Conversations with the Division of Metropolitan HIV/AIDS Programs – “Fiscal Update” January 31, 2017

Webinar Description and Agenda This webinar will provide an overview and update on critical and emerging fiscal issues for Part A programs and include recipient presentations and interaction across Part A program staff to include:   •             Part A Administrative Updates •             Federal Financial Report (FFR) Submission Requirements •             Advance Payment •             Monitoring and Utilization of Program Income •             Differentiation of Clinical Quality Management and Administrative Costs

Part A Administrative Updates Part A Awards Comprehensive Site Visits Integrated Plan Reviews Special Projects Future Webinars Division of Metropolitan HIV/AIDS Programs (DMHAP) Strategic Planning

Division of Metropolitan HIV/AIDS Programs _____________________________________ Mission: Provide leadership that promotes access to and retention in high quality treatment and support services for people living with HIV in metropolitan areas DMHAP – Agent of Change and Innovation 1st year a Period of Coalescence; then: Change agent; Fostering innovation; Forward thinking; Analyze old & emerging issues w/ sensitivity to the needs of PLWH. DMHAP has & will continue to push the envelope 4

Part A FFR and Carryover Process FFR and Carryover Topics Understanding the FFR FFR Reconciliation Carryover review and approval

HRSA FFRs FFR Must be submitted annually through the Electronic Hand Book (EHB); due date aligned with Payment Management System (PMS) quarterly due date (currently July 30, 2017) Used to report on annual expenditures, annual unobligated balances (UOB) by funding source and Program Income The Reporting Requirements section of the Notice of Award (NoA) states specific due date – if when there is a change, Reporting Requirements section will be updated via a new NoA UOB Penalties - If unobligated balances of formula award exceed five percent, two penalties are imposed: 1. Future year award is reduced by amount of UOB less the amount of approved carryover; and 2. The grantee is not eligible for a future year supplemental award (see HAB PCN 12-02 for additional information) All Part A FFRs are considered final, and may not contain Unliquidated Obligations

Part A Final FFR

Part A – Award Totals by Source

This line cannot be used on the annual FFR Transaction Section 10d. – Populated from EHBs- this is the total authorized amount and includes any carryover funds This line cannot be used on the annual FFR

FFR – Program Income* *For additional information and clarification on what constitutes program income and how it should be used, please refer to HAB PCN #15-03

FFR UOB Breakout These amounts will auto- populate based on the awarded amounts reflected on the Notice(s) of Award (including carryover) The amounts in these 2 columns are based on the amounts reported by the recipient when the FFR is filled out, and the sum of which must match the total available UOB. These amounts are the unobligated balances of any funds previously carried over, and not the amount of funds the recipient plans to carry over!

FFR – Carryover Disposition This represents the total UOB from all sources, and may include some amounts that are not eligible for carryover

FFR – Remarks

Supporting Documents

Review FFR Review and Reconciliation The Grants Management Specialist (GMS) FFR review consists of determining the accuracy and completeness of reported information This is done through a comparison of awarded amounts, expenditures, and financial reconciliation Financial reconciliation is the comparison of the data reported on the FFR, the data reported to the PMS, and the amount of funds actually drawn from the account

Reconciliation PMS Report Total Amt Authorized Total Amt Expended Total Amount Drawn 14H89HA000XX 7,084,881.00 6,263,859.25 FY-CAN-CFDA   2012-3771205-4115 14,150.00 2012-3771206-4115 42,966.00 2012-3771207-4115 17,178.00 2013-3772044-4115 210,529.50 348,831.00 2013-3772045-4115 7,144.75 46,040.00 2014-3773024-4115 460,136.00 501,942.00 2014-3773025-4115 3,987,453.00 4,190,965.00 2014-3773026-4115 1,524,302.00 1,101,787.25

