National Monitoring Standards 2013 CDR Matthew Newland Public Health Analyst Department of Health and Human Services Health Resources and Services Administration HIV/AIDS Bureau Division of Metropolitan HIV/AIDS Programs

Session Overview Purpose of National Monitoring Standards HRSA/HAB Expectations Monitoring Standards Implementation Updates to Standards Resources

Purpose of National Monitoring Standards (NMS) Provide a compilation of all major Ryan White Program documents used for COMPLIANCE, OVERSIGHT, and EXPECTATIONS Assist grantees in meeting Federal requirements for program and fiscal management, monitoring, and reporting Help standardize project officer monitoring of grantees Clarify the oversight expectation of Ryan White Part A Program Assist/guide grantees in compliance to monitoring expectation Identify specific roles regarding monitoring of sub-grantees

Purpose of NMS Compliance, Oversight, and Expectations Ryan White Legislation Code of Federal Regulations HHS Grants Policy Manual HRSA/HAB Policies Part A Funding Opportunity Announcement Part A Manual (clarification, best practice) Program Terms and Conditions of Award OIG/GAO Reports and Recommendations

National Monitoring Standards NMS  Developed in response to OIG, Congress, and GAO oversight issues  Published April 2011  Revised May 2013 Three Components to the NMS  Universal Monitoring Standards (18 pages)  Fiscal Monitoring Standards (43 pages)  Program Monitoring Standards (78 pages) Monitoring Standards: FAQs (19 pages)

Why Do We Need National Monitoring Standards? Contract Monitoring Fiscal Monitoring – a system to assess the appropriate use of funds including the control, disbursement, use, and reporting of allowable costs Program Monitoring – a system to assess whether allowable services are provided to eligible clients according to service limits Quality Management – a system to assess the degree to which a service meets or exceeds established professional standards and user expectations

HRSA/HAB Expectations Any agency or individual receiving Federal funding is required to be monitored for compliance with federal and programmatic requirements Grantees must perform fiscal monitoring activities to ensure Ryan White funding is being used for approved purposes Grantees are required to conduct “comprehensive” annual monitoring site visits to all sub-grantees, unless an exemption has been granted by HAB/DMHAP

NMS-OIG Recommendations Specify and enforce standards and guidelines for how grantees should monitor grantees Standardize a corrective action process and address grantee issues more formally Increase the frequency and comprehensiveness of site visits

NMS Implementation Grantee Responsibilities: Conduct annual visit Develop its own Monitoring Standards Ensure compliance with all the National Monitoring Standards Make National Monitoring Standards available to sub- grantees and document monitoring activities Keep POs informed about its monitoring activities

Monitoring Standard Elements Each Monitoring Standard has four elements: Performance Measure/Method Grantee Responsibility Provider/Sub-grantee Responsibility Source Citation

Example of a Part A Fiscal Monitoring Standard Standard Performance Measure/ Method Grantee Responsibility Provider/Subgrantee Responsibility Source Citation Section A: Limitation on Uses of Part A funding 1.Adherence to 10 percent limit on proportion of federal funds spent on administrative costs in any given grant year  For grantees without a fiduciary intermediary or administrative agent  Identification and description of all expenses within grantee budget that are categorized as administrative costs  Documentation that administrative expenses do not exceed 10 percent of the awarded Ryan White grant  Identify and appropriately categorize administrative expenses and ensure that they do not exceed 10 percent of total grant  Provide HRSA/HAB with current operating budgets with sufficient detail to determine and review administrative expenses N/A PHS ACT 2612 A 2604(h)(1)

Universal Monitoring Standards Section A: Access to Care Section B: Eligibility Determination Section C: Anti-Kickback Statute Section D: Grantee Accountability Section E: Reporting Section F: Monitoring Appendix 1 – Report Due Dates

Universal Standards - Updates ItemLocationChange TypeSource/Purpose Section B: 1.Eligibility Determination ClarificationPCN #13-02 Client Eligibility and Recertification Requirements Section D: 1.Grantee Accountability New CitationsSteven Young and Heather Hauck Letter 09/20/2012 “Exemption to Annual Site Visits” Section E: 2.ReportingLanguage added under Grantee Responsibility; New Citations FFATA Reporting Section F: 2.MonitoringStandard updated; New Citation “Note” added on Annual Site Visit Exemption; SY and HH Letter 09/20/12 Appendix 1Report Due Dates UpdatedAdded “Estimated UOB and Carryover” due date

Part A Fiscal Monitoring Standards Section A: Limitation on Uses of Part A Funding Section B: Unallowable Costs Section C: Income from Fees for Services Performed Section D: Imposition and Assessment of Client Charges Section E: Financial Management Section F: Property Standards Section G: Cost Principles Section H: Auditing Requirements Section I: Matching of Cost-Sharing Funds Section J: Maintenance of Effort Section K: Fiscal Procedures Section L: Unobligated Balances

