Milwaukee County Department of Health Human Services DHHS
- Slides: 58
Milwaukee County Department of Health & Human Services (DHHS) 2007 Purchase of Service Contracts Orientation Presented by: Dennis Buesing – DHHS Contract Administrator Wes Albinger – DHHS Contract Services Coordinator Randy Iding- DHHS Accounting Coordinator January 18, 2007
Overview of 2007 Purchase-Of-Services Contract & Changes Presented By: Dennis Buesing, DHHS Contract Administrator January 18, 2007
Summary of Changes SECTION TEN - INDEMNITY & INSURANCE Paragraph A: Indemnity from copyright and patent infringement language added as a separate paragraph. Paragraph B: Coverage language added to include: malpractice, errors and omissions. Automobile insurance requirements statement added. Statement regarding professional liability added. Types of Insurance Coverage: Working Out of Home Office Exclusions to “additional insured” endorsement updated. Evidence of insurance coverage to be furnished on or before the date of renewal. Insurance underwritten on a Claims-Made Basis. Identifies when insurance “binders” will be accepted January 18, 2007
Summary of Changes…. . contd. Insurance Requirement: Auto Liability: required for all agency vehicles (owned, non-owned, and/or hired). Coverage: 1 million per accident Employees of Providers using personal vehicles to transport Clients/ participants, or for any other reason related to the contract shall have Automobile Insurance providing the same liability limits as required of the Network Provider January 18, 2007
Summary of Changes…. . cont’d. Insurance Requirement (Cont’d): Commercial General and/or Business Owner’s Liability: Required of ALL Providers and must include premises and off premises liability coverage Professional Liability: If the services provided constitute Professional Services, Provider shall maintain Professional Liability coverage (i. e. if a license or certification is required to perform the service). Includes Certified/Licensed Mental Health & AODA Clinics and Providers. Coverage: 1 MM/3 MM January 18, 2007
Summary of Changes…. . cont’d. Insurance Requirement (Cont’d): Upon Renewal: Provider shall furnish County annually on or before the date of renewal, evidence of a Certificate indicating the required coverage (with the Milwaukee County Department of Health & Human Services named as the “Certificate Holder”) Binders are not acceptable except during preliminary application period Failure to comply with insurance requirements may result in suspension or non-renewal of contract January 18, 2007
Summary of Changes…. . contd. SECTION NINETEEN - PROHIBITED PRACTICES AND REQUIRED DISCLOSURES Section rewritten re. Campaign contribution restrictions associated with Milwaukee County Code of Ethics - Chapter 9. SECTION TWENTY - CERTIFICATION REGARDING DEBARMENT & SUSPENSION Debarment By Milwaukee County – 2 Yr. Minimum Period of Debarment (New Section) SECTION TWENTY-THREE – CRC PLAN Language modified/rewritten January 18, 2007
Budget & Other Final Submission Items 2007 Purchase of Services Revenue & Expenses Report 2006 Revenue & Expenses Report Issues January 18, 2007
Budget and Other Final Submission Issues 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, 3 S, 4, 4 S, 5, 5 A and 6. Providers reporting Milwaukee County’s share of the program only, versus the total program, typically on Forms 1 or 5. (i. e. Forms don’t agree with Total Program Expenses, Form 3) January 18, 2007
Final Submission Items cont’d 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, (Total Allocated Costs should agree with Form 6 & include all Indirect Costs to be allocated). Omission of IRS form 990 for Non Profit providers. January 18, 2007
Changes in Allowable Costs The Annual audit report shall contain a budget variance and reimbursable cost calculation for each program contracted. (refer 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 excess variance by submitting revised budget & obtaining approval by DHHS prior to end of contract yr. (Extended until deadline for final billing, Jan. 26, 2007) Final billing should include revised budget. (Refer to Section 4 Reporting Requirements Pg 113 of Tech Requirements Booklet) An annual audit report that omits information or doesn’t present line item information utilizing classifications as per Form 3 will place Contractor out of compliance with the contract. January 18, 2007
2007 Purchase of Service Revenue & Expenses Report 2007 Purchase of Service Revenue & Expense Report has been revised. (http: //www. milwaukeecounty. org/display/router. asp? docid=15483) No More Macros. No buttons to hide columns or switch between summary and detail as in last year’s forms. New selection boxes added (e. g. partial or final invoice, period of contract, budget – original, revised or amended). New Tabs added last year 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. 2007 Professional Services Expense Report has also been January 18, 2007 revised. (http: //www. milwaukeecounty. org/display/router. asp? docid=15483)
