FFY2014 EAP Annual Training

1. FFY2014 EAP Annual Training Part 8: Quality & Performance Controls; State Monitoring & Auditing; Grant Contract

2. Intro. to Monitoring & Auditing

3. Monitoring, Auditing & Oversight One comprehensive system- its all about the money • HHS monitoring • OLA Auditing DOC • EAP Auditing SP • PARs • On-site visits • Desk monitoring

4. Monitoring, Auditing & Oversight National, State and Local efforts • Federal level • Increased funds staffing, monitoring, training, oversight • State level • Increased scrutiny, systems, controls, requirements • Local level • Self monitoring, risk assessment, oversight

5. Monitoring, Auditing & Oversight All of us • Play a role • Are responsible • Need to get better at these activities

6. Monitoring, Auditing & Oversight It’s about the money because . . . • Need to understand that is as important as providing the service to the household • If the program does not have integrity it can’t be here to help those who need it • It’s about the households

7. Monitoring and Q&PC • Sandra Seemann

8. Quality & Performance Control • Periodic review of program data helps ensure compliance with policies, timely service, program integrity • Some reports help mitigate risk (e.g. of inaccurate benefit) • Duplicate vendor accounts and addresses • Electric mismatch • ERR outliers • Other reports ensure quality, timely service • Aging applications • Aging Crisis payments • Aging PH payments • Unprocessed refunds

9. Dup Vendor & Address Checks Checking for duplicate vendor accounts and addresses is a key risk mitigation activity • Program integrity and audit-ability • Address problems early before they become critical (i.e. catch duplicate vendor account before double payment goes to a HHD) • Dup checks aren’t busy work – we catch stuff • SPs must continue to be responsive to dup checks • OLA examines our records for dups

10. Dup Vendor & Address Checks Provide good responses to dup checks • Give enough info so it’s known what happened & that correct benefit was determined or necessary corrections made • Examples:

11. Electric Mismatch • This shows mismatches between the info in eHEAT and consumption for the HHD • SPs can and should run this themselves (in eHEAT Advanced Search) • DOC also runs these

12. ERR Outliers • ERR is the largest benefit and thus biggest risk • Outside of central payment process • Checking for ERR outliers helps find ERR projects that may be outside program rules

13. Aging Apps, Crisis & PH Payments • Important to ensure timely service to HHDs • SPs can and should check for aging apps and payments on a regular basis • DOC also runs these to notify SP when they have aging apps or payments they may have overlooked

14. State Monitoring

15. State Monitoring Training Topics • Types of on-site monitoring • De-mystifying file review • Purpose of findings & recommendations • Questions

16. State Monitoring Intentions • Conduct oversight to reduce risks to the program, service providers and households • Evaluate SP’s competency for delivering EAP • Ensure program integrity

17. State Monitoring On-site visits • DOC conducts two types of on-site visits • Initial Program Assessment Visit (iPAV) • Full Program Audit Visit (fPAV)

18. State Monitoring Initial Program Assessment Visit (iPAV) Focus • Review findings and recommendations from previous year(s) • Review Local Plan – discuss DOC questions and SP changes • Ensure SP has necessary resources and is ready for FFY14 • File review • Provide Training and Technical Assistance (T&TA) Prior to visit • Send T&TA requests to your Program Performance Auditor • Do not save questions for the visit, send immediately to your PPA or eap.mail

19. State Monitoring Full Program Audit Visit (fPAV) Focus • In-depth review of SP’s program implementation • Review of Primary Heat, Crisis and ERR files • Review payroll records • Inventory • Additional documents as requested Prior to visit • Full Program Audit Tool (fPAT) • Send T&TA requests to your Program Performance Auditor • Do not save questions for the visit, send immediately to your PPA or eap.mail

20. State Monitoring File Sample Review – What do we look for? • PH – 30 files, plus: • 5 Self employment • 5 No income • 5 Denied • All consumption >$5,000 • Crisis – 30 files • ERR – 5 files, plus • All tasks >$5,000

21. State Monitoring File Sample Review – Why so many files? • Statistical significance • Each SP has a “population” of files • We can’t review all of them • By reviewing a random sample of the whole population, we can get a relatively good representation of the whole • Even 30 files out of 1000+ is not entirely representative

22. State Monitoring File Sample Review – Why so many files? • Enables DOC to more accurately know the true nature of any identified issue • For example: • We review 5 files, and 2 have an issue (40%) • Do 40% of all the SP’s files have the same issue? We can’t say… • We review 30 files, and 2 have an issue (~7%) • In this case, we can be more certain that it’s not a systemic issue • We review 30 files, but 12 have an issue (40%) • In this case, we would be more certain that SPs files may actually have an systemic issue

