How To Ensure Compliance With The Drug Abuse Program

Transcription

1 Commission on Alcohol and Drug Abuse Reference No Strengthen the Control Environment Over the Program Services Division A weakness exists in the Program Services Divisions (Division) control environment over the administration of substance abuse programs. The weakness has resulted in a lack of necessary documentation and adherence to established procedures designed to ensure compliance with the Block Grants for Prevention and Treatment of Substance Abuse (CFDA ) program (SAPT). The risk to the Commission on Alcohol and Drug Abuse (Commission) is that allowable services may not be consistently provided in an efficient and economical manner. Create and implement formalized contracts to be signed by all parties for new and revised awards. Start the contracting funding process early enough so that contracts are finalized by the cut-off date for obligating SAPT block grant funds. Implementation of this recommendation will be completed in three phases: 1. Develop a policy and procedure: This phase was completed in June, With few exceptions, contracts for FY 1998 were signed and entered as such in the system; 2. Save a copy of the 9/30/XX File: This was done on 9/30/98. The purpose of this process is to provide a record of the obligations as of the SAPT Block Grant cutoff date. 3. Run report reflecting obligations: This report is in the development process. Completed 6/98. Comply with the established policies and procedures regarding the clearance of refunds from the Suspense Fund. Implemented February The Commission implemented procedures in February 1998 to begin the process of clearing the Trust and Suspense account. Through the end of August 1998 we were able to reduce the Trust and Suspense account from $501,413 to $24,772. Follow and document established award contract funding procedures and rules. Partially implemented. Program Management staff followed procedures and documented their reviews.

2 SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS All providers that received continuation funding were required to submit a continuation application for review by Commission Staff. The continuation application requests that each provider to submit any changes from the prior year to include target population, program design and methodology, outcomes, and justification for funding at the current level. Copies of the continuation applications for prevention and treatment are available. Program management and program services reviewed each of the applications and documented the reviews. The program services contract finding reviews were documented on the form attached. Records indicate that 85% of the program reviews were performed and documented. In addition to the reviews above, provider performance measures are reviewed twice a year for each provider and requests for corrective action are sent if necessary. In FY98, all treatment providers were formally reviewed with program staff and evaluation staff specifically in regard to their performance measures. Comply with procedures to review subrecipient monitoring findings FSRs for unallowable costs and cash on hand. Partially implemented. In the transition of data in our management information system from the Grants and Contracts System to the Source, access to prior year data was not available until late into the second quarter of fiscal year Management s decision was to waive the first quarter review. Review of Financial Status Reports (FSR) for the second and third quarter were completed and letters were sent to Providers to notify them if they appeared to have excess cash on hand. A fourth quarter review is not conducted because any excess cash on hand will be identified through the contract close-out process. In regards to reviews for unallowable costs, contract specialist review initial budgets submitted by Providers to determine if unallowable costs are included in the budgets. Also throughout the fiscal year, as FSRs are submitted, automated edit checks are performed to determine if FSRs exceed budgeted line items that require prior approval. Provide timely notification to subrecipients regarding federal funding award information. Implemented 9/97. The Commission notifies sub-recipients of award funding sources by mailing a copy of the payment voucher. The voucher identifies the CFDA Title and number, provider name, number, year and federal awarding agency. Reference No Improve Administrative Controls Over Federal Requirements (Prior Audit Issue , 5-114) Although the implementation of monthly variance reports has improved monitoring capabilities, the Commission on Alcohol and Drug Abuse (Commission) continues to lack sufficient accounting procedures and fiscal controls to monitor and report spending activities in the Block Grants for Prevention Initial Year Written: 1994 SAO REPORT NO AND COMPLIANCE AUDIT RESULTS JUNE 1999

3 and Treatment of Substance Abuse (CFDA ) program. Supervisory review of all federal reports: The first step was implemented 8/1/98 by establishing the Office of Federal Reporting (OFR). The OFR will be responsible for completing all reports, as well as, the financial parts of all grant applications. The OFR is directly supervised by the Assistant Deputy to assure an appropriate level of detailed review. Policies are being developed to further clarify the roles and responsibilities of the OFR. This should be completed by 8/31/99. Maintenance-of-Effort calculations: Consistent Procedures - A procedure was established and used to restate the MOE for all years. Under this procedure, expenditures in each years AFR, for certain types of general revenue, would be aggregated for the MOE total. However, further evaluation has shown that this approach has flaws relating to timing and backlog differences between years. A different procedure is being established and will be used consistently thereafter. Qualifying Expenditures - In the restatement process mentioned above, qualifying expenditures were applied consistently. This will be the basis of a formal policy. A comprehensive MOE policy will be adopted by 8/31/99. Documentation supporting reported data: Contact TDH to assure adequate documentation. Policies and procedures are being developed. Reports from automated system are also being developed. Federal report cross-training: After the OFR is fully established, cross-training will take place. Reference No Internal Audit Function Needs Improvement The internal audit function should be improved to more effectively assist the Board of Commissioners and executive management in the discharge of their responsibilities. Status: Implemented Corrective action was taken.

4 SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Reference No Improve Procedures for Collection of Questioned Costs No procedures exist establishing criteria for repayment of subrecipient questioned costs. Corrective action was taken. Status: Implemented Reference No Improve Controls Over Independent Peer Review Process The Commission on Alcohol and Drug Abuse (Commission) does not have adequate controls over the independent peer reviews of funded treatment programs to ensure compliance as required by the Block Grants for Prevention and Treatment of Substance Abuse (CFDA ) program. During FY 1998, TCADA took action to ensure that programs selected for independent peer review are representative of all funded treatment programs in the state and all necessary forms related to peer review are obtained and other information is documented. TCADA s plan of action included: (1) Revised PRQIP procedures; and (2) Training peer reviewers and the PRQIP Steering Committee on the revised procedures. Revising PRQIP Procedures. Included in the revised procedures are guidelines for planning and implementing the independent peer review. The guidelines address topics like the site selection process. During the FY 1998 PRQIP process, TCADA used stratified random sampling as its mechanism for selecting sites and ensuring that the programs selected for review are representative of all treatment programs funded in the state. This means that the programs were stratified by region, then randomly selected. For example, if a region had four programs operating within its boundaries, one program was randomly selected from the pool of four programs. This process was applied to each of the regions until a program from each region was selected. This sampling mechanism took into account geographic distribution, cultural and ethnic populations, and rural/urban representation. There were 164 funded programs in Texas at the time of the selection process. SAO REPORT NO AND COMPLIANCE AUDIT RESULTS JUNE 1999

5 To ensure that all necessary forms related to the peer review were obtained and other information documented, TCADA staff reviewed individual peer reviewer and treatment program information during the May 1998 meeting. TCADA staff followed up with the peer reviewer and PRQIP Steering Committee member if required documentation was missing. As part of the planning for the FY 1999 PRQIP, TCADA will revisit these procedures and make revisions (if appropriate). Training. Peer reviewers and PRQIP Steering Committee members were trained on the revised procedures in March of Peer reviewers and PRQIP Steering Committee members were trained prior to their conducting site reviews. Reference No Improve Procurement Procedures Related to Federal Requirements The Commission on Alcohol and Drug Abuse s (Commission) Goods Procurement Department does not have procedures in place to address federal requirements related to suspension and debarment. We prepared a memorandum to correct the 1997 finding regarding vendor debarment on procurements over $100,000. With the release of the memorandum we implemented a practice that ensures compliance with the circular. This information will be included in our agency-wide policies and procedures manual when it is developed.