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National Monitoring Standards 2013
CDR Matthew NewlandPublic Health Analyst
Department of Health and Human ServicesHealth Resources and Services
AdministrationHIV/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 NMSCompliance, 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 MonitoringFiscal 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 StandardStandard
Performance Measure/ Method
Grantee ResponsibilityProvider/Subgrantee
ResponsibilitySource
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
Item Location Change Type
Source/Purpose
Section B: 1.
Eligibility Determination
Clarification
PCN #13-02 Client Eligibility and Recertification Requirements
Section D: 1.
Grantee Accountability
New Citations
Steven Young and Heather Hauck Letter 09/20/2012 “Exemption to Annual Site Visits”
Section E: 2.
Reporting Language added under Grantee Responsibility;New Citations
FFATA Reporting
Section F: 2.
Monitoring Standard updated; New Citation
“Note” added on Annual Site Visit Exemption; SY and HH Letter 09/20/12
Appendix 1 Report Due Dates
Updated Added “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
Item Location Change Type Source/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 08-02 – “Waiver of Core Medical Services Requirements”
Section B: 7, 9
Unallowable Costs
Language added
Performance 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 - UpdatesItem Location Change Type Source/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: 2 Auditing Requirements
New Standard Small Program Audits; S. Young & H. Hauck Letter 09/20/12
Section K: 10
Fiscal Procedures
Language added to Grantee Responsibility
Estimation of carryover request
Section L: 1 Unobligated Balances
Language update; new Citation
Submission of UOB; HAB PN 12-02 “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
Item Location Change Type Source/Purpose
Section B: 3
Core Medical Services
Language updated
LPAP eligibility, advisory board, 340B compliance
Section C: 7, 10
Support Services
Language updated and clarified
Housing services; Medical transportation – clarified need for prior approval when purchasing or leasing vehicle
Section F: 2
Other 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
Item Location Change Type Source/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: 1c Data Reporting Requirements
Language added Grantees 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 # Section Change Type Source/Purpose
#9 Structure of NMS Deleted #9 from FY12 no longer relevant
#23 Implementation of NMS
Updated (replaces #24 & #25)
Annual site visit exemption
#24 Implementation of NMS
Updated (Previously #26)
Desk audits may substitute for site visit with approved exemption
#34 Universal MS New PCN #13-02 Client Eligibility & Recertification Requirements
#42 Universal MS New Underinsured qualify for RW services
FAQ - Updates FAQ # Section Change Type Source/Purpose
#43 Universal MS Updated Clarifies eligibility for insurance and RW
#53 Fiscal MS Clarification Clarifies use of RW funds for QM
#54 Fiscal MS Clarification Indirect cost rates
#55 Fiscal MS Clarification Indirect cost rate documentation requirements for grantee/subgrantees
#56 Fiscal MS Updated Includes “exceptions” for rent as allowable direct service cost
#57 Fiscal MS Updated Includes language on auditing of high-risk programs
FAQ - Updates FAQ # Section Change Type Source/Purpose
#58 Fiscal MS New Small program audits; S. Young & H. Hauck Letter 09/20/12
#61 Fiscal MS Clarification Schedule of charges and limit on client charges
#66 Fiscal MS New Schedule of charges discounts based on individual income
#68 Fiscal MS Clarification Reimbursement is a form of program income
#70 Fiscal MS Clarification Establishing MOE
#71 Fiscal MS Updated Contains new web link for sample monitoring tools
Appendix 1 Updated Website links updated
Resources
Part A and B Monitoring Tool:
https://careacttarget.org/category/topics/program-monitoring
(click the “Grantee” tab at the top of the page)
