How to Prepare for an OCS Assessment - NASCSP

OUR MISSION 2/24/2018

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A N N U A LTraining Conference

2017

WINTER CONFERENCE

How to Prepare for an OCS Assessment

National Association for State Community Services Programs | www.nascsp.orgNASCSP | How to Prepare for an OCS

Assessment

Panelists

Beverly Buchanan, AR, CSBG Program Manager

Michelle Fields, TN,CSBG Program Director

Kris Schoenow, MI, Executive Director

NASCSP | How to Prepare for an OCS Assessment

Core Values– Compassion– Courage– Respect– Integrity– Trust


VisionArkansas citizens are healthy, safe, and enjoy a high quality of life.

MissionTogether we improve the quality of life of all Arkansans by protecting the vulnerable, fostering independence, and promoting better health.


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Arkansas

• 16 Community Action Agencies

• State Manager and three Grants Analysts

• Housed at the Department of Human Services/Division of County Operations/Office of Community Services

• For FY 2016 our CSBG allocation was $9.6 mil.

– 5% admin– 5% discretionary


Community Social Services Block Grant (CSBG)


Community Social Services




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20 Community Action Agencies covering 95 counties• Non-Profit• Public ( 5 Human Resource Agencies)

• 4 LPAs

Nashville, TN13 million• 95% Pass-through• 5% Administration

4 FTEs – Direct 31 FTEs—Indirect

• Community & Social Services• Adult Protective Services• Child Care• CACFP & SFP• CSBG & SSBG • Family Assistance & Child Support

• SNAP & TANF• Rehabilitation Services

Associations:• TACA• TAHRA

Michigan


The Michigan Department of Health and Human Services ( MDHHS) strives to promote better health outcomes, reduce health risks, and support stable and safe families while encouraging self-sufficiency.

Michigan


Michigan Department of Health and Human Services

Bureau of Community Action and Economic Opportunity

Lansing, Michigan

State Staff 18 FTEsNew/Vacant 10 FTEs

29 Community Action Agencies covering all 83 counties

Community Services Block Grant Weatherization Assistance ProgramEnergy Assistance ProgramSchool Success Program

CSBG $26 MillionWAP DOE $15 MillionWAP LIHEAP $ 6 MillionEnergy $ 7 Million

Annual Budget: $54 Million

Leadership 2 FTEsGrant Managers 5 FTEsProgram Monitors 2 FTEsFinancial Monitors 2 FTEsCSBG 2 FTEsWeatherization 13 FTEsAdministrative Support 2 FTEs


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Michigan


Community Service Block Grant Funding Summary

$- $1,000,000 $2,000,000 $3,000,000 $4,000,000 $5,000,000 $6,000,000 $7,000,000 $8,000,000 $9,000,000

Small

Small to Moderate

Moderate to Large

Large

Extra Large

FY2017 CSBG 90% Allocation Summary for 29 Community Action Agencies

1 Agency

7 Agencies

10 Agencies

5 Agencies

6 Agencies

$351,000

$261,429

$105,000

$258,206

$89,000

$200,000

$- $50,000

$100,000 $150,000 $200,000 $250,000 $300,000 $350,000 $400,000

AssetBuilding

InnovativeProgram

OtherProjects

MinAmount for

Smallagencies

NativeAmerican

Training andTechnicalAssistance

CSBG Discretionary FY2017Allocation Summary

CSBG Final FY2017 Funding Allocations:CSBG 90% $23,306,387CSBG 05% Discretionary $1,294,799CSBG 05% Administration $1,294,799

PREPARING FOR THE STATE ASSESSMENT


IM 102, CSBG Monitoring Checklist



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Preparation

• Initial Indicator: NASCSP advised that OCS had requested CSBG IS Report

• Initial Steps:– Establish perspective, i.e., learning opportunity– Request internal audit– Reference IM 102, CSBG Monitoring Checklist

• Initial Guidance:– NASCSP Webinar—Discussion regarding the OCS Process – OCS Call

