California Department of Public Health

Local Incentive Awardee

Fiscal Orientation

Goals of Fiscal Training

To ensure that Contractors have an

accurate understanding of the fiscal

requirements of their Network contract.

Network For A Healthy CaliforniaFunding Structure

USDA

California Department of Social Services

California Departmentof Public Health (CDPH)

RegionalNetworks

Local Incentive Awardees (LIA)

Special Projects

• Participants are receiving or eligible for USDA Food Stamp Program

• Organizations that serve individuals: 50% or more under 185% of Federal poverty level

• Individual schools: 50% or more free and reduced lunch program

Network Audience

Roles

• Contract Manager (CM)

• Program Manager (PM)

• Program Compliance (PC) Team

• Nutrition Education Coordinator (NEC)

• Contractor

Contract Manager (CM)

• Budget justifications, budget revisions and source documentation review

• Contract, fiscal and administrative issues (including negotiations and processing of contract)

• Payment of invoices

• Memorandums of Understandings and Subcontractor Agreements

• Equipment management and tagging

• Travel approval

• Conduct site visits and desk reviews

• Provide ongoing technical assistance

Program Manager (PM)• Assistance in development and approval of the

Scope of Work (SOW)

• Clarification of USDA Guidelines for SOW activities

• Review of SOW progress reports and provide Contractor with Final Progress Report Analysis (FPR)

• Conduct site visits

• Provide ongoing technical assistance

Nutrition Education Coordinator (NEC)

• Provide Technical Assistance to LIAs working in schools on: Curriculum Nutrition education resourcesStrategies to resolve challengesProgram evaluation

• Connect LIAs with other organizationsShare resources and ideasAvoid duplication of efforts

• Facilitate trainings to meet the needs of LIAs working with schools

• Provide Technical Assistance to the PM

Program Compliance (PC) Team

• The PC Team will conduct an in depth review for all Network Contractors during a three year period. (An 8 week notice will be given.)

• They will review fiscal records and systems for one Quarter to ensure compliance with USDA rules and regulations.

• If necessary, they will provide recommendations to the

Contractor for program improvement.

• The Contractor will develop a Program Improvement Plan (PIP) proposing a corrective action/change.

• Network staff will follow up with the Contractor to ensure changes have been implemented.

ContractorFiscal Responsibilities

• Compliance with USDA rules and regulations.

• Documentation, completion and timely submission of State and Federal Share reports.

• Prepare and respond to Network and USDA site visits.

• Respond to Network requests for information.

• Retain all records related to contract for 3 years

after the end of the contract term.

ContractorProgram Responsibilities

• Conduct all Network activities per USDA Guidelines

• Complete all Objectives and Activities in SOW as scheduled.

• Full completion of Semi Annual Activity Report (SAAR), Final Project Report (FPR), and Interim Progress Reports

• Provide assistance and information to the Network team, PC team or USDA during site visits

Contractor Information Form

• All Contractor Information found on this form

Continuing: Use current contract numberRenewing: Leave contract number blank if

not known at time of completion.

• Payment Receiver: Fiscal remittance address (Where you want the check sent)

• Notify CM of any personnel or location changes to this form

(Handout)

FSNE Guidelines Manual

• Provides USDA Guidance

• Allowable and Unallowable activities.

• Fiscal/Administrative and Contract section highlighted by green tabs.

• Available on the website at:

www.dhs.ca.gov/ps/cdic/cpns/network/FiscalGM.htm

Budget Justification

BUDGET JUSTIFICATIONIntroduction

The Budget Justification is a

financial plan

to carry out the activities

in your program

Budget Justification

• State and Federal Share combined on one form

• Gives the basis for the costs in your budget

• Must correspond directly to SOW and supports the SOW activities

• Prior CM/PM authorization required for any SOW or budget changes

• Part of a contractual agreement between Contractor and CDPH—must be adhered to

Budget Justification Nine Line Items

A. Personnel

B. Fringe Benefits

C. Operating Expenses

D. Equipment Expenses

E. Travel & Per Diem

F. Subcontracts

G. Other Costs

H. Indirect Costs

I. Total Costs

Reasonable and Necessary Costs

Reasonable –

• Provides a program benefit generally commensurate with costs incurred

• Is in proportion to other program costs

• Is a priority expenditure relative to other demands

Necessary -

• Is incurred to carry out essential functions

• Cannot be avoided without adversely affecting operations

• Does not duplicate efforts

A. Personnel

• Name and Title of Staff

• % of time spent on allowable activities

• Yearly or hourly rate must be based on 2080 hours/year. Show staff FTE in Admin or direct Delivery