Part A Carryover Process Carryover Basics Carryover must be submitted within 30 days of submission of the FFR, but no later August 29th Request must include: Explanation of why the recipient was unable to expend the funds, as well as the source of the funds by service category Line item budget and budget narrative Explanation of how the fund will be used during current budget year Breakout of carryover request based on funding source* *Please note that supplemental funds are not eligible for carryover, and any UOB from this funding source will be used as an offset on the next available award

FFRs and Carryover Together Part A Carryover Process FFRs and Carryover Together Submission and acceptance of FFR Submission of Carryover Programmatic Review Division of Grants Management Office (DGMO) Review Issuance of NoA

Part A Carryover Process

Part A Carryover Process

Part A Carryover Process Once carryover request is submitted, DGMO waits for programmatic approval before reviewing/approving the request Approval Process in EHB: Project Officer → Branch Chief → Deputy/Division Director → GMS → QC/Branch Chief Part A carryovers require 2 actions to complete: Deobligation of funds from old award Reobligation of funds to new award Both actions must be processed in the same calendar month A carryover is not official until the second NoA is released

Common Reasons Carryover Requests are Delayed: FFR has not been submitted FFR was incorrectly submitted and requires revision Funding source by sub-program/prior year UOB not submitted correctly or properly explained

Common Reasons Carryover Requests are Disapproved or Reduced: Funds are requested for inappropriate items or restricted funds, such as requests for use of funds from restricted sources (prior year carryover/supplemental funds) or for unallowable costs Incorrect calculation of UOB Late submission of FFR or carryover request in EHB

Advance Payment Requirement for Recipients and Subrecipients – 45 CFR §75.305(b)(1) Implementation Approaches

Discussion - Monitoring and Utilization of Program Income At this time we request that everyone respond to the poll questions that will appear on your screen so that we may discuss.

Important Policy Clarification Notices Clinical Quality Management Important Policy Clarification Notices 15-01 Treatment of Costs under the 10% Administrative Cap for Ryan White HIV/AIDS Program Parts A, B, C, and D 15-02 Clinical Quality Management Policy Clarification Notice https://hab.hrsa.gov/program-grants-management/policy- notices-and-program-letters Two policy clarification notices are important when considering if expenses are treated as an administrative cost or clinical quality management cost. These policy clarification notices are 15-01 and 15-02. These policy clarification notices provide valuable information to guide you as your prepare your budget. You can find these and other policy clarification notices and corresponding frequently asked questions under the program and grants management tab on the HIV/AIDS Bureau website or at the address listed on the slide.

15-01 Treatment of Costs under the 10% Administrative Cap for Ryan White HIV/AIDS Program Parts A, B, C, and D (page 3) For all recipients (grantees) funded by RWHAP Parts A, B, C, or D, costs subject to the 10% administrative cap include, but are not limited to: Routine grant administration and monitoring activities, Preparation of routine programmatic and financial reports Subrecipient monitoring activities including telephone consultation, written documentation, and onsite visits Policy clarification notice 15-01 outlines costs that are allowable under the administrative cost category. There are a variety of administrative costs that are explained in the policy clarification notice. From page 3 of the policy clarification notice, I have highlighted a few administrative costs. These are costs that we have discussed with grant recipients. The routine grant activities including routine reporting (AKA RSR) and monitoring of subrecipients is considered an administrative activity; and therefore, allocated to the administrative cost category.

15-02 Clinical Quality Management Policy Clarification Notice A clinical quality management program is the coordination of activities aimed at improving patient care, health outcomes, and patient satisfaction. Infrastructure Performance measurement Quality improvement The other policy clarification notice I wanted to highlight is 15-02. Policy clarification notice 15-02 provides background information regarding clinical quality management program, the components of a clinical quality management program, and other related concepts (grant administration and quality assurance activities). The components are: infrastructure, performance measurement, and quality improvement. The expenses directly related to your clinical quality management program and components can be allocated under the clinical quality management cost category. Most of the clinical quality management costs are clear cut – meaning easily identify and allocate to the clinical quality management cost category. A examples include: staff time and effort to support the clinical quality management program including staff who direct and coordinate the clinical quality management program activities, analyze performance measure data train subrecipient on quality improvement tools and techniques.