• Planning & Logistics (i.e., date, staff, process, and coordination w/other departments)• Entrance / Exit Interview Process• Source Documentation

• Key Steps to preparation (time): 4 months– Documentation:

• IM 102: CSBG Monitoring Checklist• A Self-Assessment Tool for State Offices• State Accountability Measures

– Interdepartmental Planning & Coordination (w/budget, fiscal, procurement, and audit services)– Internal audit


Preparation

• What staff were involved?– Audit Services– Budget– Fiscal– Contracts/Procurement– Legal– Program & Administrative Staff

• Materials gathered:– Source Documents (i.e., general ledger)– Checklist/Work Documents (i.e., CSBG Monitoring Checklist/A Self-Assessment

Tool for State Offices)

• Tools used: – NASCSP Self-Assessment Tool– IM 102, CSBG Monitoring Checklist– State Accountability Measures

• What preparation occurred for the CAA visits?



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Preparation

• Agencies Selected for Onsite Visits 5/10/17– Identified three (3) Agencies

• Coordinated and Advised Agencies 5/10/17– 5/16/17-5/17/17

– Advised they would like to review:– Overview of agency and the community they serve (could include tour of facility or

presentation)– Agency success stories– Present any best practices– Challenges w/state– Challenges w/in community– Anything else agency would like to present or discuss

• During the Entrance Interview—Emailed Agencies 5/15/17 – OCS advised they would like to understand how agencies correlate date

to IS Report.


Preparation Timeline

• OCS Requested CSBG Report Data 4 months prior to assessment 1/19/17• Requested internal audit 4 months prior to assessment 1/20/17• Informal notification via a call 3 months prior to assessment 2/17• NASCSP Webinar: OCS Assessment 3 months prior to assessment 2/24/17• Internal Planning Meeting 3 months prior to assessment 2/27/17• Planning Meeting with OCS 1 month prior to assessment 4/6/17• Source Documentation Sent to OCS 1 month prior to assessment 4/20/17• Coordinated with State Association 1 month prior to assessment 4/20/17

to provide documentation• Reserved rooms 1 month prior to assessment 4/20/17• OCS call/Additional Source 17 days prior to assessment 4/28/17

Documentation Sent• Discussed preparation w/NASCSP 14 days prior to assessment 5/1/17• OCS request for Additional Source 14 days prior to assessment 5/1/17• Documentation• OCS requested DHS to identify 13 days prior to assessment

5/2/17• Agencies demonstrating • best practices/at risk• DHS call with OCS 12 days prior to assessment 5/3/17• OCS Provided Sample Selections 12 days prior to assessment 5/3/17• OCS Discussed Final Preparations 5 days prior to assessment 5/10/17• DHS Coordinated Agency Visits 5 days prior to assessment

5/10/17• Final Preparations with OCS 4 days prior to assessment 5/11/17


Preparation Timeline

• Discussed preparation 14 days prior to assessment 5/1/17w/Jackie Orr, NASCSP

• OCS request for Additional 14 days prior to assessment 5/1/17Source Documentation

• OCS requested DHS to identify 13 days prior to assessment 5/2/17– Agencies demonstrating

best practices/at risk

• DHS call with OCS 12 days prior to assessment 5/3/17• OCS Provided Sample Selections 12 days prior to assessment 5/3/17• OCS Disc. Final Preparations 5 days prior to assessment 5/10/17• DHS Coordinated Agency Visits 5 days prior to assessment 5/10/17• Final Preparations with OCS 4 days prior to assessment 5/11/17



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Michigan


State Preparations for theCSBG State Assessment

Process and Time line• OCS Requested CSBG Report Data 7 months prior assessment 1/19/17• Informal notification via a call 7 months prior to assessment 1/26/17• IM 153 State Assessment 5 months prior to assessment 3/15/17• Informal Planning Meeting Call 3 month prior to assessment 5/23/17• Engagement Letter Email 3 months prior to assessment 5/26/17• Planning Meeting with OCS 3 months prior to assessment 5/31/17• Source Documents Sent to OCS 2 month prior to assessment 6/12/17• OCS Select Onsite Visits 1 month prior to assessment 7/7/17• BCAEO Coordinates Onsite Visits 1 month prior to assessment 7/7/17• OCS Sent Draft Agenda 1 week prior to assessment 7/26/17• CSBG Onsite Assessment 0 Day - Assessment 8/7/17 to 8/11/17• CSBG Exit and Wrap-up 0 Day – Last day of Assessment 8/10/17• Draft Report Received 90 Days after assessment 11/1/17• Response from BCAEO Sent 119 Days after assessment 11/29/17