• Detailed position description of each staff

Staff Time Reporting Requirements

• Document time (must be reasonable and necessary) spent on ALLOWABLE nutrition education activities (prime and subcontractors)

• 100% FTE of time on Network activities:Semi-Annual Certificate of Activity

(Handout)

• Less than 100% of time on Network activities:Weekly Time LogQuarterly Time Study approved by USDA

(Handouts)

• Document State and Federal Share separately

• Expenses based on actual time and actual salary rate per employee

Weekly Time Log

• Clearly delineate documented time for State or Federal Share in 15 minute increments, i.e., .25, .50. 1.75, etc.

• Activities must be listed on reverse side of all logs

• Must be signed by Staff and Supervisor

• Can be customized with prior from USDA(Handout)

B. Fringe Benefits

• Records actual expenditures associated

with fringe benefits for each employee

• Average fringe used during budgeting,

actuals used when reporting to Network

• Must include a list of items covered under Fringe in Budget Justification

C. Operating Expenses

• Routine and ongoing expenses

• Supported by vendor invoices, bills, receipts

• Facility costs must be based on actual expenses (not fair market value or realized cost)—must include a formula for the basis on the budget justification

• Must be prorated by FTE of staff incurringthese expenses

Calculating Operating Expenses

• Prorating formula

FTE of FSNE Staff = % to prorate FTE of Organization Staff

• Historical costs

• Allocated costs

D. Equipment

• Non-expendable property used to conduct eligible nutrition education activities

• Must be prorated by FTE of staff using the equipment (office furniture, computer, printer, etc.)

• Costs must be supported by vendor invoices, bills, receipts

• Prior written authorization is required by CM/PM for any equipment purchases not in the approved Budget Justification (both State and Federal)

Equipment: Laptops

• Laptops must have encryption software installed

• Laptops should only be assigned to 50% FTE FSNE staff

• Staff using laptops must complete a laptop procedure and protocol form

• Laptops require a signed Agreement of Responsibility, addressing protection of privacy data, necessary steps in the occurrence of a security breach, and responsibility for negligence.

Equipment: Tags

After purchase of equipment with Federal Share funds:

• Contractor must complete a Contractor Equipment Purchased with CDPH Funds form (Exhibit H) and submit it to your assigned CM along with the quarterly invoice that includes equipment expense(Handout)

• CM will obtain tags from CDPH for equipment and provide them to the contractor

• Immediately report damaged, lost or stolen equipment to your CM

Equipment: Inventory

• At close of each contract term, complete an Inventory/Disposition of CDPH Funded Equipment Form (Exhibit I) and submit to your assigned CM(Handout)

E. Travel and Per Diem

• Network sponsored trainings, conferences, and meetings are

100% allowable for all staff

• All Travel expenses must adhere to current DPA rates (included as Exhibit G of your contract). This applies to the Contractor, all Subcontractors and advisory committee members

Travel and Per DiemDocumentation

Travel logs/claims for each staff (separately) which lists the following:

• Name/title of person traveling

• Date(s) of travel

• Start and end time

• Purpose and location of FSNE trip

Travel and Per DiemDocumentation (Continued)

• Hotel, parking, airline and any other receipts (meals do not require a receipt)

• An agenda must accompany the travel log/claim (not required for Non-Network conferences/meetings)

• Objective of Conference or Workshop as it pertains to FSNE

NON-NETWORK SPONSORED TRAVEL

• All Non-Network sponsored trainings conferences, meetings must be pre-approved by your CM/PM utilizing the Non-Network Sponsored Travel Pre-Approval Form and prorated appropriately

F. Subcontracts

Each Subcontractor is required to submit a:

• Budget Justification and description of service

• Signed Memorandum of Understanding (State Share)

• Signed Subcontractor Agreement (Federal Share)

• Adherence to all USDA/CDPH guidelines and rules

• Documentation retention for 3 years, beyond the end of the contract

Key Elements Required in Network Subcontracts

• Name of the parties

• Terms

• Scope of Work

• Maximum amount payable

• Cancellation clause

• Record retention clause

• Exhibit D (F), Special Terms and Conditions

Subcontractor vs. Consultant

• Subcontractor:– organization– budget for the complete project– assigned a part of the SOW– minimal direction from prime – Federal Tax I.D. Number