23. State Monitoring File Sample Review – What do we look for? • PH – Application Processing • Applications are dated and signed by applicant • Applications are date stamped and logged the day they arrive • Income statements for all HH members are complete & well documented • Accurate income calculation of the EAP household • Complete documentation verification case notes (Who, When, What) in paper file or in eHEAT • Copies of any correspondence with the applicant, if applicable • Documentation of research done in response to a question, complaint, or appeal, if applicable • Delivery of timely program services • Maintain proper EAP data security practices

24. State Monitoring File Sample Review – What do we look for? • PH – Eligibility Determination • Household member info • Household income documentation & calculation • Housing type and status (e.g., subsidized, heat in rent) • PH – Benefit Amount Determination • All of the above, plus: • Fuel type • Home heating system status (e.g., dual fuel) • Consumption

25. State Monitoring File Sample Review – What do we look for? • Crisis – Eligibility Determination • HH’s past due bills in file or documentation of emergency • Documentation of energy vendor verification • Available PH payments did not resolve the emergency. Check if PH payments were made payable after Crisis benefit determined • SP - HH correspondence notes in file or eHEAT • Check that eHEAT Crisis reason matches documented rationale • Are SPs doing reasonability checks for delivered fuel?

26. State Monitoring File Sample Review – What do we look for? • Crisis – SP Response • For HH in a life-threatening situation the LIHEAP law requires that the threat to life be removed within 18 hours of a household requesting crisis • No heat in the house • No heat distribution • For HHs experiencing immediate energy emergencies that are not life threatening SPs must approve crisis services within 48 hours • Compare crisis reported date to completion/approval/ payment date

27. State Monitoring File Sample Review – What do we look for? • Crisis – Benefit Amount Determination • Compare the crisis amount with the vendor verification documentation and PH benefit amount • Is the SP properly using the Crisis amount and fees boxes in eHEAT?

28. State Monitoring File Sample Review – What do we look for? • ERR – Eligibility • Documentation of proof of ownership (if required) must be in paper file or eHEAT. • Documentation of a qualified dwelling. • Documentation of valid request for repair or replacement, including description of the problem. • Documentation of eligible heating system (e.g., not redundant). • Determine if ERR-related application information matches eHEAT information. • Verify that changes to application are documented.

29. State Monitoring File Sample Review – What do we look for? • ERR – SP Response • For HH in a life-threatening situation the LIHEAP law requires that the threat to life be removed within 18 hours of a household requesting crisis • No heat in the house • No heat distribution • For HHs experiencing immediate energy emergencies that are not life threatening SPs must approve crisis services within 48 hrs • Compare ERR reported date to completion/approval/payment date • Documentation that temporary heat was provided appropriately, if applicable

30. State Monitoring File Sample Review – What do we look for? • ERR – Benefit Amount Determination • Documentation of the contractor's determination of need for response to the ERR request (i.e., need for repair or replacement) • Documentation of "Manual J" calculations

31. State Monitoring File Sample Review – What do we look for? • ERR – Other • Inspection Certificate • 50% of completed furnace replacements & retrofits inspected • Must be inspected prior to contractor payment • Completion Certificate • Required for all repairs & replacements > $1,000 • Signed and dated by homeowner & contractor • Must include model and serial numbers • If inspected, inspector signature • Itemized Invoices

32. State Monitoring Findings & Recommendations • Meant to point out areas that should or must be improved • By identifying areas for improvement, we can take meaningful action • We want to ensure that we: • Deliver the highest quality of service to their communities • Comply with applicable laws • Not meant as punishment or to reprimand • Use the audit as a tool to improve services to HHs

33. State Monitoring Questions During the Program Year • DOC EAP staff are here to help you • Call or email your Program Performance Auditor • Can also email your questions to eap.mail • Emails with private household data must be sent via secure email • Check with your IT staff about how to do this

34. EAP Grant Contract & Allocation of EAP Funds

35. EAP Grant Contract & Allocation Training Topics • EAP Contract • FFY 14 changes • Contract checklist • Contract timelines • Allocation of EAP funds • EAP Fund Line Items • EAP Fund Allocation Determination • Service Providers Obligation Authority

36. EAP Grant Contract Intention: • Authorize grantees to provide program services • To ensure program changes to policy, law or other guidance are complied with by Service Providers By: • Meeting the requirements of state and federal program and contracting laws • Clearly detailing requirements for service providers delivering programs • Clearly detailing program service outcomes