Common Errors in 2006 Revenue & Expense Reporting Failure to submit by the end of the fifth working day of the month following the month in which services were delivered. Timely submission of required reports is a scored item in the proposal review process, and failure to submit required reports in a timely fashion can reduce agency scores on "Administrative Ability" by up to 33%. Improper use of email subject line. (e. g. Division, Agency, Program & Month). Instructions detailing the proper use of the subject line are detailed in the "Instructions" tab included with the template. Sending reports email addresses other than DHHSAccounting@milwcnty. com Combining of line items-a common error is combining line items 7100, employee benefits, and 7200, payroll taxes. January 18, 2007
Common Errors… Contd. Inaccurate approved budget figures - approved budget for the program should reflect the format and amounts in your final submission of Form 3. Budgeted “Net Request” should agree with the County Contract amount on Attachment 1. (i. e. budgets should balance & not have net unfunded requests!) Reporting estimated versus actual expenses. All expenses should be supported with general ledger entries. (mandated by fed & state costs principles) Reporting expenses for line items with no approved budget for that line item. (will not be paid) Combining multiple programs into 1 R/E statement. January 18, 2007
Common Errors… Contd. Reporting expenses for line items for which the YTD total exceeds the greater of 10% of the prorata budget for the line item or 3% of the total prorata approved program budget prior to receiving approval of revised budget. Reporting only the Milwaukee County purchase contract portion of the program, versus the whole program. This applies to expenses as well as units. January 18, 2007
Common Errors… Contd. Not entering approved budgeted units on the “Units” tab Entering the incorrect, or no unit rate on the “Units” tab. (Unit rate should equal “Absenteesm Rate” on contract Attachment 1) Itemizing units by different funding sources on the "Units" tab. All units should be reported together, except in the case of different services with different rates within a program, such as Supportive Living Options. January 18, 2007
Audit and Account Requirements Maintaining Financial Records General Information on Allowable Costs Audit Waiver Procedures Audit Review Issues January 18, 2007
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 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 CCIs) 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. Fed audit requirements are for an annual audit January 18, 2007
What Must the Audit Contain? Opinion on the Financial Statements and all Supplementary Schedules Report on Compliance & Internal Control (I/C) Based on Audit of Financial Statements Performed in Accordance with GAS and PAAG If applicable, Report on Compliance with Requirements Applicable to Each Major Federal Program and I/C over Compliance in Accordance with OMB Circular A-133 Summary of Auditor’s Results and Schedule of Findings and Questioned Costs & Copy of Management Letter, if any 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. January 18, 2007
What Other Schedules are Required? Schedule of Expenditures of Federal & State Awards Per Contract, Schedule of Program Revenue & Allowable Cost by Funding Source, and by Contract, or program/facility within a contract (If program receives revenue from more than 1 funding source, all funding sources must be listed separately) If applicable, Incorporated Group Home/Child Caring Institution Supplemental Schedule Nonprofit providers paid on a unit-times-unit-price contract, Reserve Supplemental Schedule For-profit providers, Schedule of Allowable Profits January 18, 2007
Allowable Costs & Allowable Profits or Reserves Per State Statute, ultimately, all agreements with Milwaukee County DHHS for client care & services paid with dept. funding are cost reimbursement contracts For-profit providers may retain up to 10% in profit per contract; 7½% of allowable costs, plus 15% of net equity (Allowable Cost Policy Manual, Section III. 16) Nonprofit providers paid on a unit-timesunit-price contract may add up to 5% of contract amount in excess revenues to reserves each yr. , up to a cumulative maximum of 10%. January 18, 2007
Allowable Costs & Allowable Profits or Reserves The County will not fund a program’s cumulative prior year’s deficits with current year funding (i. e. a program cannot have a negative reserve balance). 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 January 18, 2007