Michigan



Planning Checklist

• State CSBG Participants: Compile a contact list of all State Staff/State Offices/Upper Management – State CSBG Office Staff– Budget/Accounting/Federal Reporting– Office of Quality Assurance– Contracting Unit

• Upon informal notice of the CSBG State Assessment: – Hold all tentative weeks for the Assessment based on OCS’s request– Hold meeting rooms for the assessment (1 room for the auditors and several for mini meetings

throughout the week)– Send a hold the date email/outlook appointment to the State CSBG Participants– Meet with your CSBG staff to discuss support documentation and location of files (use the IM 102 as

a guide). Create a project assignment list that includes Categories, Descriptions, Staff Name, File Links, Start On Dates, Due Dates, and Completed Dates

– Develop a plan to transfer files to OCS• Our State’s IT department setup a File Transfer Protocol Site (FTP)• OCS was issued a user name and password to the FTP site that enabled them to download files• We uploaded 345 documents to FTP after receiving the Engagement Letter• Use good file naming conventions to help auditors get through the material quickly and easily

MichiganState Preparations for files

Category AreaAgency Site Visit ListAgency Contact ListCSBG Contract Data for HDCCSBG IM 102 - Complete the last column by finding the documentation to

prove compliance. State the name of the document, location of the document, page number and paragraph number

CSBG Tripartite Board Review Procedures (when doing a CAP review, org standards review, monitoring, and special focus review)

CSBG Federal Award Documentation/Reports FY15 and FY16CSBG FY15 Application Packet Process/Amendment Process -

Instructions and TrainingCSBG FY16 Application Packet Process/Amendment Process -

Instructions and TrainingCSBG FY15 Contract Processing in BCAEO (Route/Review Sheet)CSBG FY16 Contract Processing in BCAEO (Route/Review Sheet)CSBG Annual Report Data FY15 (include review process, communication,

& training)CSBG Annual Report Data FY16 (include review process, communication, &

training)CSBG All Federal Approvals in FY15 and FY16CSBG State Plan FY15 and FY16 (including processing, collaboration,

communication, public hearing …)CSBG Past HHS Monitoring Report and Corrective ActionCSBG Annual Report Processing FY15 and FY16CSBG Contract/NFA/Amendments (Explain FY15 and FY16 - give

samples)CSBG Allocation charts FY15 CSBG Allocation charts FY16Financial Cost Allocation Plan and Procedures (FY15 and FY16)Financial CAA Single Audit Review including policyFinancial CTP System PolicyFinancial Procurement Policy - Training ContractFinancial SOE Processing - TrackingFinancial Single Audit Management Decision Letters for CAAs (FY15 and FY16)

Financial General LedgerFinancial Draw Down Procedures and PolicyFinancial Final Federal Reports (Final FFR 2015 and Annual FFR 2016)Financial Michigan Single Audits (FY15 and FY16 include corrective action

plans)Financial Federal Reporting Financial ReportsFinancial Account Codes (FY15 and FY16)Financial SOE/FSR Processing - Approval Process including PAL instructionsFinancial SOE/FSR Processing - Grant Managers Instructions on processing

SOEs/FSRs (step by step) and time frameFinancial Payroll Instruction - DCDS SystemFinancial Accounting PolicyFinancial Main System PolicyMonitoring Tools - ProgrammaticMonitoring Report SamplesMonitoring Monitoring Plan, Schedule, PracticesMonitoring QIPsMonitoring Risk Assessments (include Quality Assurance Risk Assessment