• Consultant:– person with expertise– hourly rate– works with direction from prime contractor– require a 1099M form

G. Other Costs• Non-routine, occasional or one time expenses:

Publications/materials/videos

Food and supplies for nutrition education food demonstrations/taste testings

Expendable small equipment items

• Must be itemized on the budget justification and show the basis for the costs

• Nutrition Education Reinforcement Items (NERI) must be $4 or less each. (Currently there is a moratorium on all NERI)

• Must be documented by vendor invoices or receipts

H. Indirect Costs

• General overhead costs

• Should be based on organization’s Federally Negotiated Indirect Rate whenever possible

• Actual expenditures must be used and documented with a copy of organization’s indirect cost rate and a list of all items billed under this line item

• If no Federally Negotiated Indirect cost rate—cost cannot exceed 25% of total personnel and fringe expenses

Documentation and Invoicing

• Must be based on actual expenses incurred during the quarter—include cents, no rounding

• Correspond directly with the approved budget justification

• Be substantiated by supporting documents

• Submit original documents signed in blue ink by the duly authorized contract representative

• No correction fluids or tapes

• Fill in all information on form (date, contract number, contract name, etc.)

• PLEASE CHECK YOUR MATH

State & Federal Share DocumentsInvoice and State Share Documentation Report(Handouts)

State Share Documentation

• Report actual expenses even if amounts go over amounts listed on Budget Justification

• Negative line items total allowed

• BAR not necessary for State Share Documentation

Source Documentation

• USDA guidelines apply to both State and Federal Share in the same way and must be documented consistently

• Documentation must:– be dated– match invoices– be organized by budget line item

• State Share documentation reports must represent at least twice the Federal Share invoice

Federal Share Invoice

• Invoices cannot list negative numbers

• Over-expenditure of a line item requires a Budget Adjustment Request (BAR) with a written justification (prior to invoice)

• Supplemental invoices must be utilized for expenses not originally billed in a particular quarter. Do not bill these expenses on the next quarter

• Invoice only documented and allowable expenses

Budget Adjustment Request (BAR)(Handout)

• BAR used to revise line item amounts in Federal Share budget

• Cannot exceed $25,000 or 10% of fiscal year total, whichever is greater, up to a cumulative maximum of $50,000 per year

• Total Federal Share budget amount per year cannot increase or decrease

• Must be programmatically justified and not alter SOW

• Requires prior written approval from CM/PM

• Submit prior to 4th quarter invoice

PROGRAM LETTERS

• Program letters are changes made to the contract by CDPH or USDA guidelines, during the term of the contract

• Item # 1A(3) in Exhibit E (Additional Provisions) in your contract

• Example: Program Letter # 07-10 – Clarification on Spending FFY 2007 Funds Held Due to Print and Promotional Item Moratorium

Payment Process

• Contract Manager Review

5-10 business days

• Accounting Staff Review

11-30 business days

• State Controller’s Office

mailed within 15 business days

• Total time 45-60 business days

Network Address

• Regular MailCalifornia Department of Public HealthCancer Prevention and Nutrition SectionATTN: (Assigned Contract Manager)P.O. Box 997377, MS 7204Sacramento, CA 95899-7377

• Overnight MailCalifornia Department of Public HealthCancer Prevention and Nutrition SectionATTN: (Assigned Contract Manager)1616 Capitol Avenue, MS 7204, Suite

74.516Sacramento, CA 95814

Contractor’s Fiscal Schedule

Invoices

• Federal Fiscal Year October 1 to September 30.

• Invoices paid in arrears, quarterly or monthly.

• Deadlines per USDA. Contact CM for extension

Period Covered Due Date

Q1 10/1 - 12/31 January 31

Q2 1/1 - 3/31 April 30

Q3 4/1 - 6/30 July 31

Q4 7/1 - 9/30 December 31

• Monthly invoices due 30 days after invoice period.

