FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training Part 8: Quality & Performance Controls; State Monitoring & Auditing; Grant Contract

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Intro. to Monitoring & Auditing 2

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Monitoring, Auditing & Oversight One comprehensive system- its all about the money  HHS monitoring  OLA Auditing DOC  EAP Auditing SP  PARs  On-site visits  Desk monitoring

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Monitoring, Auditing & Oversight National, State and Local efforts  Federal level  Increased funds staffing, monitoring, training, oversight  State level  Increased scrutiny, systems, controls, requirements  Local level  Self monitoring, risk assessment, oversight

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Monitoring, Auditing & Oversight All of us  Play a role  Are responsible  Need to get better at these activities

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Monitoring, Auditing & Oversight It’s about the money because...  Need to understand that is as important as providing the service to the household  If the program does not have integrity it can’t be here to help those who need it  It’s about the households

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Monitoring and Q&PC  Sandra Seemann 7

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Quality & Performance Control  Periodic review of program data helps ensure compliance with policies, timely service, program integrity  Some reports help mitigate risk (e.g. of inaccurate benefit)  Duplicate vendor accounts and addresses  Electric mismatch  ERR outliers  Other reports ensure quality, timely service  Aging applications  Aging Crisis payments  Aging PH payments  Unprocessed refunds 8

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Dup Vendor & Address Checks Checking for duplicate vendor accounts and addresses is a key risk mitigation activity  Program integrity and audit-ability  Address problems early before they become critical (i.e. catch duplicate vendor account before double payment goes to a HHD)  Dup checks aren’t busy work – we catch stuff  SPs must continue to be responsive to dup checks  OLA examines our records for dups 9

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Dup Vendor & Address Checks Provide good responses to dup checks  Give enough info so it’s known what happened & that correct benefit was determined or necessary corrections made  Examples: 10

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Electric Mismatch  This shows mismatches between the info in eHEAT and consumption for the HHD  SPs can and should run this themselves (in eHEAT Advanced Search)  DOC also runs these 11

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 ERR Outliers  ERR is the largest benefit and thus biggest risk  Outside of central payment process  Checking for ERR outliers helps find ERR projects that may be outside program rules 12

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 Aging Apps, Crisis & PH Payments  Important to ensure timely service to HHDs  SPs can and should check for aging apps and payments on a regular basis  DOC also runs these to notify SP when they have aging apps or payments they may have overlooked 13

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring 14

FFY2014 EAP Annual Training August 20 & 21, 2013 Training Topics   Types of on-site monitoring   De-mystifying file review   Purpose of findings & recommendations   Questions State Monitoring 15

FFY2014 EAP Annual Training August 20 & 21, Intentions   Conduct oversight to reduce risks to the program, service providers and households   Evaluate SP’s competency for delivering EAP   Ensure program integrity State Monitoring

FFY2014 EAP Annual Training August 20 & 21, On-site visits   DOC conducts two types of on-site visits   Initial Program Assessment Visit (iPAV)   Full Program Audit Visit (fPAV) State Monitoring

FFY2014 EAP Annual Training August 20 & 21, 2013 Initial Program Assessment Visit (iPAV) Focus   Review findings and recommendations from previous year(s)   Review Local Plan – discuss DOC questions and SP changes   Ensure SP has necessary resources and is ready for FFY14   File review   Provide Training and Technical Assistance (T&TA) Prior to visit   Send T&TA requests to your Program Performance Auditor   Do not save questions for the visit, send immediately to your PPA or eap.mail State Monitoring 18

FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring Full Program Audit Visit (fPAV) Focus   In-depth review of SP’s program implementation   Review of Primary Heat, Crisis and ERR files   Review payroll records   Inventory   Additional documents as requested Prior to visit   Full Program Audit Tool (fPAT)   Send T&TA requests to your Program Performance Auditor   Do not save questions for the visit, send immediately to your PPA or eap.mail 19

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  PH – 30 files, plus:  5 Self employment  5 No income  5 Denied  All consumption > $5,000  Crisis – 30 files  ERR – 5 files, plus  All tasks > $5,000 20

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – Why so many files?  Statistical significance  Each SP has a “population” of files  We can’t review all of them  By reviewing a random sample of the whole population, we can get a relatively good representation of the whole  Even 30 files out of is not entirely representative 21

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – Why so many files?  Enables DOC to more accurately know the true nature of any identified issue  For example:  We review 5 files, and 2 have an issue (40%)  Do 40% of all the SP’s files have the same issue? We can’t say…  We review 30 files, and 2 have an issue (~7%)  In this case, we can be more certain that it’s not a systemic issue  We review 30 files, but 12 have an issue (40%)  In this case, we would be more certain that SPs files may actually have an systemic issue 22