Policy)Monitoring Feedback Letters - Risk Assessments and Annual ReportMonitoring Tools - FinancialMonitoring Tools - Organizational StandardsMonitoring Organizational Standards - Process, instructions, how you

monitorOrg Admin RulesOrg State ActOrg Contract Processing ManualOrg CSBG CSPMOrg PARs - ProcessingOrg FACSPRO (Statewide database) DescriptionOrg Organizational Chart and Key Staff



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Michigan



Planning Checklist

• Planning with OCS Meeting (Call)– Invite all State CSBG Participants on your contact list to the Planning Call with OCS– Make sure all State CSBG Participants receive a copy of the Engagement Letter– When you get confirmation on the CSBG Assessment Date from OCS – Send out a

Confirmation Email/Outlook Appointment to all State CSBG Participants– OCS will go through the Engagement Letter and ask the State to start sending information.

The engagement letter defines the fiscal years being reviewed in the assessment. OCS asked the State to focus on the following financial information first:

• General Ledger (GL) data to include detailed transactions (revenue and expenses ) recorded for the CSBG award during fiscal year ending (FYE) 2015 and 2016 (10/1/2014–9/30/2016), along with the Trial Balances, and detailed Financial Statements.

• Corrective Action Plans for the most recent OMB A-133 Single Audit for FYE 2015, if applicable.

• Draw Down procedures for the PMS reimbursements.

– During this meeting, OCS will ask the State to send recommendations for possible CAA site visits. Specifically, they will ask for the top and bottom performers.

Michigan



Engagement Letter

Category # Category Description PL 105-285 Section

1 Organizational Structure Documents: State Policy and Procedures manual governing CSBG.1

Organizational Chart identifying positions, along with names of key staff.

676

2 Financial and Administrative Documents: General Ledger (GL) data to include detailed transactions

(revenue and expenses ) recorded for the CSBG award during fiscal year ending (FYE) 2015 and 2016 (10/1/2014–9/30/2016), along with the Trial Balances, and detailed Financial Statements.2

Final Federal Financial Reports – Final FFR 2015 and Annual FFR 2016.

Corrective Action Plans for the most recent OMB A-133 Single Audit for FYE 2015, if applicable.

Approved Negotiated Indirect Cost Rate Agreement or the Cost Allocation Plan, if applicable.

Draw Down procedures for the PMS reimbursements. Prior approvals and/ or scope changes, approved budget

revisions, and relevant financial correspondences, if applicable.

675 & 678 (D)

3 CSBG’s Monitoring and other related records: State Monitoring Schedule, along with QIPs or correction

action plans, if applicable. CSBG Information Survey data for FY 2016. Relevant Correspondences, if applicable. Instructions for the Community Action Plan.

678(B), C & (E)

___________________________________1 To ensure for effective and efficient CSBG controls, your organization should include the State regulations/codes, along with written business practices and procedures for the following controls: accounting, fiscal, financial and administrative, procurement, travel, employment, and federal grant management practices to support the CSBG monitoring, QIPs, corrective actions, designation and re-designation of eligible entities, termination & reduction of funding, ROMA and FFR reporting.

2 As a preferred method for submitting the GL and other related financial records, we would like to recommend Excel or a compatible format. Please include the detailed chart of account codes and code descriptions related to each of the GL entries for CSBG. Accompanied with category 2, identify in the GL detailed entries associated with Discretionary and Administrative billed charges by month for the scope period under review (2015 and 2016). Additionally, to ensure transparency over PMS reporting, identify in the GL the payments drawn down from PMS.

Michigan



Planning Checklist

• Planning for the Onsite Visits at the agencies: One month prior to the assessment the State received an email identifying the CAAs that were selected for site visits.