37. EAP Grant Contract Contract address three general areas • Grant administration • Fiscal management • Performance requirements

38. EAP Grant Contract FFY14 Contract Change Termination of contract by the Grantee (Page 6-20.3): • Current: The Grantee may terminate this grant contract at any time, with or without cause, upon thirty days written notice to the State. • FFY14:The Grantee may terminate this grant contract at any time, with or without cause, upon sixtydays written notice to the State. • Current:The Grantee must submit a final invoice to the State no later than thirtydays after termination. • FFY14: The Grantee must submit a final invoice to the State no later thansixtydays after termination.

39. EAP Grant Contract Grant Contract Timeline • August 9, 2013, DOC sent FFY14 Contract to SPs for signatures • September 9, 2013 signed Contract submissions due by 4:00 pm. • By October 1, 2013 DOC executes and distributes contract documents with Local Plan

40. Grant Contract Checklist • State of Minnesota Encumbrance Worksheet • FFY14 EAP Grant Contract • Affirmative Action Certificate • Certification Regarding Lobbying, Debarment … • Current Certificate of Compliance from MN DHS. • Conflict of Interest Policy Statement Exempts: County agencies, Reservations and Service Providers with less than 40 employees • FFY2014 Local Plan (Separately) • Supplements • eHEAT Admin Security Agreement

41. EAP Grant Contract Grant Contract Submission • Make sure signatoriesare available to sign the contract • Return the two contracts with: • Original signatures of the Chair of the Board of Directors or the authorized signatory. • Signature authority from Board of Directors must accompany the grant contract only if person signing the grant contract is not the Chair of the Board of Directors. • Signature of Certifications for Affirmative Action & Lobbying

42. Allocation of EAP Funds EAP Funds Allocation • Budgeting and allocation of EAP funds are among the key components of EAP fiscal management along EAP Fund Line items: Activities include: • Managing budget • Requesting funds • Spending funds in compliance with EAP

43. Allocation of EAP Funds State level EAP Fund management activities • Maintain EAP budget for local allocations • Identify total amount of funds available for local allocations • Establish budget by LIHEAP line items • Establish budget to Service Providers (EAP Line items) • Enter budget limits into eHEAT • Monitor Budget • Update Budget as needed • Maintain eHEAT • Allocate obligational authority to local agencies

44. EAP Fund Line items • Administrative funds: Pay the cost of delivering the local EAP including staff salaries and associated allowable costs • A16 funds: Pay the cost of EAP outreach, referral and advocacy services. EAP Policy Manual describes allowable A16 activities • Primary Heat funds: Pay portion (%) of energy costs for eligible EAP households in residential dwellings • Emergency funds: Pay in addition to Primary Heat funds, for Crisis eligible households experiencing an energy emergency • ERR funds: Address mechanical heating system problems for eligible homeowners.

45. Allocation of EAP Funds Funds distributed by DOC but approved by SPs • Primary Heat Funds (eHEAT) • Crisis Funds (eHEAT) Funds administered by Service Providers • Administrative Funds • A16 Funds • ERR Funds

46. Allocation of EAP Funds Service Providers Obligation Authority • Know the amounts of their EAP fund allocations. • Request cash, as needed (the three-day-cash-on-hand rule applies). • Spend in compliance with LIHEAP policies &procedures • Report their expenditures.

47. Allocation of EAP Funds Factors affecting allocation of EAP funds • Total amount of Federal fund allocated for the year • State level allocation percentage for each EAP fund line items (Based on LIHEAP Statue) • Service Provider’s number of processed applications from previous years • Service Provider’s amount of expenditures from previous years

48. EAP Fund Allocation Determination: Allocations for each EAP funding line items are established using a predetermined process: 1. Allocation MN State LIHEAP fund by each EAP category * The EAPWX* is 5% when admin funds are included

49. EAP Fund Allocation Determination (Cont..) 2. EAP Production: Line items with allocations determined by Previous years’ number of processed EAP applications, Crisis and ERR: • Administrative Funds • A16 Funds 3. EAP Expenditure: Line items with allocations determined current years’ EAP expenditure rate: • Emergency Funds • ERR Funds

50. Admin and A16 Allocation formula Uses the two previous years average of : • # of Approved Apps • # of Crisis Approved • # of ERR Approved • # of Others Apps including: • Total Denied • Insufficient Information • Invalid SSN • Over Income • Subsidized / Heat & Electric Included In Rent