Site Visits and Reviews

• Program Compliance (PC) Team visit will occur during FFY 2008 or 2009

• CM/PM and NEC visit will occur minimum once per contract term

• USDA review may occur with advance notice

• Desk Reviews will be conducted by CM as necessary

Contractor’s Release Form

• Completed, signed and returned with final invoice at the end of the contract term

• Exhibit F in your contract

• Signatory of Exhibit F and contract must have same signature authority

• Must include contract name, number, amount of final invoice and date

Funding Application and Contract Processes

Funding Application Package(FAP)

• Required of all Contractors on a yearly basis

• Submitted to CPNS for CM/PM review

• Included in the Network for a Healthy California Annual Plan to USDA

• Applications reviewed and approved by CPNS and USDA

Network FAP Steps

• FAP is e-mailed to Network Primary Contractors (prime)

• Primary contractor (prime) distributes application forms to subcontractor (sub)

• Sub submits MOU, SOW, and BJ to prime

• After receiving completed sub applications, prime completes Network funding application forms

Network FAP steps, cont…

• Prime application is packaged and sent electronically to CM/PM

• Contract negotiations with CPNS and prime

• Contracts negotiated, finalized, and fully executed

• Prime issues subcontract agreements and MOUs to subs and partners

• New contract year begins

Key Network FAP Documents• Letter of Qualification and Intent (Prime)

• Contact Information Form (Prime)

• Budget Justification (Prime + Sub)

• Budget Cover Sheet (Prime)

• Project Synopsis (Prime)

• SOW (Prime + Sub)

• MOUs (Between Prime + Partners)

• Copies of “Modified” Weekly time Logs/Quarterly Time Study (if applicable) (Prime)

• Indirect Rate Certification Form (Prime + Sub where applicable)

FAP Timeline

• 12/15/07 – Continuing Contractor Instructions release

• 1/15/08 – Continuing Contractors documents finalized

• 2/4/08 – FAP released for Renewing Contractors

• 2/27 & 2/28 – FAP Teleconference

• 4/3/08 – FAP deadline for Renewing Contractors

• 4/4/08 – 6/15/08 - Contract negotiations

• 7/15/08 – FSNE Plan to CDSS for review

• 8/18/08 – FSNE Plan to USDA for approval

FAP TELECONFERENCE

• February 27, 2008 2-4 p.m. 1-888-709-9420

Password “FAP Training”

• February 28, 2008 9-11 a.m. 1-888-709-9420

Password “FAP Training”

Memorandum of Understanding

Memorandum of Understanding (MOU) with collaboratingorganizations:

• Signed by representative of each organization

• Required if collaborating organization is or is not supplying State Share

• Required for Federal Share if collaborating organization is providing a resource significant to completion of SOW

• If organization is listed on Project Summery

• MOUs are a required FAP document

• USDA wants MOUs for any partnership(Handout)

MOU Requirements

• Name of organizations

• Description and dates of proposed activities

• Total State Share dollars proposed or statement that no State Share dollars involved

• Partner will provide State and Federal Share documentation

• No activities funded by FSNE supplant existing nutrition education efforts

• Signatures, titles and dates

MOU Required Language

• No federal funds

• Not matched under another program

• Documentation requirements

• Do not supplant existing activities

• Coordination with NECs required for school-based programming

Network Growth Policy

• Contractors must maintain FFY 2008 maximum budget levels

• No budget growth for FFY 2009 for FSNE contracts

Administrative Relief

• CDPH lost administrative relief contract provisions

• CPNS appealed revocation

• Admin Relief includes:

– Nine Line Item Budget– Multi-year term– Line Transfer (BARs)– Informal Budget and SOW changes

• Impact to Network Contractors

Technical Assistance

• Response to fiscal questions

• With FAP Forms

• Understanding allowable/unallowable chart

• With budgeting

• With travel requirements and non-Network sponsored conferences

• On how to prorate expenses

Compliance• Monitor and evaluate contractor performance • Notify contractors of noncompliance or

underperformance issues, and request appropriate action within a reasonable time period

• Implement appropriate Corrective Action

Plan (when necessary)

• Conduct CM/PM Site Visit or Desk Review

Administrative Consequences for Non-Compliance

• Restrict Budget Growth

• Require back-up documentation for payment of quarterly invoices

• Restrict eligibility of Budget Adjustment Request (BAR)

• Restrict eligibility of formal contract amendment

• Reduce contract budget

• Reduce contract term

• Revoke contract

CPNS Website

http://www.dhs.ca.gov/ps/cdic/cpns/

USDA Guidance for FFY 2007www.nal.usda.gov/foodstamp/national_fsne.html