– Notify each agency that has been selected and instruct them to hold the assessment dates. At this point, ask the agency to send you the name and contact information for the Onsite Assessment Coordinator at the agency

– Send OCS the selected agencies information/documents to review• Monitoring Reports• Contract Files• Financial Reports

– Once the State receives confirmation on the date and time OCS will arrive at the agency for the site visit, the State can:

• Develop an agenda with the assistance of the Onsite Assessment Coordinator• Ensure all relevant staff will be present for the meeting• Setup a call with the agency to help prepare them for the visit, as needed• Make sure information such as maps, parking, floor numbers, meeting room, phone number, and

contact information for the Onsite Assessment Coordinator is shared with OCS prior to the visit• One week prior to the onsite visit, conduct a check-in meeting

• Planning for the Onsite State Visit: Upon confirmation of the assessment dates and receipt of the basic draft agenda, complete the following

– Finalize the details for the Entrance Conference and the Exit Conference: Send a confirmation email/outlook appointment to all State CSBG Participants and to OCS.

– Develop a detailed agenda by operational areas for OCS, make sure a conference room is reserved, and the content area staff for a topic is invited to the appropriate meeting.


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Michigan


State Preparations for theCSBG State AssessmentDraft Agenda and final

ON-SITE VISIT


On-site Visit

• What materials did you have available?• What other materials were requested?• How long was the visit?• Who participated in the on-site visit?

– What state staff?• Their roles/responsibilities/departments

• Did you prepare a presentation for the initial meeting?• Describe visits with CAAs:

– Process– State involvement– Feedback from CAAs



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OCS Onsite Assessment

• May 15, 2017-May 19, 2017

– Entrance Interview 5/15/17• OCS Provided PowerPoint• Present: Audit Services, Fiscal, Program, Executive Leadership• Reviewed process and key points

– Onsite Assessment• OCS Interviews with Audit Services, Fiscal, and Program• OCS requests of additional documentation as needed

• Contracts• Agency Contracts• Contract Process• Central Procurement Procedures/Link

• Legislative Hearing Information


OCS Onsite Assessment

• Agency Onsite Visits 5/16/17-5/17/17– Identified three (3) Agencies

• Advised they would like to review:– Overview of agency and the community they serve (could include tour of facility

or presentation)– Agency success stories– Present any best practices– Challenges w/state– Challenges w/in community– Anything else agency would like to present or discuss

• Emailed Agencies re: Onsite Visits 5/15/17– During the Entrance Interview OCS advised they would like to

understand how agencies correlate date to IS Report.

• Provided Agency Community Action Plans 5/18/17


Michigan



Onsite

• What materials did you have available?– Financial Interviews

• Explain the draw down procedure. • Explain cost allocation• Explain financial monitoring• Explain payment processing• Explain how financial areas work with the

program areas in the state• Ask to provide more information on a couple

of expenditures• Demonstrated our Risk Assessment

– Programmatic• Explain policies and procedures• Explain monitoring• Explain the development of the State Plan• Explain how the state complies with the

tripartite board requirement (be prepared to provide a report on each agency’s board seats)

• Explain discretionary funding• Explain training and technical assistance

• How long was the visit?– Four Days with 3 onsite visits– 5 OCS Auditors

• Who participated in the on-site visit? What state staff?– BCAEO (Directly connected to CSBG)

• Executive Director Finance/Program/Monitoring• Deputy Director Finance/Program• CSBG Specialist Program• Monitors Finance/Program• Grant Manager Program

– Accounting Department• Budget Director Cost Allocation• Budget Analyst Finance• Accounting Manager Finance/Draw down• Federal Rept. Manager Finance/Draw down• Federal Rept. Analyst Finance/Draw down

– Office of Quality Assurance• QA Manager Risk Assessment/oversight

– Department’s Contract Unit• Department Analyst Finance/Program


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EXIT INTERVIEW, OCS REPORT/ RECOMMENDATIONS AND STATE FOLLOW-UP


Exit InterviewsOCS Recommendations

• Exit Interview– Process– Who was involved?

• Draft/Final Report– Recommendations– Findings


State Assessment Observations

Items for Considerations Arkansas may want to consider implementing an

attestation tool to address areas of non-compliance or deficiencies in the Tripartite board composition.