Policy Clarification Notice 15-02: Quality Assurance Quality assurance refers to a broad spectrum of activities aimed at ensuring compliance with minimum quality standards (e.g. site visits and chart reviews). Quality assurance is not the same as quality improvement. Data collected as part of quality assurance processes should feed back into the clinical quality management program to ensure improvement in patient care, health outcomes, and patient satisfaction. Quality assurance is part of the larger administrative function of a recipient’s program or organization and informs the clinical quality management program, but quality assurance activities by themselves do not constitute a clinical quality management program. The CQM PCN 15-02 also talk in a little more depth about quality assurance. Quality assurance activities are defined as a broad spectrum of activities aimed at ensuring compliance with minimum quality standards. By compliance with minimum quality standards we mean conducting site visits to assure the subrecipient is compliant with the national monitoring standards, local service standards/standards of care. Much of this compliance is completed through site visits and chart reviews. As you can see, quality assurance activities are essential subrecipient monitoring activities. As outlined in policy clarification notice 15-02, quality assurance activities are administrative funds. And thus, those costs should be allocated under the administrative cost category. I want to pause here. Susan and I have discussed this matter with grant recipients on site visits. Some grant recipient have been unclear that monitoring standards of care is considered an administrative activity and cost.

Grants Management Grant administration refers to the activities associated with administering a RWHAP grant or cooperative agreement (e.g. contracting of services, receipt and disbursal of program funds, data collection and submission of reports, monitoring of subrecipients, and compliance with audit requirements). Although these functions are necessary to comply with the terms and conditions of the award, their intent is not on improving health outcomes. Therefore, they are not clinical quality management activities. Policy clarification notice 15-02 also discusses grants management activities. Similar to quality assurance activities, grants management activities are allocated under the administrative portion of the budget. Good examples of these activities include the data collection for routine program reporting. In other words, data collection for and submission of the Ryan White Services Report (or RSR). Many grant recipients have a data system that is serving functions for both the grants management and clinical quality management components of their program. In this case, the costs associated with the data system can be allocated across both the administrative and clinical quality management cost categories. I know the question you want to ask. How much of the data systems costs should be to administration and clinical quality management cost categories? There is not exact formula.

Clinical Quality Management Relevant Activities under Quality Assurance and Clinical Quality Management Activity Quality Assurance (Admin. Costs) Clinical Quality Management Performance measurement prioritization and alignment with other RWHAP Parts in the service area X Development of service standards Data extraction for clinical quality management purposes (collect, aggregate, analyze, and report on measurement data) Chart audits/reviews Monitoring site visits If the purpose for the site visit is to assess or monitor the CQM Program Extracting data for reporting to internal and external stakeholders Electronic health records interface with other providers; system operations CQM committee in planning for quality improvement projects The chart below demonstrates the overlap between Quality Assurance activities and CQM activities. Within the last year, we have discussed with grant recipients how to handle the expenses associated with data collection --- more specifically, how to handle the expense when one data system is used for both routine report and clinical quality management. We engage in a discussion with the project officer and grant recipient regarding what are all uses (and frequency) for the data system, the associated costs, etc. Based on this information, we have come to a reasonable allocation of the expenses.

Speakers Brad K. Barney, MPA Chief, HIV/AIDS and Rural Health Branch HRSA Division of Grants Management Operations Marlene Matosky, MPH, RN Branch Chief, Clinical and Quality Branch HAB Division of Policy and Data 301-443-0798 mmatosky@hrsa.gov Susan Robilotto, DO Medical Officer HAB Division of Metropolitan HIV/AIDS Programs 301-443-6554 srobilotto@hrsa.gov Gary Cook, MPH Deputy Director 301-443-9090 gcook@hrsa.gov Steven R. Young, MSPH Director 301-443-7136 syoung@hrsa.gov

Thank You Questions?