Welcome to Compliance Clips!
A service which will provide useful tips and information in compliance that you need to know!
It will be a new year for a comprehensive review of your agency’s compliance status. Our Compliance Accountability Program can identify critical improvements on Day 1! A budget for every agency. Let us review for internal controls, fraud prevention and adherence to government regulations to protect your agency in an audit! Happy New Year!
Did you know that documentation will be the key to a successful audit? Do you have a plan? Time record keeping and proper allocations are the most reviewed area in an audit and the most costly. You must have knowledge and a proper internal control system to ensure the following guidelines are implemented:
- CFR Manual Appendix R list the position title codes and qualifications.
- CFR Appendix J includes the allocations both allowable and recommended.
- CFR Appendix L Reviews the time study guidelines.
An audit will also focus on time sheets, time studies, job descriptions and authorization for pay rates. An agency must implement a continual compliance plan to ensure audit compliance.
If your agency is subject to Executive Order #38 (“EO #38) and therefore a Covered Provider, the deadline for filing the report is December 31, 2018 for Fiscal CFR filers, and June 30, 2018 for Calendar CFR filers. If your agency does not file a CFR, your agency can choose your filing date and covered period. Step 1 is to determine if your agency meets criteria namely the $500,000 SF/SAP requirement and 30% SF/SAP of total in-state revenue requirement to be a Covered Provider. Step 2 If the answer to Step 1 is Yes, are you in compliance with the 15% Administrative Expense Limitation? Step 3 Do you have Covered Executives in compliance with the $199,000 threshold? Now is the time to review your options and set up your books and records to ensure your compliance!
Did you know that your preparation of the Consolidated Fiscal Report (“CFR”) could be more efficient and compliant if you prepare and plan the steps with a CFR Action List? This list can outline responsibilities and adherence to CFR manual appendices and help to manage deadlines.
Are you familiar with Appendix L of the CFR Manual? This appendix provides instructions on completion of time studies if an employee works in more than one program.
The key to effective time studies is to have a clear job description that summarizes the duties into PTC codes and programs. Then determine who must complete a study by preparing a grid by employee, PTC and program. Determine the time study weeks in accordance with Appendix L.
Establish an instruction sheet for employees to follow. Training of employees on the proper completion and the importance of the study is critical.
Do you know you must have a job description to support the CFR PTC codes? The description must identify and spell out the responsibilities of a specific job and the programs they work. Job descriptions also include information about knowledge and skills needed, and relationships with other positions. The description must align and “fit” within the CFR Appendix R information: education & licenses.
Do you know when you are audited by a government agency they will ask to review your Internal Control Manual? Having an effective internal control manual will not only mitigate Fraud but will help efficiency in operations, reliability of financial reporting and compliance with applicable laws and regulations.
If you are an SED provider, it is stated in the RCM that you must have an adequate internal control system and perform risk assessments. Review your system today. To be effective your internal control system must be reviewed for updates, monitored and employees must be trained.
Do you know that allocations of staff and expenses can play a key role in your ability to be under the administration maximum limit of 15% .An allocation basis (in accordance with CFR Appendix J) can allocate costs directly to the programs and therefore help to keep your agency in line with 15%. Compensation reviews and approvals from Board of Directors are essential in getting waivers and being in compliance with Covered Executive Status.