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  PH – Application Processing  Applications are dated and signed by applicant  Applications are date stamped and logged the day they arrive  Income statements for all HH members are complete & well documented  Accurate income calculation of the EAP household  Complete documentation verification case notes (Who, When, What) in paper file or in eHEAT  Copies of any correspondence with the applicant, if applicable  Documentation of research done in response to a question, complaint, or appeal, if applicable  Delivery of timely program services  Maintain proper EAP data security practices 23

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  PH – Eligibility Determination  Household member info  Household income documentation & calculation  Housing type and status (e.g., subsidized, heat in rent)  PH – Benefit Amount Determination  All of the above, plus: –Fuel type –Home heating system status (e.g., dual fuel) –Consumption 24

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  Crisis – Eligibility Determination  HH’s past due bills in file or documentation of emergency  Documentation of energy vendor verification  Available PH payments did not resolve the emergency. Check if PH payments were made payable after Crisis benefit determined  SP - HH correspondence notes in file or eHEAT  Check that eHEAT Crisis reason matches documented rationale  Are SPs doing reasonability checks for delivered fuel? 25

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  Crisis – SP Response  For HH in a life-threatening situation the LIHEAP law requires that the threat to life be removed within 18 hours of a household requesting crisis  No heat in the house  No heat distribution  For HHs experiencing immediate energy emergencies that are not life threatening SPs must approve crisis services within 48 hours  Compare crisis reported date to completion/approval/ payment date 26

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  Crisis – Benefit Amount Determination  Compare the crisis amount with the vendor verification documentation and PH benefit amount  Is the SP properly using the Crisis amount and fees boxes in eHEAT? 27

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  ERR – Eligibility  Documentation of proof of ownership (if required) must be in paper file or eHEAT.  Documentation of a qualified dwelling.  Documentation of valid request for repair or replacement, including description of the problem.  Documentation of eligible heating system (e.g., not redundant).  Determine if ERR-related application information matches eHEAT information.  Verify that changes to application are documented. 28

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  ERR – SP Response  For HH in a life-threatening situation the LIHEAP law requires that the threat to life be removed within 18 hours of a household requesting crisis  No heat in the house  No heat distribution  For HHs experiencing immediate energy emergencies that are not life threatening SPs must approve crisis services within 48 hrs  Compare ERR reported date to completion/approval/payment date  Documentation that temporary heat was provided appropriately, if applicable 29

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  ERR – Benefit Amount Determination  Documentation of the contractor's determination of need for response to the ERR request (i.e., need for repair or replacement)  Documentation of "Manual J" calculations 30

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring File Sample Review – What do we look for?  ERR – Other  Inspection Certificate  50% of completed furnace replacements & retrofits inspected  Must be inspected prior to contractor payment  Completion Certificate  Required for all repairs & replacements > $1,000  Signed and dated by homeowner & contractor  Must include model and serial numbers  If inspected, inspector signature  Itemized Invoices 31

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 State Monitoring Findings & Recommendations  Meant to point out areas that should or must be improved  By identifying areas for improvement, we can take meaningful action  We want to ensure that we:  Deliver the highest quality of service to their communities  Comply with applicable laws  Not meant as punishment or to reprimand  Use the audit as a tool to improve services to HHs 32

FFY2014 EAP Annual Training August 20 & 21, Questions During the Program Year   DOC EAP staff are here to help you   Call or your Program Performance Auditor   Can also your questions to eap.mail   s with private household data must be sent via secure   Check with your IT staff about how to do this State Monitoring

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, 2013 EAP Grant Contract & Allocation of EAP Funds 34

FFY2014 EAP Annual Training August 20 & 21, 2013 Training Topics   EAP Contract   FFY 14 changes   Contract checklist   Contract timelines   Allocation of EAP funds   EAP Fund Line Items   EAP Fund Allocation Determination   Service Providers Obligation Authority EAP Grant Contract & Allocation

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, Intention:  Authorize grantees to provide program services  To ensure program changes to policy, law or other guidance are complied with by Service Providers By:  Meeting the requirements of state and federal program and contracting laws  Clearly detailing requirements for service providers delivering programs  Clearly detailing program service outcomes EAP Grant Contract

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY2014 EAP Annual Training August 20 & 21, Contract address three general areas  Grant administration  Fiscal management  Performance requirements EAP Grant Contract

FFY2014 EAP Annual Training August 20 & 21, 2013 FFY14 Contract Change Termination of contract by the Grantee (Page ):   Current: The Grantee may terminate this grant contract at any time, with or without cause, upon thirty days written notice to the State.   FFY14:The Grantee may terminate this grant contract at any time, with or without cause, upon sixty days written notice to the State.   Current: The Grantee must submit a final invoice to the State no later than thirty days after termination.   FFY14: The Grantee must submit a final invoice to the State no later than sixty days after termination. EAP Grant Contract