Other Allowable Cost Issues Generally interest expense, except for purchase-money mortgages to purchase real estate, or equipment is not an allowable cost. Interest paid under Working Capital Loans, a line of credit or refinancing to pull money out of a property is not an allowable cost. Generally, advertising expense, except for costs associated with hiring and recruiting, is not an allowable cost Alcohol, Entertainment, Contributions & Donations and repayment of audit recoveries and other debt, are never an allowable cost January 18, 2007
Allowable Cost & Related Party 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) Rental expense under sale lease back arrangements are only allowable to the extent of expense which would have been incurred had title to the property remained vested with the renter Per contract, the auditor must disclose related party rental arrangements, rent paid to the related party, the related party’s actual expenses on the property, & the amount of unallowable rent on each property charged to any contract with Milwaukee County January 18, 2007
Maintaining Financial Records Both Federal and State contracting guidelines require provider agencies to maintain orderly books and adequate financial records Maintain a uniform double entry accounting system and a management information system compatible with cost accounting and control systems. Providers should maintain an accurate and up-todate general ledger and timely financial statements for management & board members Financial Statements must be prepared in conformity with accounting principles generally accepted in the U. S. (GAAP) and on the accrual basis of accounting. Contractor must request, and receive written consent of County to use other basis of accounting in lieu of accrual basis of accounting. January 18, 2007
Maintaining Financial Records Amounts recorded in the general ledger should be adequately supported by invoices, receipts or other documentation Providers should maintain a separate cost center or dept. in their general ledger for each contract, or program/facility within a contract Whenever possible, costs should be charged directly to a contract, all other costs should be allocated using a reasonable and consistent allocation method and supported by an Indirect Cost Allocation Plan Providers must not commingle personal and business funds. A separate checking account should be established & providers should not use personal credit cards for agency business All Provider agencies should maintain and adhere to a board approved, up-to-date Accounting Policy & Procedures Manual January 18, 2007
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 (Group Foster Care or CCI). Waiver request can only be entertained if agency does not need to have an audit according to Federal Audit requirement. Waivers need to be approved on case by case basis by regional office based on a 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. Waiver Form is available at the bottom of the web page: http: //milwaukeecounty. org/display/router. asp? Doc. ID=9853 January 18, 2007
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Common Errors or Omissions Audit indicates issuance of Management Letter, but agency fails to submit letter & management’s response Failure to submit corrective action plan when audit discloses Finding or Questioned Costs Failure to report all DHHS Programs separately by Contract, or program/facility within a contract Failure to identity all funding sources on Sch’l of Program Rev. & Exp’s (all funding sources must be listed as a separate line item) January 18, 2007
Errors or Omissions cont’d Nonprofits - Failure to provide Supplemental Reserve Schedule for all programs or contracts Failure to submit audit in a timely manner (results in Admin. Probation & inability to renew contract) Failure to submit written Extension requests Failure to submit written Waiver requests Failure to submit evidence of Insurance renewal in a timely manner Audits are sent to wrong address Audit confirmation are sent to wrong address January 18, 2007
Names & Address for Submissions Submit Audits to: Dennis Buesing DHHS Contract Administrator 1220 W. Vliet St. , Suite 109 Milwaukee, WI 53205 Ph: 414 -289 -5853 Submit Audit Confirmation Requests to: Robert Graveen DHHS Accounting 1220 W. Vliet St. , Suite 109 Milwaukee, WI 53205 Ph: 414 -289 -6036 January 18, 2007
Civil Rights Compliance Plan Requirements January 18, 2007
Civil Rights Compliance (CRC) All recipients of Federal and/or State funds are required to submit either a Civil Rights Letter Of Assurance (LOA) or a Civil Rights Plan for their agency The Equal Employment Opportunity certificate is a separate requirement and does not qualify as a CRC document. January 18, 2007
CRC (Cont’d)……. . Agencies with 25 or more employees AND awarded at least $25, 000 in federal, state & county funds are required to submit a full CRC plan Agencies with fewer than 25 employees AND/OR receive less than $25, 000 in funding may opt to submit a Letter of Assurance instead, which includes AA, EO and LEP policies Agencies who subcontract are also required to ensure the subcontractor maintains CRC requirements January 18, 2007
