| Preventive Health and Health Services Block Grant
funded solely with Prevention and Public Health
Funds |
Subrecipient Monitoring. Public Health and EMSA did not evaluate each
subrecipient's risk of noncompliance with federal statutes, regulations, and
the terms and condition of the subaward of the Public Health Emergency
Preparedness, Immunization Cooperative Agreements, Preventive Health
and Health Services Block Grant (PHHSBG), and National Bioterrorism
Hospital Preparedness Programs. Public Health and EMSA did not have
policies and procedures for evaluating each subrecipient's risk of
noncompliance with federal statutes, regulations, and terms and conditions
of the subaward in a timely manner. |
2015-16 |
| Partially Corrected. Each subrecipient has been given a risk assessment
and score for state fiscal year 2016-17, which predicts their level of grant
compliance for the fiscal year 2017-18 grant year. The risk assessment
matrix and grant compliance criteria is reviewed annually and updated as
necessary. Annually, each subrecipient will have their risk assessment
evaluated and scored.
In January 2017, Public Health/Chronic Disease Control Branch (CDCB)
reviewed all federal statutes, regulations, and the terms and conditions of
the federal PHHSBG award to determine whether or not policies and
procedures existed and were operating effectively to ensure compliance
with all requirements. In February 2017, Public Health/CDCB developed
policies and procedures to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and
conditions of the sub-award. On February 15, 2017, Public Health/CDCB
hosted a PHHSBG Program Updates Meeting and shared the new
processes and requirements with Public Health and EMSA PHHSBG
programs. On February 24, 2017, Public Health/CDCB shared a
Memorandum of Understanding (MOU) containing the requirements and
restrictions with PHHSBG Programs and requested it be signed. The
signed MOUs are retained in Public Health/CDCB’s files. On July 14,
2017, Public Health/CDCB hosted a PHHSBG orientation to share
updated information pertaining to the requirements and restrictions, and to
answer programs’ questions. On August 4, 2017, Public Health/CDCB
distributed written guidance on the new processes and requirements,
including evaluating subrecipient’s risk of noncompliance.
Since November 2017, EMSA has been utilizing the Public Health Risk
Assessment Tool for evaluating each subrecipient’s risk of noncompliance
with federal statutes, regulations and the terms and conditions of the
subaward.
Public Health is currently working to centralize and streamline the
subrecipient monitoring process. PHHSBG subrecipients will be
monitored according to the assessed risk.
Effective July 2017, the Immunization Branch implemented the use of a
Request For Application (RFA) to ensure all potential subrecipients of
federal funding were provided with federal grant information, compliance
requirements, and terms and conditions in advance of submitting an
application for funding. The RFA includes an acknowledgement form,
which confirms the applicant has received and reviewed the information.
Public Health is continuing to work on developing a tool to assess each
subrecipient’s risk of noncompliance with federal statutes, regulations, and
the terms and conditions of the federal award, as well as monitor
subrecipients around the same items. Public Health has been researching
appropriate items to include in the submonitoring checklist. The
Immunization Branch is collaborating with both the state and Centers for
Disease Control and Prevention (CDC) to determine what best practices
exist to help in the development of the form. Public Health anticipates that
a draft of the form will be completed by the end of August 2017 and then
will solicit feedback from the state and CDC in the month of September
2017 in order to complete the form by October 2017.
Emergency Preparedness Office (EPO) in collaboration with Grant
Compliance Unit, part of the Office of Compliance, performed its risk
assessment for noncompliance with federal statutes, regulations, and the
terms and conditions of the federal award for all of its subrecipients. |
56 |
| Preventive Health and Health Services Block Grant
funded solely with Prevention and Public Health
Funds |
Subrecipient Monitoring. The Immunization Branch and Chronic Disease
Control Branch (CDCB) of Public Health and EMSA did not communicate
the universal identifier and system for award management requirements to
applicants in accordance with 2 CFR 25.200. Additionally, the unique
entity identifier was not collected prior to awarding funds in accordance
with 2 CFR 25.205. Public Health and ESMA did not communicate to its
subrecipients the required federal award data elements upon making a
subaward, including identifying the award as a subaward in accordance
with 2 CFR 200.331. Public Health and EMSA were not aware of these
pre-award and post-award requirements for pass-through entities, and had
not established a process to ensure required information is communicated
to subrecipients.
|
2015-16 |
| Partially Corrected. Public Health/CDCB and EMSA agree with this
finding. In February 2017, Public Health/CDCB created policies and
procedures to ensure the required information is communicated to
applicants in accordance with 2 CFR 25.200, and that the unique entity
identifier is collected prior to making subawards in accordance with 2 CFR
25.205. On February 15, 2017, Public Health/CDCB hosted a Program
Updates Meeting and shared the new processes and requirements with
Public Health and EMSA’s Preventive Health and Health Services Block
Grant (PHHSBG) Programs. On February 24, 2017, Public Health/CDCB
shared with programs a Memorandum of Understanding (MOU)
containing the requirement to comply with 2 CFR 25.205 and requested it
be signed. The signed MOUs are retained in Public Health/CDCB’s files.
On July 14, 2017, Public Health/CDCB hosted an orientation to share
updated information including the requirement to comply with 2 CFR
25.205. On August 4, 2017, Public Health/CDCB distributed written
guidance on this requirement. CDCB plans to work with the Public Health
Contract Management Unit to develop a PHHSBG specific contract
checklist that will be required for all PHHSBG contracts. These
requirements will be included in the PHHSBG Checklist. Public
Health/CDCB will implement all aspects of this corrective action and
maintain records demonstrating that such communications occurred.
EMSA’s administrative staff met during May 2017 to discuss the audit
findings and reviewed existing processes. The review process was
completed before December 31, 2017. EMSA received in November 2017
the Public Health “Program Instructions for Potential PHHSBG
Contractors and Sub Recipients Checklist” which was distributed to all
PHHSBG programs. EMSA is utilizing this document to ensure that
EMSA communicates to applicants in accordance with 2 CFR 25.200 and
that the unique entity identifier is collected prior to making sub awards in
accordance with 2 CFR 25.205. Additionally, this document also provides
for the timely and proper communication of all applicable subaward
information in accordance with 2 CFR 200.331 and ensures that EMSA
maintain records demonstrating that such communications occurred.
Effective July 2017, the Immunization Branch implemented the use of a
Request For Application (RFA) to ensure all potential subrecipients of
federal funding were provided with federal grant information, compliance
requirements, and terms and conditions in advance of submitting an
application for funding. The RFA includes an acknowledgement form,
which confirms the applicant has received and reviewed the information.
The universal identifier of each applicant is one data element collected
through the RFA while the cover letter to the RFA identifies potential
awards as subawards and provides required federal award information. |
52 |