Part A “Fiscal” Monitoring Standards - Updates ItemLocationChange TypeSource/Purpose Section A: 4, 5, 6, 8 Limitation on Uses of Part A Funding Clarification (6, 8); New Citations (4, 5, 6, 8) Item 6. “Note” added under Standard - website for obtaining Indirect Cost Rate; Citations: H. Philips & S. Young Letter “Administrative Costs & Rent”; FOA – “Indirect Cost Rate”; HAB PN – “Waiver of Core Medical Services Requirements” Section B: 7, 9 Unallowable Costs Language addedPerformance Measure/ Method - Item 7 new bullet on document review for outreach; Item 9 new bullet on document review for foreign travel

Part A “Fiscal” Monitoring Standards - Updates ItemLocationChange TypeSource/Purpose Section D:Imposition & Assessment of Client Charges Terminology Updated Schedule of Charges (previously sliding fee scale) Section E: 3, 4, 5, 6 Financial Management Language added; reformat Revisions to approved budgets Section H: 2Auditing Requirements New StandardSmall Program Audits; S. Young & H. Hauck Letter 09/20/12 Section K: 10Fiscal Procedures Language added to Grantee Responsibility Estimation of carryover request Section L: 1Unobligated Balances Language update; new Citation Submission of UOB; HAB PN “UOB and Carryover Provisions”

Part A Program Monitoring Standards Section A: Allowable Uses of Part A Service Funds Section B: Core Medical Services Section C: Support Services Section D: Quality Management Section E: Administration Section F: Other Service Requirements Section G: Prohibitions and Additional Requirements Section H: Chief Elected Official (CEO) Agreements and Assurances Section I: Minority AIDS Initiative

Part A “Program” Monitoring Standards Updates ItemLocationChange TypeSource/Purpose Section B: 3Core Medical Services Language updated LPAP eligibility, advisory board, 340B compliance Section C: 7, 10 Support ServicesLanguage updated and clarified Housing services; Medical transportation – clarified need for prior approval when purchasing or leasing vehicle Section F: 2Other Service Requirements Language updated “Referral relationships with key points of entry” Section G: 5, 9 Prohibitions on Promotion Language updated and added Direct Cash Payments; two items added to Additional Prohibitions

Part A “Program” Monitoring Standards Updates ItemLocationChange TypeSource/Purpose Section H: 3a, 3f, 5a CEO Agreement & Assurances Language updated - 3a & 3f; Language deleted with referral to Fiscal Monitoring Standards – 5a 3a-Obligation and expenditure of funds; 3f-Medicaid status; 5a- Imposition of charges for services Section J: 1cData Reporting Requirements Language addedGrantees ensure providers are entering client- level data

Monitoring Standards: FAQs FAQs are divided into seven sections:  National Monitoring Standards (NMS) Basics  Structure of the NMS Documents  Implementation of the NMS  Universal Monitoring Standards Questions  Program Monitoring Standards Questions  Fiscal Monitoring Standards Questions  Appendix 1

FAQ - Updates FAQ #SectionChange TypeSource/Purpose #9Structure of NMSDeleted#9 from FY12 no longer relevant #23Implementation of NMS Updated (replaces #24 & #25) Annual site visit exemption #24Implementation of NMS Updated (Previously #26) Desk audits may substitute for site visit with approved exemption #34Universal MSNewPCN #13-02 Client Eligibility & Recertification Requirements #42Universal MSNewUnderinsured qualify for RW services

FAQ - Updates FAQ #SectionChange TypeSource/Purpose #43Universal MSUpdatedClarifies eligibility for insurance and RW #53Fiscal MSClarificationClarifies use of RW funds for QM #54Fiscal MSClarificationIndirect cost rates #55Fiscal MSClarificationIndirect cost rate documentation requirements for grantee/subgrantees #56Fiscal MSUpdatedIncludes “exceptions” for rent as allowable direct service cost #57Fiscal MSUpdatedIncludes language on auditing of high-risk programs

FAQ - Updates FAQ #SectionChange TypeSource/Purpose #58Fiscal MSNewSmall program audits; S. Young & H. Hauck Letter 09/20/12 #61Fiscal MSClarificationSchedule of charges and limit on client charges #66Fiscal MSNewSchedule of charges discounts based on individual income #68Fiscal MSClarificationReimbursement is a form of program income #70Fiscal MSClarificationEstablishing MOE #71Fiscal MSUpdatedContains new web link for sample monitoring tools Appendix 1UpdatedWebsite links updated

Resources Part A and B Monitoring Tool: monitoring (click the “Grantee” tab at the top of the page)

Contact Information CDR Matthew Newland Public Health Analyst (301)