Should reach out to Head Start liaison for updates on their Eligible Entities, potential training to staff to understand basic requirements of eligibility

Arkansas may want to redefine how findings or deficiencies are presented for clarity.

The time frame from a monitoring report and the time the State takes to address the deficiency

May want to reconsider voucher receivable process ( could lessen the burden, more cost effective, )



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Highlights

Positives:

• Audit Department reviews eligible entities single audit for different programs

• Monitoring relationship with Eligible Entities is very close

• Quarterly Meetings with Entities and Association

• Has 14 ROMA trainers within the State

• Drug Treatment facilities run by agencies within urban populations


Exit Interview/OCS Recommendations

Exit Interview (OCS provided PowerPoint) 5/19/17• Present: Audit Services, Fiscal, Program, Executive Leadership• Reviewed best practices, site visits, key observations, findings and

process

– Best Practices• Robust Accounting System (Edison)• Monitoring Tools (Community Action Partnership Tools, et al )

– Site Visits• Comprehensive Case Management Tracker and state required all

agencies use tool• STAR (Self-Sufficiency Training and Results) Program• Inside Out Dads Program; transportation, and audit trails



– Observations• Costs incurred after end of contract period; OPM requested amended SF-425

with explanation of adjustments

– Findings• Timeliness of the award of contract (9 month delay) seen as a reduction in

time funds are available

Recommendations:• Increase the length of time funds available to eligible entities; consider issuing

the award upon availability and consider issuing through the end of the grant period.

– OCS Reporting Process• Formal draft report within 60 days• State has 30 days to respond• State response should include Corrective Action Plan for all noted deficiencies

(if applicable).• If needed, a teleconference maybe held to further discuss and resolve any

disagreements



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• Draft Report Received 11/17/17• Coordinated Internal Response• DHS Questioned Response Date 11/30/17

– Dated 11/9/17; Rec’d 11/17/17• Response from DHS Sent 12/12/17

Key Learning: Use “A Self-Assessment Tool for State Offices” to provide new worker orientation, organize your files, and assure compliance of the CSBG Performance Management System


Michigan



Exit Conference

• OCS developed a PowerPoint for the Exit Conference

– Best Practices• Statewide Database ( Repository system )• STAR Assessment ( Risk Assessment tool)

– Site Visit Summary• Pleased with visits, agencies suggest that BCAEO combine our conference with the State Association• OCS was very interested in the Shared Services Agreement between a strong agency and a weaker

agency that is rebuilding

– State Assessment Observations • Non compliance with State and Federal Regulations regarding Tripartite Board

– BCAEO policies and procedures require vacancies to be filled within 90 days .– Nine entities with tripartite board vacancies that exceeded 90 days.

• Opportunities for Improvement– Review tripartite board vacancies more frequently to ensure compliance with filling vacancies within 90 days as noted in

the state’s policies and procedures.– Establish process to review by-laws to ensure tripartite board information in Statewide database is accurate.

• General Ledger Testing – One instance of unallowable charges to CSBG

Michigan


State Preparations for theCSBG State AssessmentDraft Report Summary

Issue of Non-Compliance

FINDING ONE: TRIPARITITE BOARD- Partially Compliant OCS found that a number of the local eligible entities within the State of Michigan were not in compliance with state and federal requirements governing Tripartite Boards. As required under Section 678B of the CSBG Act, entities' boards must be comprised of at least one third representatives of low-income individuals and families, one third elected officials (or their appointees), and the remainder business, industry, labor, religious, law enforcement, education, or other major groups and interests in the community served.

OCS noted that the state has a policy for the eligible entity compliance with the Tripartite Board requirement. However, among the 29 local eligible entities within the State of Michigan, nine (9) out of 29 board vacancies' positons had not been filled within the prescribed 90 days. During observations, OCS noted the majority of 9 board vacancies existed in the sector of public elected officials.

Required Action(s)MDHHS must additional steps to enforce its Tripartite Board policies and follow a course of action to ensure routine compliance with Tripartite Board requirements throughout the Michigan CSBG network.


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How to Prepare for an OCS Assessment - NASCSP

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