OTHER REQUIRED ITEMS (ATTACHMENTS) FOR SUBMITTING WITH THE CRC LOA Required Items Attachment 1: AA EO in Employment Policy Attachment 2: Form DOA-3607 Approval to be in Vendor Directory Form DOA-3024 Request for Exemption for Submitting AA Strategies for achieving a balanced workforce Form DOA-3023 Vendor Subcontractor List January 18, 2007 Profit & Nonprofit Entities Required Not Required
CRC (Cont’d)……. . New CRC plan requirements for years 2007 -2009 have been posted at DWD and DHFS web sites. LOA Instructions & Templates are available at: http: //dwd. wisconsin. gov/dws/civil%5 Frights/plans 0708/lo a_contents_page. htm CRC Plan Requirements & Templates are available at: http: //dwd. wisconsin. gov/dws/civil_rights/plans 0708/doc/p lan_07_09. doc Plan instruction and resources are available at http: //dwd. wisconsin. gov/dws/civil_rights/plans_instruction s. htm Training webcasts are available at: January 18, 2007 http: //dhfs. wisconsin. gov/civilrights/Index. HTM
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 durand@dhfs. state. wi. us Phone: (608) 266 -9372 Fax: (608) 267 -2147 January 18, 2007
Accounting Suggestions Presented By: Randy Iding, Accounting Coordinator, DHHS Accounting January 18, 2007
Accounting suggestions Items DHHS Accounting reviews for before authorizing proper and timely payments: R & E Report Format and others: Use 2007 RE report forms. Make sure the correct division is checked. Make sure the correct month is selected. Backup must match the request. Make sure contact info is correct. Don’t put Text in a numeric field. January 18, 2007
Suggestions…. . . Cont’d. Make sure you use the unit count and unit rate(s) as specified in the Attachment 1. The program name must agree with that shown on the Attachment 1. If budgets are revised and/or amended use the correct item drop down menu selection in the RE report to identify the change. If estimates instead of actual amounts are being reported. Please pick the correct item from the drop down menu on the RE report. Use only actual amounts for the final report. January 18, 2007
Suggestions…. . . Cont’d. DHHS pays on cumulative basis , the Lowest of the : • • • Net Expenses (expenses less revenue) Net Unit amount ( unit x unit rate less revenue) Pro rata contract amount. DHHS usually adjusts the advance payment in the last two months of the contract. In the case of under-spent contracts, adjustments for the advance may be made sooner. January 18, 2007
Suggestions…. . . Cont’d. Please Submit your RE report timely as it takes Central Accounting about 2 weeks to issue a check from time of submission to CA plus add another week from time of submission for review & processing by CSC & DHHS Accounting. If Vendor information changes such as name, address, tax ID #, etc. Please inform the CSC at the earliest as they have to submit a form to Central Accounting before payment under a new name, etc. can be made. Remember, Last date for submission of final RE Report for 2006 is January 26, 2007. January 18, 2007
Reporting Of Units DSD Agencies should submit the electronic Form 533 to report units. A copy of the form is available at the net http: //county. milwaukeecounty. org/Contract Mgt 15483. htm Please email form 533 to : dataunit@milwcnty. com attention of Ms. Debra Turzai. A Copy shold also be submitted to DHHS Accounting along with monthly R/E report : DHHSaccounting@milwcnty. com January 18, 2007
Accounting Contact Info: Randy Iding (414) 289 -6105 Riding@milwcnty. com Howard Felix (414) 289 -6183 (Billing Supervisor) Hfelix@milwcnty. com Robert Graveen (414) 289 -6036 Rgraveen@milwcnty. com (Audit Confirmations) Paula Dills (414) 289 -6465 (Process Payments) January 18, 2007 Pdills@milwcnty. com
BHD Contact info: Paul Radomski Walter Laux (414) 257 -7493 (414) 257 -7436 Pradomski@milwcnty. com ewlaux@milwcnty. com Chuck Sigurdson (414) 257 -7361 Csigurdson@milwcnty. com Rochelle Landingham (414) 257 -7337 Rlandingham@milwcnty. com January 18, 2007
DCSD Contact Info: Eric Meaux (414) 257 -7789 Dave Emerson (414) 257 -7284 demerson@milwcnty. com Jim Sponholz (414) 289 -5778 jsponholz@milwcnty. com January 18, 2007 emeaux@milwcnty. com
DSD Contact Info: Charlotte Williams (414) 289 -5898 Cwilliams 2@milwcnty. com Wes Albinger (414) 289 -5871 Walbinger@milwcnty. com Virgil Cameron (414) 289 -5954 Vcameron@milwcnty. com January 18, 2007
ESD Contact info: Judy Roemer-Muniz (414) 289 -6692 Jreomermuniz@milwcnty. com Jim Sponholz January 18, 2007 (414) 289 -5778 jsponholz@milwcnty. com
Thank you for your participation! Have a Great Day! January 18, 2007
Thank you for your participation! Have a Great Day! January 18, 2007
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