FFY2014 EAP Annual Training August 20 & 21, Grant Contract Timeline August 9, 2013, DOC sent FFY14 Contract to SPs for signatures   September 9, 2013 signed Contract submissions due by 4:00 pm.   By October 1, 2013 DOC executes and distributes contract documents with Local Plan EAP Grant Contract

FFY2014 EAP Annual Training August 20 & 21, Grant Contract Checklist State of Minnesota Encumbrance Worksheet FFY14 EAP Grant Contract Affirmative Action Certificate Certification Regarding Lobbying, Debarment … Current Certificate of Compliance from MN DHS. Conflict of Interest Policy Statement Exempts: County agencies, Reservations and Service Providers with less than 40 employees FFY2014 Local Plan (Separately) Supplements eHEAT Admin Security Agreement

FFY2014 EAP Annual Training August 20 & 21, Grant Contract Submission  Make sure signatories are available to sign the contract  Return the two contracts with:  Original signatures of the Chair of the Board of Directors or the authorized signatory.  Signature authority from Board of Directors must accompany the grant contract only if person signing the grant contract is not the Chair of the Board of Directors.  Signature of Certifications for Affirmative Action & Lobbyin g EAP Grant Contract

FFY2014 EAP Annual Training August 20 & 21, EAP Funds Allocation   Budgeting and allocation of EAP funds are among the key components of EAP fiscal management along EAP Fund Line items: Activities include :   Managing budget   Requesting funds   Spending funds in compliance with EAP Allocation of EAP Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 State level EAP Fund management activities   Maintain EAP budget for local allocations   Identify total amount of funds available for local allocations   Establish budget by LIHEAP line items   Establish budget to Service Providers (EAP Line items)   Enter budget limits into eHEAT   Monitor Budget   Update Budget as needed   Maintain eHEAT   Allocate obligational authority to local agencies Allocation of EAP Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 EAP Fund Line items   Administrative funds: Pay the cost of delivering the local EAP including staff salaries and associated allowable costs   A16 funds: Pay the cost of EAP outreach, referral and advocacy services. EAP Policy Manual describes allowable A16 activities   Primary Heat funds: Pay portion (%) of energy costs for eligible EAP households in residential dwellings   Emergency funds: Pay in addition to Primary Heat funds, for Crisis eligible households experiencing an energy emergency   ERR funds: Address mechanical heating system problems for eligible homeowners.

FFY2014 EAP Annual Training August 20 & 21, 2013 Funds distributed by DOC but approved by SPs   Primary Heat Funds (eHEAT)   Crisis Funds (eHEAT) Funds administered by Service Providers   Administrative Funds   A16 Funds   ERR Funds Allocation of EAP Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 Service Providers Obligation Authority   Know the amounts of their EAP fund allocations.   Request cash, as needed (the three-day-cash-on-hand rule applies).   Spend in compliance with LIHEAP policies & procedures   Report their expenditures. Allocation of EAP Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 Factors affecting allocation of EAP funds   Total amount of Federal fund allocated for the year   State level allocation percentage for each EAP fund line items (Based on LIHEAP Statue)   Service Provider’s number of processed applications from previous years   Service Provider’s amount of expenditures from previous years Allocation of EAP Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 EAP Fund Allocation Determination: Allocations for each EAP funding line items are established using a predetermined process: EAP fund categories FFY13 (%) Plan FFY13 ($) Plan Heating assistance 62.40% 69,888,000 Crisis assistance 7.60% 8,512,000 Energy Related Repair (ERR) 7.50% 8,400,000 EAPWX* 4.50% 5,040,000 Carryover from FFY % 3,360,000 Administrative 10.00% 11,200,000 Assurance % 5,600,000 Total % 112,000, Allocation MN State LIHEAP fund by each EAP category * The EAPWX* is 5% when admin funds are included

FFY2014 EAP Annual Training August 20 & 21, 2013 EAP Fund Allocation Determination (Cont..) 2. EAP Production: Line items with allocations determined by Previous years’ number of processed EAP applications, Crisis and ERR:   Administrative Funds   A16 Funds 3. EAP Expenditure: Line items with allocations determined current years’ EAP expenditure rate:   Emergency Funds   ERR Funds

FFY2014 EAP Annual Training August 20 & 21, 2013 Admin and A16 Allocation formula Uses the two previous years average of :   # of Approved Apps   # of Crisis Approved   # of ERR Approved   # of Others Apps including:   Total Denied   Insufficient Information   Invalid SSN   Over Income   Subsidized / Heat & Electric Included In Rent

FFY2014 EAP Annual Training August 20 & 21, 2013 ERR Allocation formula   DOC uses the last 5 previous years ERR expenditures (taking out the max and min expenditure years) Allocation of EAP Funds