Services Guidelines Technical Requirements (RFP)
Outcomes(Cont’d)…….. • Contract Administration will be gathering input from agencies through surveys and focus groups to better understand your agency’s practices, capabilities, and technical assistance needs with: • Program theory • Program outcomes, indicators, and measurement tools • Data collection and analysis • Research/Evidence based program design
Accounting Contact Info: Randy Iding (414) 289-6105Riding@milwcnty.com Paula Dills (414) 257-6465Pdills@milwcnty.com Robert Graveen (414) 257-6036Rgraveen@milwcnty.com
BHD Contact info: Paul Radomski(414) 257-7493Pradomski@milwcnty.com Walter Laux (414) email@example.com Chuck Sigurdson (414) 257-7361Csigurdson@milwcnty.com Rochelle Landingham (414) 257-7337Rlandingham@milwcnty.com
DCSD Contact Info: Eric Meaux (414) firstname.lastname@example.org Dave Emerson (414) email@example.com Jim Sponholz (414) firstname.lastname@example.org
DSD Contact Info: Charlotte Williams(414) 289-5898 Cwilliams@milwcnty.com Rosemarie Forster (414) 289-5896Rforster@milwcnty.com Wes Albinger (414) email@example.com Virgil Cameron (414) 289-5954Vcameron@milwcnty.com
ESD Contact info: Judy Roemer-Muniz (414) 289-6692Jromermuniz@milwcnty.com Jim Sponholz (414) firstname.lastname@example.org